Overseas Compliance Checklist: New Export Thresholds for Fresh Food Packaging Films Revealed at 2026 MOREFOOD EXPO
From March 5–7, 2026, the 2026 MOREFOOD EXPO · Shanghai will be held at the National Exhibition and Convention Center. As a 150,000-square-meter flagship global exhibition for catering ingredients, this year marks not only the launch of a newly established international pavilion, but also a pivotal year in which multiple global food contact material regulations officially take effect.
For exporters of fresh food packaging films, 2026 represents a critical compliance upgrade window. At this exhibition, what overseas buyers may hand over is not merely a purchase order—but a compliance questionnaire. The event offers a valuable opportunity to observe overseas regulatory trends and market access requirements at close range.
Export Compliance: Regulatory Red Lines Behind Buyer Questionnaires
1.1 EU Buyers: "Does Your Film Contain Bisphenol A? Can You Provide a DoC?"
This has become a standard question from EU procurement teams in 2026.
On December 17, 2025, the European Commission released the BPA ban implementation guidance (C/2025/6721), clarifying:
- Scope of application: Adhesives, rubber, ion-exchange resins, plastics, printing inks, silicones, varnishes, and coatings intended for food contact.
- Restricted substances: Intentional use of Bisphenol A (BPA), its salts, and five CMR/ED-class bisphenol derivatives (including Bisphenol S and Bisphenol AF) is prohibited.
- Testing requirements: Where other permitted bisphenol derivatives are used, residual BPA testing is required, with a detection limit of 1 μg/kg.
- Declaration of Compliance (DoC): All regulated products must be accompanied by a DoC issued and transmitted by the operator.
For fresh packaging film exporters, BPA compliance has shifted from a technical detail to a formal market entry condition.
1.2 Japanese Buyers: "Do You Have ISO 17025 Test Reports? Can You Provide a Migration Substance List?"
On December 27, 2025, Japan's Ministry of Agriculture, Forestry and Fisheries released the Draft List of Hazardous Chemicals for Priority Risk Management, covering 34 substances categorized under three management levels.
Simultaneously, the Mid-Term Monitoring Plan for Hazardous Chemicals in Food (FY2026–2030) confirmed:
- Priority monitoring substances: Lead, cadmium, arsenic, methylmercury, acrylamide, 3-MCPD fatty acid esters, glycidyl fatty acid esters, and PFAS (per- and polyfluoroalkyl substances).
- Laboratory requirements: All analyses, in principle, must be conducted by laboratories accredited to ISO/IEC 17025, using validated analytical methods.
- Monitoring cycle: Continuous monitoring from 2026 to 2030.
This means that exporting packaging films to Japan requires not only migration test reports, but also proof that the testing laboratory itself meets ISO 17025 accreditation standards—effectively raising the access threshold.
1.3 A Global Baseline Question: "Does It Comply with REACH and RoHS?"
Although REACH and RoHS regulations primarily target electronic products, EU buyers increasingly treat them as baseline compliance references.
In particular:
- REACH requirements regarding Substances of Very High Concern (SVHC) notification
- RoHS restrictions on hazardous substances
These frameworks are gradually becoming implicit entry criteria for food contact packaging materials, especially in cross-border procurement.
Packaging Adaptability: Technical Demand Profiles Across Markets
2.1 Vacuum Skin Packaging (VSP) in the Seafood Sector
The adoption of Vacuum Skin Packaging (VSP) in seafood applications is accelerating.
Nordic seafood exporters are embedding origin certification labels to comply with strict transparency regulations, driving demand for VSP formats suitable for refrigerated logistics. Leading international packaging companies have developed seafood-specific VSP systems that remove oxygen and provide tailored barrier performance, extending shelf life while preventing purge leakage inside the pack.
2.2 Balancing Lightweighting and Functionality
Global packaging innovators have introduced high-performance flexible films such as Multifol Extreme, which are approximately 30% lighter than traditional PA/PE structures. A 150-micron film can replace a 200-micron thermoforming film without compromising protection performance, reducing material consumption and transportation costs.
Anti-fog technology has also become critical in cold chain packaging. Companies such as Cosmo Films have launched anti-fog BOPET lidding films using advanced coating technologies to prevent condensation formation. These films maintain clarity throughout storage and retail display and can extend the shelf life of fresh products by 4–5 days, effectively addressing condensation challenges in refrigerated environments.
Strategic Response Pathways for Export Enterprises
3.1 Establishing a Traceable Compliance System
Exporters should first conduct a comprehensive review of controlled substances potentially present in existing products, including bisphenols, PFAS, and heavy metals.
Key actions include:
- Collaborating with upstream suppliers to develop bisphenol-free alternatives
- Focusing on technical routes such as EVOH, PVDC, and MDO-PE
- Commissioning ISO 17025-accredited laboratories for residual and migration testing
- Establishing a documentation transmission system to ensure accurate issuance and retention of Declarations of Compliance (DoC)
Compliance documentation management is becoming as important as product performance itself.
3.2 Evaluating Recyclability Grades
According to the EU's packaging recyclability assessment guidelines, packaging will be categorized into four grades: A, B, C, and D.
Exporters should:
- Evaluate current products against recyclability criteria
- Initiate improvement plans for lower-grade structures
- Prioritize mono-material high-barrier solutions such as MDO-PE or full PE/PP structures
- Participate in certification programs and obtain recyclability documentation in advance of the unified labeling requirements expected from 2028
By 2030, recyclable material usage is projected to reach 45%, making recyclability no longer optional but structural.
3.3 Adapting to Regional Market Differences
- EU market: Prioritize BPA and PFAS compliance; ensure recyclability grade C or above.
- Japan market: Prepare ISO 17025 laboratory reports in advance and monitor the 34 priority-controlled substances.
- Southeast Asia: Enhance performance stability in high-temperature and high-humidity environments while maintaining cost competitiveness.
- North America: Monitor recycled resin price fluctuations and balance recyclable design with cost control strategies.
Market segmentation increasingly defines technical development direction.
Frequently Asked Questions
Two primary regulations require close attention:
BPA Ban (EU) 2024/3190 and Amendment (EU) 2026/250
The regulation prohibits intentional use of BPA and five CMR/ED-class bisphenol derivatives (including Bisphenol S and Bisphenol AF). The residual detection limit is 1 μg/kg. Products must complete compliance transition by July 20, 2026 or July 20, 2027, depending on category.
Packaging and Packaging Waste Regulation (PPWR)
Fully applicable from August 12, 2026, PPWR requires packaging to be recyclable, contain minimum recycled plastic content, prohibit PFAS and excessive packaging, and mandate manufacturers to issue and retain a Declaration of Compliance (DoC).
Japan's requirements focus on hazardous chemical management. The priority list published by the Ministry of Agriculture, Forestry and Fisheries includes 34 substances, with PFAS, heavy metals (lead, cadmium, arsenic), acrylamide, and 3-MCPD fatty acid esters among priority monitoring items.
All analyses must, in principle, be conducted by ISO/IEC 17025-accredited laboratories using validated analytical methods with proper accuracy management. Exporters must identify potential migratory substances in packaging materials and prepare compliant test reports aligned with Japanese monitoring standards.
Recyclability requirements are tightening rapidly:
- Under PPWR, from 2030 onward, all packaging must achieve at least Grade A, B, or C recyclability; Grade D packaging will be banned from the EU market.
- From 2038, only Grade A or B packaging will be accepted.
- Plastic-containing packaging must include minimum percentages of post-consumer recycled content from 2030.
- From 2028, packaging must carry harmonized pictogram labels indicating recyclability and sorting instructions.
Mono-material PE/PP high-barrier designs are emerging as a major R&D focus in response.
The 2026 MOREFOOD EXPO · Shanghai brings together professional buyers from 16 countries, offering a unique window into global demand trends for fresh food packaging films.
From a compliance perspective, the EU BPA ban and PPWR are elevating market entry thresholds. From a recyclability perspective, sustainable design is shifting from a value-added feature to a mandatory requirement. From a functionality standpoint, demand for MAP, VSP, and anti-fog technologies continues to grow.
For export-oriented packaging film enterprises, understanding overseas buyer priorities, closely tracking international regulatory developments, and continuously enhancing technical adaptability will determine their ability to capture global opportunities. At the international pavilion of MOREFOOD EXPO, these trends are no longer theoretical—they are being translated into concrete procurement requirements.
