Packaging Test Reports: 3 Real Categories — When QS / CoA / Third-Party Testing Is Used by Print Suppliers and Where Clients Get Tripped Up

In November last year, the boss of a mooncake gift box factory in Wuxi slapped a report stamped "Jiangsu XX Testing Technology Co., Ltd." on the desk and asked me: "Mr. Zhang, our client says the reports we used before were fake and wants us to reissue a QS report, or they'll stop placing orders next year. Can you stamp this directly?"

I looked at the report header — it was last year's food contact material commissioned test report issued to our company, complete with the CMA seal, CMA number, test officer signature, and test date. But what the client called a "QS report" referred to the periodic supervisory inspection report paired with the factory's production license (SC certificate), organized by the local market regulation bureau, requiring a type inspection every year before license renewal. These two reports are not the same thing at all.

This is not an isolated case. Today in Wuxi, among printers doing food packaging, two out of three have had clients tell them "the report is wrong" — always because the difference was never clarified. Let me untangle this here — which report seals a printer can stamp, which report a client actually needs for compliance, and why this information gap is the most overlooked issue in packaging certification.

Category 1: QS (SC) Supervisory Inspection Report — Where Printers Most Often Trip Up

QS stands for Food Production License, renamed SC in 2015, though clients still习惯叫 QS. This report is not stamped by the printer, nor can the client apply for it on their own. It is the type inspection report organized by the local market regulation bureau when the food packaging client applies for their own production license.

Some clients ask the printer to "show your QS report" — this is the wrong question. As the packaging manufacturer, the printer only holds a "food packaging material production license," which is a separate license from the client's "food" production license. The printer holds its own "industrial product production license" (subdivided into food-use plastic packaging, paper packaging, glass packaging, etc.), and the samples tested under the printer's license are packaging bags, boxes, and plastic containers produced by the printer itself, not the client's food products.

Where do printer owners most often fall into trouble? Three common mistakes:

• Mistake 1: The client asks the printer for a "QS report," the printer shows the client its own SC report, and the client rejects it — because the report lists the printer's product model, not the client's product specifications.
• Mistake 2: The client asks the printer to issue an SC report on their behalf, the printer doesn't realize it has no authority to do so, naively collects testing fees, and ends up being sued by the client for fraud.
• Mistake 3: The client is new to food packaging, has not yet obtained an SC certificate but still demands delivery from the printer — the printer ships without verifying the client's qualification, and when the client gets spot-checked by the market regulation bureau, the printer is held jointly liable.

What should a printer do here? Check the client's SC certificate, verify that the "food category" on the SC certificate matches the packaging category the printer is producing (pastries, mooncakes, chocolate, candy, meat products, pickled vegetables, etc.), and confirm the SC validity period. If the client's certificate is expired or nonexistent, the printer should reject the order outright — this is not timidity; under the 2023 joint accountability mechanism from the State Administration for Market Regulation, the printer as upstream supplier must also sign a "supply voucher" into the system, and if something goes wrong, both client and printer are penalized together.

Category 2: CoA Report (Batch Product Quality Certificate) — Printer Can Stamp, but With Boundaries

CoA stands for Certificate of Analysis, essentially a "this batch meets factory release standards" certificate attached to each outgoing batch. In food packaging, a typical CoA covers 5 basic categories:

• Appearance and dimensions (L × W × H in mm, basis weight in g)
• Material (white cardboard / grey board / corrugated grade)
• Print color difference (ΔE ≤ 3.0 or brand-defined custom value)
• Physical performance (compression / burst / puncture / edge crush strength)
• Hygiene indicators (microbial / evaporation residue / heavy metal migration)

This report can be stamped with the printer's own QC seal. Should the printer stamp it? It depends on two conditions:

1. The printer's QC department has the capability to perform these tests — for example, appearance, dimensions, basis weight, and print color difference can be handled by most printers; but physical performance (compression / burst) requires standard laboratory equipment (electronic universal testing machine), and hygiene indicators require microbial incubators and related chemical analysis capabilities that most small to mid-sized printers cannot offer.
2. The test data on the CoA is truthful and credible — a common pitfall for printers is "the engineer eyeballs that the color looks about right and writes OK on the report." When the client later submits the CoA to a national spot check and the data doesn't match, the printer is blacklisted.

So the reliable path is: for tests the printer can perform, stamp with its own seal; for tests the printer cannot perform, send to a third-party CMA laboratory. Who pays depends on two scenarios — if the client does not specify the supplier, the printer adds a 5-15% testing handling fee to the quote; if the client designates a third party, the client pays directly and the printer charges a sample coordination fee of 200-500 RMB per batch.

Here is a real case for comparison. In October 2025, a Suzhou client making flexible packaging for pickled vegetables sent me a CoA stamped with the printer's QC seal, in which the compression data was the printer engineer's two-character note: "Qualified." I helped the client arrange a recheck with a CMA lab and found the burst strength was 18% below standard — the printer engineer had written "Qualified" by gut feel. The client's loss was about 72,000 RMB in return-and-rework costs for 20,000 pieces of product, and the printer ultimately compensated only 4,000 RMB, but the client moved all orders away from the second year onward.

Category 3: Third-Party Commissioned Test Report — Printer Assists with Sample Submission but Does Not Stamp

A third-party commissioned test report is a compliance test performed at a CMA / CNAS accredited laboratory, either designated by the client or recommended by the printer. Among the three report categories, this one carries the highest legal effect, and is also the one the printer should never stamp with its own seal.

What the printer needs to do is:

1. Submit samples but never unilaterally appoint a laboratory — for food contact materials, samples must go to a CMA laboratory for GB 4806 series testing; for cosmetics packaging, a CMA laboratory for GB/T 29604 series testing; for medical device primary packaging, a CMA laboratory for GB/T 19633 / ISO 11607 series testing. The standard laboratories for these test items have nationally limited qualifications, and reports from any randomly chosen "testing company" will not be accepted by regulators when the client submits them.
2. Sample preparation must be compliant — for packaging material submission, the products sent to the lab must be mass-production samples (not proofing samples), must use the same batch of raw materials as the mass-production run, and 5× redundant samples must be prepared for retesting if needed.
3. The original report belongs to the client — the third-party report is headed with the product made by the printer, but its legal effect belongs to the commissioning party (client). The report is stamped with the CMA seal, CNAS seal, and test officer signature seal, and the printer's seal must never appear. The printer may keep a copy for quality records.

If a client is willing to pay for testing, that shows they care about quality — such clients should be valued by the printer. But the printer should also clarify upfront: testing cycles usually run 7-15 working days, and special items such as overall migration and plasticizer screening require 20-30 working days. This means the client must allow at least 1 month from order placement to receiving the report. The printer should write the testing cycle into the contract terms to prevent the client from pressuring the printer's delivery schedule out of impatience.

How Should a Printer Tell Which Report the Client Actually Needs?

When a client comes to a printer asking for a "test report," the first thing the printer should do is not flip through report templates but ask the client three questions:

1. What specific category of food (or cosmetics / medical device) do you produce? — this determines whether SC filing, cosmetics filing, or medical device filing applies;
2. Who do you need this report for? — end-retail listing, market regulation spot check, customs export, brand-side compliance audit, each purpose corresponds to a different report type and test items;
3. Show me your SC certificate / cosmetics production license / medical device production license number — if you have no license, no order.

If it's for end-retail listing (supermarket, convenience store, e-commerce), a printer-stamped CoA plus a third-party CMA GB 4806 report is sufficient; if it's for the client's own SC annual review, the printer issues no report at all and the client must handle it themselves; if it's for an export client, it depends on the destination country's standard (FDA / EU 1935 / KFDA / JP Food Sanitation Act, etc.), the printer handles sample submission and data support, the compliance chain is in the client's hands, and the printer cannot call the shots.

If a printer owner has no clue about this section, orders will inevitably be lost or clients will give them a hard time. I recommend every printer make a "Test Report Category Mapping Chart" and post it in the sales office or include it as part of the client-facing SOP — it takes 3 minutes to make a client understand which report to ask whom for. This is nothing to be ashamed of; it is actually a sign of the printer's professionalism.

Real Pricing Numbers for These 3 Report Categories

For printer owners, here is a real pricing range to keep in mind when quoting:

• In-house printer CoA: 200-600 RMB per batch (covering labor + basic testing consumables), depending on the number of test items and how often the printer runs the test;
• Third-party CMA / CNAS testing: 800-2500 RMB per item (e.g., GB 4806.7 evaporation residue, one item around 1500 RMB), or 4000-12000 RMB for a full set (full food contact material suite);
• Type inspection report (supervisory inspection category): handled by the client, no charge from the printer — the printer should not even tell the client how much this costs;
• Sample coordination service fee: 200-500 RMB per batch charged by the printer (covering sample preparation + data coordination + report delivery) — this is reasonable service income for the printer, not "extra charges."

If a client proactively offers "we'll cover the testing fees," this should be included in the formal quote rather than made as a verbal promise, to avoid later disputes. If the client says "we'll provide our own test reports going forward, so deduct testing fees from your quote" — the printer can do this, but the contract terms must clearly state: client-provided test reports must list the specific product model received by the printer, must be issued by a CMA / CNAS laboratory, and must include all compliance items the printer may need; otherwise the client-provided reports are deemed insufficient and the printer bears no responsibility for compliance risks arising therefrom.

Further Reading

• Food Packaging's 6 Mandatory Label Categories: Ingredient List / Allergen / Shelf Life / Nutrition Facts / Net Weight / Origin — 3 Pitfalls Printers Most Often Hit
• Food Contact Packaging GB 4806 Test Items in Practice: 5 Commonly Failed Items + 3 Remediation Approaches
• 3 Real Cost-Sharing Rules for Gift Box Proofing Fees
• 6 Real Action Steps in Packaging Supplier Audits

Frequently Asked Questions (FAQ)