Reviewing materials and documentation for each product code

An exported bag of cashews may be made from multilayer laminated film to prevent oxygen and moisture from entering. When a business considers switching to a structure that is more suitable for recycling, the new packaging must be retested for its ability to preserve product quality, seal integrity, and compatibility with existing packaging lines. Changing packaging materials therefore involves a series of technical, cost, and product quality decisions.

This scenario was presented at the 2026 Vietnam International Food Industry Conference, held in Ho Chi Minh City as part of Vietnam Foodexpo 2026. From requirements for food-contact materials to the roadmap for designing recyclable packaging, discussions at the conference highlighted the need for businesses to review their packaging practices from the material procurement and product development stages.

According to Dr. Ngo Xuan Nam, Deputy Director of the Viet Nam SPS Office, businesses need to consider three groups of requirements simultaneously. The first concerns the safety of food-contact materials, including controls on substance migration and material traceability. The second covers environmental requirements under Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR). The third relates to labeling information, including how the environmental attributes of packaging are communicated to consumers.

Under the regulation, the PPWR has generally applied since August 12, 2026, to packaging placed on the E.U. market, including packaging used for imported goods. Among the requirements businesses need to review immediately are restrictions on PFAS in food-contact packaging, technical documentation, and declarations of conformity based on the respective roles of the parties involved. Requirements concerning harmonized labeling, recyclability grades, and recycled plastic content will follow separate implementation timelines. The application dates for certain provisions will also depend on implementing legislation.

The review must cover every component of the packaging. Grease-resistant paper and molded pulp packaging were among the material categories highlighted in the conference presentations for potential PFAS risks. Regarding bisphenol A (BPA), businesses need to pay attention to can coatings, lids, printing inks, and laminating adhesives, depending on the packaging structure. The presentation also identified a separate transitional deadline of January 20, 2028, under Commission Regulation (E.U.) 2024/3190, for certain single-use food-contact articles used to preserve fruit, vegetables, and fishery products. This is particularly relevant to canned food producers when planning trials of alternative coatings and working with can and lid suppliers.

From a testing perspective, Dr. Ngo Xuan Nam advised businesses to confirm the sample type, testing method, and limit of quantification with laboratories before submitting samples. Testing scopes may vary across paper, plastic, and coated materials. For example, when assessing a grease-resistant paper bag, a business needs to check whether the laboratory's testing scope covers the specific type of paper and coating being used. The resulting test reports should then be retained together with information on the material code and specifications of the tested sample.

MSc. Nguyen Quoc Dung, Head of the Chemical Engineering Department at Eurofins Vietnam, analyzed the PPWR requirements across different stages, from design and material selection to reuse, labeling, and traceability. At the design stage, colors, labels, adhesives, printing inks, and coatings can all affect material identification, sorting, and the quality of materials recovered through recycling. For a plastic bottle, for instance, businesses need to consider the bottle body, cap, and ease of label removal. For flexible packaging films, the assessment must account for both the individual film layers and the materials used to bond them together.

Based on these requirements, the Viet Nam SPS Office recommends that businesses develop a packaging inventory for each export product code, documenting its structure, number of layers, material types, and intended use. This inventory serves as the basis for collecting suppliers' declarations of compliance, identifying the necessary tests, and reviewing label information. Whenever a supplier changes the film, printing ink, adhesive, or coating, the updated information must be communicated to the food producer so that the documentation for the relevant product code can be reassessed.

The division of responsibilities with import partners also needs to be clearly established. Depending on the parties' roles under applicable regulations and the requirements of the destination market, businesses should determine which entity is responsible for preparing and retaining documentation, which party bears testing costs, and which party fulfills extended producer responsibility (EPR) obligations. The Viet Nam SPS Office's presentation cited registration through Germany's LUCID system as an example of why businesses must identify their obligations in each country where packaging is placed on the market.

Designing for recyclability while preserving food protection

According to Bui Quang Thinh, Chairman of the Science, Technology and Sustainable Packaging Committee of the Vietnam Packaging Association (VINPAS), packaging design must start with the characteristics of the food product and its intended conditions of use. For dry goods, businesses need to determine their sensitivity to oxygen and moisture, as well as the expected shelf life. Frozen food packaging must maintain its strength at low temperatures, resist punctures, and provide adequate sealing. For food sterilized in its packaging, both the materials and seals must withstand the product's heat-processing conditions.

In the cashew packaging example, VINPAS proposed exploring a transition from a laminated PET, aluminum, and PE structure to a predominantly PE structure incorporating a specialized barrier layer. The approach aims to improve compatibility with PE recycling streams while maintaining the packaging's protective performance. To assess its suitability, businesses need to measure oxygen and moisture barrier properties, test seal integrity, conduct trials on packaging machinery, and monitor cashew quality throughout the storage period. Performance tests on the finished packaging provide the basis for deciding whether the proposed structure should be adopted for production.

For flexible packaging, structures made primarily from PE or PP can reduce the use of combinations of different plastics that are difficult to process together. However, their suitability depends on stiffness, heat resistance, sealing performance, and machine operating speed. VINPAS also emphasized the need to assess the entire packaging structure, including films, barrier layers, printing inks, and laminating adhesives. A change to the barrier layer may require adjustments to film thickness or sealing conditions to maintain finished-product quality.

VINPAS introduced technical guidelines such as CEFLEX and RecyClass as references for businesses designing packaging and assessing its recyclability. CEFLEX can help guide the selection of flexible packaging structures from the design stage, while RecyClass provides assessment methodologies for individual material streams. Results from these tools can serve as additional technical evidence in businesses' compliance documentation. However, the determination of legal obligations and recyclability grades under the PPWR must follow the applicable E.U. criteria.

Another approach is to reduce packaging materials and empty space. Businesses can consider reducing film thickness, adjusting bag and box dimensions, or optimizing the way products are arranged on pallets. According to VINPAS, assessments should track both the amount of packaging used per kilogram of food and the product damage rate. If packaging dimensions or thickness are changed, businesses need to retest impact resistance, seal integrity, and product quality after storage and transportation.

VINPAS proposed a 90-day roadmap to help businesses get started with specific product codes. During the first 30 days, businesses should compile an inventory of export products, collect relevant documentation, and update their understanding of customer requirements. From day 31 to day 60, they should classify risks and select two to three priority product codes. The final stage should focus on conducting packaging trials, carrying out tests, assessing recyclability, and comparing the results against projected costs. For businesses considering packaging changes, the results for each product code will provide a basis for deciding whether to retain the existing structure, improve the materials, or invest in new equipment.

PPWR stands for Packaging and Packaging Waste Regulation, the European Union's regulation on packaging and packaging waste, established under Regulation (EU) 2025/40. It provides a new legal framework governing all types of packaging and packaging waste, regardless of whether the packaging is used in or originates from industry, other manufacturing sectors, retail or distribution, offices, services, or households. The regulation officially entered into force on February 11, 2025, and has applied broadly since August 12, 2026.