The short answer
- Most “certificates” buyers ask for in fiber packaging are actually one of three different things: a regulation, a certification scheme, or a supplier declaration.
- Food contact is a declaration, not a certificate — FDA regulates substances under 21 CFR 176.170 and 176.180, and does not certify packaging.
- RoHS (2011/65/EU) covers electrical and electronic equipment, not packaging. Suppliers issue a materials declaration so a tray can ship alongside a device.
- Compostability is the one item where a certificate number exists — EN 13432, BPI or AS 5812, issued against a specific grade, not a factory.
- PPWR (Regulation (EU) 2025/40) is law, not a certification. There is nothing to “get” — there is a compliance position to document.
Procurement teams ask molded pulp suppliers for “certificates” and usually receive a folder that mixes three unrelated document types. This page separates them, states which document proves which claim, and lists what is reasonable to request before you specify a grade for a regulated market.
Three things buyers call “certification”
| Type | What it is | What you receive |
|---|---|---|
| Regulation | Law that applies to the product in a market — EU PPWR, FDA food-contact rules, RoHS | A declaration of compliance and supporting test reports. No certificate exists |
| Certification scheme | Third-party assessment against a published standard — EN 13432, BPI, FSC, ISO 9001 | A certificate with a number and a scope, issued to a specific grade or site |
| Supplier declaration | A signed statement by the manufacturer, sometimes backed by lab data | A signed document on letterhead. Its weight depends entirely on the test data behind it |
Almost every dispute about molded pulp “certification” comes from treating one row as another. A supplier who answers “yes, FDA certified” to a food-contact question has mislabelled a declaration as a certificate — and a buyer who repeats that in an audit is exposed.
Food contact: what an FDA declaration for molded pulp covers
In the United States, food-contact paper and paperboard are regulated through the component-substance provisions of 21 CFR: 176.170 for aqueous and fatty foods, and 176.180 for dry foods. The FDA does not certify packaging; it defines which substances may be used and under what conditions, and the supplier declares that the grade complies.
A usable declaration states four things: the CFR sections relied on, the pulp grade and any coating, the intended food types and conditions of use, and the migration test data behind it. Ask for all four — a one-line “FDA approved” letter is not a declaration.
We supply FDA food-contact declarations for the food-grade grades we produce, with the underlying migration test data. If your application involves a coated or grease-resistant grade, the coating is part of the declaration and must be named in it.
Electrical markets: why RoHS shows up in a packaging RFQ
RoHS (Directive 2011/65/EU, as amended) restricts hazardous substances in electrical and electronic equipment. Packaging is not electrical equipment, so a molded pulp tray is outside the directive’s scope. The request still arrives, because the tray ships in the same box as the device and the buyer’s compliance file covers the whole shipment.
What a supplier can legitimately provide is a materials declaration: the substance list screened against RoHS limits — 0.1% by weight for lead, mercury, hexavalent chromium, PBB and PBDE, 0.01% for cadmium — with the test method and the lab named. That is what we issue for electronics packaging programs, and it is the document your compliance team can actually file.
PPWR: what EU packaging law asks of molded pulp
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, replaced the old directive approach with directly applicable rules and entered application in 2026. It touches molded pulp on five points that matter to a buyer:
- Recyclability — design requirements for what goes into the waste stream.
- Recycled content — minimum shares, phased in by format.
- EPR registration — producer responsibility data per member state.
- PFAS restrictions — food-contact packaging is explicitly targeted.
- Empty space ratio — limits on air shipped inside a carton, which is where a nested tray helps.
There is no PPWR certificate and no body that issues one. What exists is a compliance position: which SKUs meet which requirement, which documents support it, and what is still open. Our PPWR readiness programme is in progress; ask for the current status sheet for your grade and destination before you specify, and we will tell you what is documented and what is not.
Compostability: where a molded pulp certificate number matters
Industrial compostability is assessed against EN 13432 in the EU, certified by BPI in the US, and against AS 5812 in Australia. Standards are published through CEN. Three tests sit behind any claim: disintegration, biodegradation, and ecotoxicity, plus limits on heavy metals.
Two practical rules. First, a certificate covers a grade, not a factory — the same supplier can hold a certificate for uncoated bagasse and none for a coated variant. Second, a waterproof or grease-barrier coating usually removes compostability, so a pack cannot be both moisture-resistant and certified compostable unless the coating itself is covered. “Biodegradable” with no certificate number is a marketing word; ask for the number and the scope.
Protection testing: ISTA 3A and ASTM D5276 on molded pulp
Nothing certifies that a tray protects a product. What exists is a repeatable test: ISTA 3A for parcel distribution, or a drop test to ASTM D5276 on the loaded container. A usable report states the drop height, which faces were dropped, the packed weight, the product configuration, and the inspection criteria — plus what changed between a failed and a passed iteration.
A damage-rate percentage without the protocol behind it is not evidence. Ask for the report, then ask what was changed to make it pass; the second answer tells you whether the supplier engineers or guesses.
What to request in a molded pulp RFQ
Eight documents cover a molded pulp order. Ask for them before tooling, not after the first batch ships.
- FDA food-contact declaration naming the CFR sections, the grade and the coating, with migration data.
- RoHS materials declaration with limits, test method and laboratory.
- PPWR status statement for your destination market — documented items and open items.
- Compostability certificate number and scope, if compostability is a requirement.
- Drop-test report to ISTA 3A or ASTM D5276 on your packed configuration.
- Heavy-metal and migration test report for the specific grade.
- Which documents are issued per shipment versus once per grade.
- Who signs the declaration, with a name and a title you can file.
Certification FAQ
Is molded pulp packaging FDA approved?
There is no FDA “approval” for packaging. Food-contact paper and paperboard comply with 21 CFR 176.170 and 176.180, and the supplier issues a declaration of compliance. Ask any molded pulp supplier for the CFR sections, the grade, the coating and the migration test data — that is what an auditor will look for.
Does packaging need RoHS?
No. RoHS covers electrical and electronic equipment, and packaging is outside its scope. Buyers still request a declaration because the pack ships with the device, so suppliers issue a materials declaration screened against RoHS substance limits.
Is there a PPWR certificate?
No. PPWR is a regulation, and compliance is a documented position rather than a certificate. Ask a supplier for their PPWR status per SKU: recyclability, recycled content, EPR data, PFAS position and empty-space ratio.
Can a coated tray still be compostable?
Usually not. Waterproof and grease-barrier coatings typically remove industrial compostability, and a certificate covers the specific grade. If you need both moisture resistance and compostability, the coating has to be inside the certified scope — ask for the certificate number and read the scope line.
Which document proves the packaging protects the product?
A test report, not a certificate: ISTA 3A for parcel distribution or ASTM D5276 for drop testing, on your packed configuration, with the height, faces, weight and inspection criteria stated.
Next step
Send the destination market and the product category, and we return the document set that applies to your grade — declarations, test reports and the PPWR status — before you commit to a tool.
Request the compliance document set →
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