Food-Grade Gift Box Factory: 3 Types of Third-Party Test Reports Clients Ask For — QS / CoA / Commissioned Testing

Why This Article

In November 2025, a food gift box factory owner came to me holding screenshots from a client's WeChat conversation. The client asked "Do you have third-party test reports?" The owner replied "Yes, our paper supplier has reports." The client immediately followed up "Is it a QS report or a CoA report? Which lab issued it?" The owner admitted on the phone "I can't really tell them apart" — the client hung up immediately and cancelled the order.

In practice, food packaging factory owners and salespeople frequently confuse these three terms: QS report, CoA report, and commissioned testing report. When clients ask, if the factory answers any one of them wrong, the client will immediately question the factory's professionalism.

But these three terms actually refer to three different materials needed at three different stages of the food packaging chain. This article breaks down the three reports clearly. After reading, the next time a client asks, the factory can respond by differentiating among the three report types.

The Essential Differences Among the 3 Reports — Who Issues Each QS/CoA

Break down the legal entity and testing target of the three reports:

• QS Report: Full name "Food Production License". The legal entity is the printer or raw material factory. The testing target is the enterprise's production capability (plant/equipment/personnel/systems). Issued by the Market Supervision Administration. Valid for 5 years.
• CoA Report: Full name "Certificate of Analysis". The legal entity is the printer. The testing target is the measured data of that specific production batch (chemical migration/physical strength). Issued by the printer's QC department or a contract lab. Issued per order batch.
• Commissioned Testing Report: The legal entity is a third-party lab (with CMA/CNAS qualification). The testing target is the specific items the client cares about (e.g., migration, microorganisms, heavy metals). Commissioned and paid for by the client.

Clients care about these three reports from different angles:

1) Whether the factory has "qualifications in place": they look at QS. This is the client's compliance judgment.

2) Whether this shipment is "qualified for that batch": they look at CoA. This is the client's acceptance judgment for the goods.

3) Whether they need "data on a specific metric": they look at commissioned testing. This is for client product market filing or client factory audit purposes.

When a client asks "do you have third-party test reports?", if the client is concerned about QS vs. CoA vs. commissioned testing, the factory should first ask back "Which type of report do you need?" rather than answering vaguely "Yes". This is a core skill for the factory's sales staff.

Type 1: QS Report — Factory Qualification Entry Pass, Often Asked But Optional for the Factory

The QS report is essentially "the license allowing the factory to produce food-contact materials". To obtain QS, the factory needs 3 conditions:

• An independent production workshop (separated from other material production to avoid cross-contamination)
• Food-grade raw material sourcing channels (raw material suppliers with QS qualification or food-grade compliance certificates)
• The factory's own lab or a contract lab (capable of testing migration/microorganisms and basic items)

The application cycle is 3-6 months, with costs of 20,000-50,000 RMB (excluding plant renovation). Without QS, the factory will be screened out of bidding for food liner (direct food contact) orders.

How does the factory determine whether the client needs to see QS?

• Client says "I need food liners/food packaging": the factory needs QS; if not, inform the client that the order cannot be accepted
• Client says "I make liquor/tea/candy outer gift boxes, the liner doesn't need to be made by you": the factory doesn't need QS, but needs CoA and food-grade test reports for the base paper
• Client says "I do exports, FDA food contact regulations apply": the factory needs FDA certification rather than QS, but QS serves as indirect proof

Real Case: A mooncake gift box factory in Suzhou landed a major client in 2024, who required QS for the liner paper. But this factory only had qualifications for outer gift boxes and couldn't handle liners. The client asked "Can you apply for QS?" The factory replied "Can't get it done within 3 months." The client left — a single 2 million RMB mooncake gift box order. The factory later chose to "only do outer gift boxes, outsource liners to factories that have QS", which looking back also proved to be a viable path.

Factory decision: the core of whether to obtain QS lies in "the share of food liner business in total revenue". If all clients say "I'll handle the liner, you just do the outer layer", the factory doesn't need to spend 50,000 RMB on QS; if the factory wants to handle liner orders from major clients, QS is almost mandatory.

Type 2: CoA Report — Mandatory for the Factory, Most Frequently Required by Clients

The CoA report is "proof that this batch of products is qualified". It must be issued for every batch and attached when the client receives the goods. This is the highest-frequency report the factory issues on a daily basis.

Standard format of a CoA report (7 mandatory items):

• 1) Product name (corresponding to client order)
• 2) Batch number (corresponding to production batch)
• 3) Test items (corresponding to items agreed in client contract)
• 4) Test standards (corresponding to national/EU/FDA standards)
• 5) Test results (measured data, must not be falsified)
• 6) Test date (within 14 days of batch production date)
• 7) Tester signature + factory seal

Where do the test data on the CoA come from? 3 ways:

• Method 1: Factory self-testing. The factory has its own lab (autoclave/gas chromatograph), capable of testing basic items (moisture/pH/appearance). This approach has low cost, but data credibility is limited and insufficient when client requirements are high.
• Method 2: Factory sends to contract lab. The factory sends samples to third-party labs (e.g., SGS/Intertek/CTI), which perform the testing with high data credibility. Cost is 500-1500 RMB per item, 3-5 working days.
• Method 3: Raw material supplier provides. The factory's paper/ink supplier has already issued a CoA when the raw material leaves the factory. The factory can include it after its own CoA as upstream supporting evidence. Lowest cost, but the latest batch must be used; old batches are not acceptable.

The factory's standard practice is a combination of all three — self-testing + contract lab + raw material CoA. Most items are self-tested; key items (migration/microorganisms) are sent to contract labs; the raw material CoA is attached when the client accepts the goods as a complete evidence chain.

Key traps of CoA reports:

1) Falsified data: The factory finds a tested item non-compliant, but the client urgently needs the batch, so the factory fills in "qualified" on the CoA. This is a serious violation. Once discovered, the client can claim compensation.

2) Batch mismatch: Client order batch A001, but the CoA shows A002, discovered by the client. This signals chaotic batch management at the factory, and the client will question the entire production process.

3) Incomplete test items: The client contract specifies 5 test items, but the CoA only lists 3, with the other 2 not tested. The client will request supplementary testing, delaying delivery.

Real scenario: A factory in Shenzhen was claimed 500,000 RMB by a food brand in October 2024 because the CoA showed "formaldehyde migration" as "not detected", but a Market Supervision Administration spot check measured "0.8mg/L", exceeding the GB 4806.7 limit of 0.5mg/L. The client immediately initiated a recall, with the factory bearing the recall costs. This is a real case. The factory must treat test data as a hard metric, not a soft one.

Type 3: Commissioned Testing Report — Client-Initiated, Factory Only Needs to Cooperate with Sample Submission

A commissioned testing report is a report actively commissioned by the client from a third-party lab. The factory only needs to cooperate with sample submission; the cost is generally borne by the client.

Key differences between commissioned testing and CoA:

• CoA is self-certified by the factory (with a conflict of interest); commissioned testing is third-party certified (no conflict of interest)
• CoA is used for daily shipment; commissioned testing is used for critical occasions (government spot checks/client factory audits/new product filing)
• CoA cost is absorbed internally by the factory; commissioned testing cost is borne by the client

When cooperating with clients, the factory often encounters these 3 commissioned testing scenarios:

• Scenario 1: Client factory audit: The client sends personnel or commissions SGS to sample at the factory and take samples back to the lab for testing. The factory needs to cooperate by providing samples + batch information + on-site sampling.
• Scenario 2: New product filing: The client's new product must be filed with the Market Supervision Administration and requires a "third-party test report" attached. The client commissions a lab for testing; the factory ships samples + product specifications.
• Scenario 3: Government spot check: The Market Supervision Administration commissions a lab to sample at the factory. The factory only needs to cooperate with sampling; refusal is not allowed.

Key points for the factory cooperating with commissioned testing: give whatever the client or lab asks for. Don't pick samples, don't reveal the client's sampling numbers in advance, and don't delay sampling because "this batch has a lot of product". All of these are compliance requirements. Refusal by the factory will be labeled as "non-cooperation with sampling" and added to the abnormal list.

A common mistake made by factories is "use the best samples when the client comes for sampling". This approach seems fine in the short term, but once discovered or subjected to repeated testing, the client will suspect consistency issues between actual factory products. The correct approach is "random sampling, whatever is pulled from the production line is sent", which reflects the true quality level.

How to Calculate "Testing Fees" on the Factory's Quote Sheet

When quoting externally, how should these 3 reports be written? Usually the quote sheet has a line item "testing fees". Break this line down:

• CoA issuance fee: 500-1500 RMB per batch, covering factory self-testing cost + report processing
• Third-party testing fee: 500-3000 RMB per item, calculated based on the number of items required by the client
• QS maintenance fee: 50,000-100,000 RMB per year, absorbed internally by the factory; not charged separately to the client

The factory can quote a combined "testing fee 1500 RMB per batch" so the client doesn't need to break down details. Or it can be broken down so the client knows where every penny goes. Both methods work. The key is that the contract must clearly state "what items the testing fee covers, and how overages are charged".

"Golden Script" Template for Factory to Reply to Clients

When factory salespeople are asked "Do you have third-party test reports?", they can respond as follows:

"Mr. Li, our factory's reporting system is divided into 3 categories: 1) QS production license we have [yes/no], valid until [date]; 2) CoA reports are issued per order batch and shipped with the goods; 3) Third-party commissioned testing, if required in the contract, we cooperate with sample submission with costs borne by the client. Which type are you asking about? For [specific type], I can provide you with detailed materials."

The core of this script is "differentiate the 3 types + proactively ask back", which makes the client feel the factory is professional. At the same time, it avoids vague answers that lead to client doubts.

Further Reading

• Printing Factory's 3 Quote Templates for Brand-Owner Packaging — When Clients Only Ask About Unit Price, How the Factories Make Clients Look at 3 Hidden Fields
• Food Packaging GB 4806.10 Coatings: 3 Real Compliance Categories — Printers Taking "Coated Paper Box" Orders Most Likely to Stumble on "Evaporation Residue" Item
• Printing Factory BRC Packaging Materials Certification: 3 Real Audit Blind Spots — Auditors First Look at the Trash Can, Not Records, When Entering the Workshop
• Gift Box Client Acceptance "7-Day Re-inspection Period": 4 Real Traps — 3 Factory Cases Where Clients Deliberately Delayed 7 Days to Refuse Acceptance