Are Your Paper Bags Ready for California Prop 65, REACH SVHC, and FDA 21 CFR?

Exporting packaging sounds easy — until you hit the wall of compliance. Suddenly, your eco-friendly paper bag is under scrutiny. Labels, materials, inks — everything needs to meet standards across multiple regions. And trust me, a single missed test could get your shipment rejected, or worse, trigger a recall.

Yes — if you’re selling paper bags into the US or EU, you absolutely must comply with California Prop 65, REACH SVHC, and FDA 21 CFR. And yes — we at GreenWing handle it all, so you don’t have to sweat the paperwork.

Let’s break it all down and build your no-nonsense compliance checklist. (Your logistics team will thank you.)

Why Compliance Isn’t Optional in Packaging Anymore?

The days of “ship now, test later” are long gone.

Modern importers — especially in food, beverage, and e-commerce — are under pressure to prove their packaging is safe, sustainable, and compliant. That means your paper bags need to tick every box, even before they leave China.

If your bags touch food, are printed with ink, or could expose consumers to chemicals — regulations apply. And they’re getting stricter.

Non-compliance can result in:

• Product recalls
• Border rejections
• Fines or bans
• Ruined brand reputation

So, the smart move? Get it right before you ship.

What is California Proposition 65 — And Why Should You Care?

Let’s start with the drama queen of packaging regulations: California Prop 65.

Prop 65 (officially the Safe Drinking Water and Toxic Enforcement Act of 1986) requires businesses to warn Californians about exposure to certain chemicals that may cause cancer, birth defects, or reproductive harm.

Over 900 chemicals are on the list — and it’s growing. Even printing inks, adhesives, and coatings on paper bags can trigger this if they contain:

• Phthalates
• Lead
• Formaldehyde
• BPA

So if your bag is sold anywhere in California — directly or via online sales — you must test it and either:

1. Provide a clear warning label, or
2. Prove it doesn’t require one.

We at GreenWing can provide Prop 65 testing reports and certify compliant bags for our U.S. clients.

What is REACH SVHC — And How Does It Affect Export to Europe?

Next up: the REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals). It’s the EU’s heavyweight regulation for chemical safety.

Within REACH is a “naughty list” of Substances of Very High Concern (SVHC) — over 240 chemicals that are:

• Toxic
• Persistent in the environment
• Harmful to human health

Your paper bag’s inks, glue, coatings, and even handles may contain trace SVHCs. If they do, you’re legally required to:

• Notify customers
• Register with ECHA
• Possibly find safer alternatives

Most importantly, you must prove your products are below the SVHC thresholds (typically <0.1% weight by article). We help clients by offering REACH SVHC screening reports — and choosing pre-approved, safe materials.

What is FDA 21 CFR — And Why It Matters for Food Packaging?

If your paper bag touches food — think sandwich bags, bakery bags, or takeaway pouches — then you need to follow FDA 21 CFR.

This is a massive regulation that governs indirect food contact materials. Your paper, glue, and ink must be:

• Food-grade
• Non-leaching
• Safe at intended use temperatures

The FDA rules vary depending on:

• Wet vs dry food
• Greasy vs non-greasy contents
• Direct vs indirect contact

We work with certified suppliers and labs to ensure our paper bags meet FDA 21 CFR 176 and 178 — including sections related to adhesives and coatings.

And yes, we provide food contact declarations of compliance for import customs and brand audits.

Your 6-Point Export Compliance Checklist (Save This)

Here’s the checklist I personally send to importers like Mike (our favorite food brand buyer in the U.S.):

✅ 1. Material Safety Reports (paper, glue, ink, lamination)

✅ 2. California Prop 65 compliance certificate or warning label as required

✅ 3. REACH SVHC test report, especially for EU-bound goods

✅ 4. FDA 21 CFR food-contact compliance, if bag touches food

✅ 5. Labeling requirements followed (warning labels, material declarations)

✅ 6. Batch traceability with production records and test dates

We handle all six for our clients — no extra headache, no language barriers. Just one invoice, one shipment, full peace of mind.

What Happens If You Skip Compliance? (Real Talk)

Look, I’ve seen horror stories.

A client once bought bargain paper bags off Alibaba — no testing, no certifications. They sold in California, got flagged for lead in ink, and ended up paying $70,000 in Prop 65 fines.

Another had their REACH-noncompliant packaging blocked at a German port — losing a full peak-season shipment.

Not worth it.

Spending $100–300 on pre-shipment compliance is far cheaper than dealing with lawsuits, returns, or ruined credibility.

How GreenWing Makes Export Compliance Easy

Let me brag for a second — we’ve been doing this since 2008.

We don’t just make bags. We engineer them for export.

Our facility has:

• Over 60 industry qualifications
• On-site testing and QA lab
• Pre-approved material supply chains
• Full traceability system from raw paper to final print
• Dedicated compliance officers who speak your language (literally and legally)

Plus, we work with SGS, TUV, and Intertek for third-party lab reports. You get test data, compliance declarations, and printable labels — all ready for customs or retail inspection.

Need a custom compliance pack for Amazon, Costco, or Walmart? We’ve done that. And we’ll do it for you.

Conclusion

If your paper bags cross borders, so should your compliance standards.

Whether it’s California Prop 65, REACH SVHC, or FDA 21 CFR, the best packaging isn’t just strong and pretty — it’s legally bulletproof.

Let’s make your next shipment not just compliant, but confidently compliant.