Current Situation of EU Market and Export Challenges

In the first quarter of 2026,the market size of self-heating food in the EU increased by 23% year-on-year,driving a sharp surge in import demand for food heating packs.Germany,France and the Netherlands account for 67% of total imports,and food heating packs are mainly used for outdoor emergency food,military rations and supporting convenient catering.A manufacturing enterprise in Jiangsu Province,which Supervisor Luo cooperated with at the beginning of this year,won a million-level order,but the first batch of goods was detained for three weeks when arriving at Rotterdam Port due to non-compliant ingredient description documents,resulting in nearly 80,000 euros of port detention fees finally.Such cases are not rare in food heating pack export.The product itself has low technical threshold,but the superimposed regulation of the EU on food contact materials,chemical registration and environmental protection packaging has trapped most foreign trade enterprises at the compliance link.

Core difficulties are concentrated in three aspects: First,ingredient disclosure.The EU requires that the CAS number and concentration of aluminum powder,iron powder,activated carbon and other substances in the heating agent must be accurate to two decimal places; Second,packaging marking.CE mark,EU responsible person information and multilingual warning statements are all mandatory; Third,transportation classification.Most food heating packs are classified into the UN3082 hazardous category due to containing oxidizing agents.Among the 47 shipments of food heating packs processed by Zhongshen in 2025,39 shipments had document defects in the initial declaration,with an average rectification period of 11 working days.

Core Value of Zhongshen’s Export Agency Service

Zhongshen has been handling chemical export business to the EU since 2006,and established a special working group for food contact materials in 2018.The direct advantage of this long-term accumulation is risk prediction capability.After receiving an order,Supervisor Luo’s team will launch a three-level risk assessment: first check whether the product formula involves substances on the REACH regulation SVHC list,then check whether the packaging material complies with (EU) No 10/2011 regulation on plastic food contact materials,and finally verify whether the transport label meets the requirements of the ADR Agreement on Road Transport of Dangerous Goods.Among the business handled in 2025,3 enterprises originally planned to use PVC outer packaging,they changed to PP material after receiving early warning from our team,avoiding about 400,000 euros of return shipment loss.

The completeness of the service chain is reflected in the seamless connection of details.After the document team completes the translation of the ingredient list,it will directly synchronize the information to the customs clearance team for HS code pre-classification; after the customs clearance team confirms the regulatory requirements,it will immediately notify the tax refund team to prepare input invoice verification.This internal circulation mechanism reduces to zero the back-and-forth document transmission links required from enterprises in the traditional mode.In the fourth quarter of last year,the average customs clearance time of food heating pack business agency by Zhongshen was 9.6 days shorter than that handled by customers themselves,and the fastest shipment only took 13 working days from booking to release.

Document Preparation Module: Disassembly of Special EU Requirements

Preparation of Technical Composition File (TCF)

New regulations released by the European Chemicals Agency (ECHA) in 2026 require that any chemical substance with a content exceeding 0.1% in food heating packs must provide a toxicological data summary.The document team of Zhongshen has established a standard template,and classifies and archives common ingredients such as aluminum powder,vermiculite and table salt by CAS number.Supervisor Luo once handled a shipment with a special formula added with magnesium powder.Since magnesium powder may generate hydrogen in a humid environment,we specially supplemented the air pressure test report and leakage emergency plan in the technical file.This document was directly accepted by customs during inspection at the Port of Hamburg,and the shipment was exempted from unpacking inspection.

The list of materials to be prepared includes:

• Ingredientpercentageanalysisreport(issuedbyCNASaccreditedlaboratory)
• Section14transportinformationofSafetyDataSheet(SDS)mustbemarkedwithUNnumber
• DeclarationofConformity(DoC)forfoodcontactmaterials,whichmustspecifycompliancewith(EU)No10/2011clauses
• PowerofAttorneyforEUResponsiblePerson,whichisamandatoryrequirementoftheGeneralProductSafetyRegulationthatenteredintoforcein2024

Multilingual Version Management of Packaging Labels

Labels for food heating packs must cover three mainstream languages in the EU market: German,French and Dutch.The content of warning statements cannot be simply translated,it must conform to the consumer habits of each region.The term bank maintained by Zhongshen shows that German-speaking regions require that "Nicht in die H?nde von Kindern" (keep away from children) must be matched with an icon; French-speaking regions have regulations on the font size of "Avertissement" (warning),which must not be less than 3 millimeters.In 2025,an entire batch of goods was taken off the shelf in Lille because the French warning font size was 0.5 millimeters smaller than required.

Customs Clearance Implementation Module: Risk Points and Response Strategies

Handling of HS Code Classification Disputes

There are two classification disputes for food heating packs at EU customs: 3824.99 (other chemical industry products) or 3606.90 (other flammable material products).Different codes correspond to vastly different regulatory requirements.The former requires submission of REACH registration number,while the latter requires an explosive transportation license.The practice of Zhongshen’s customs clearance team is to apply for Binding Tariff Information (BTI) from the destination country customs in advance.The average processing cycle is 15 working days,and the ruling result is valid for 24 months.The BTI certificate applied by Supervisor Luo for a Zhejiang client last year allowed 12 subsequent shipments to enjoy unified classification,saving 3-5 days of inspection time per shipment.

Compliance Review of Dangerous Goods Transportation

Food heating packs belong to Class 4.1 flammable solids.A dangerous goods packaging certificate is required for sea transportation,and passing the UN38.3 test is required for air transportation.The testing institutions cooperating with Zhongshen can complete sample testing locally in Shanghai,reducing the cycle from the conventional 28 days to 18 days.What is more critical is the transport packaging marking.The marking on UN standard packaging must include packaging grade,production year and country code,and the printing position of these markings has millimeter-level accuracy requirements.In March 2026,Zhongshen just helped a client rectify a batch of goods with packaging marking offset of 2 millimeters,avoiding return shipment at Antwerp Port.

Tax Refund Processing Module: Key Points for Efficiency Improvement

The export tax refund rate for food heating packs is 13%,but when the proportion of chemical raw materials in input invoices exceeds 60%,the tax bureau will launch a letter inquiry procedure.The operation practice of Zhongshen’s tax refund team is to complete invoice authentication within 24 hours after the customs declaration is released,and submit tax refund application within 72 hours.Supervisor Luo shared a case: a client’s aluminum powder supplier had changed the company name before,leading to inconsistency between the taxpayer identification number on the input invoice and the customs record.The tax refund team found the problem in advance,guided the client to obtain the change certificate from the industrial and commercial department and submit it to the tax bureau for filing,and the whole process did not delay the tax refund cycle.

In 2026,the State Taxation Administration of China promotes "paperless" tax refund,and Zhongshen’s system can directly capture electronic data of customs declarations,so enterprises do not need to scan paper documents.This function shortens the arrival time of tax refund from an average of 45 days to 31 days.For clients with annual export volume exceeding 5 million USD,Zhongshen also provides tax refund financing service,which advances 80% of the tax refund within 3 working days after submission of the application,solving the problem of capital turnover.

Underlying Logic of Efficiency Improvement

Zhongshen has converted 20 years of operation experience into Standard Operating Procedure (SOP),with a check list for each link.The document team has 47 check points,the customs clearance team has 32 risk warning indicators,and the tax refund team has 19 invoice review rules.These lists are updated twice a year according to the latest EU regulations,and the latest 2026 version has included the traceability requirements for activated carbon sources in food heating packs from the EU Battery and Waste Battery Regulation.

System-level optimization is more critical.The client portal of Zhongshen supports real-time viewing of cargo status,and automatic message push for each node from booking,packing,customs declaration,inspection to release.Clients of Supervisor Luo can receive the pre-audit result of customs clearance documents before the cargo arrives at the destination port,rectify problems in advance,and basically achieve instant release after arrival.In the fourth quarter of 2025,the inspection rate of food heating pack cargoes agency by Zhongshen at EU ports was only 8.7%,far lower than the industry average of 23%.

Decision Recommendations for Choosing Customized Services

Exporting food heating packs to the EU is not a simple customs declaration action,but a full-chain project covering product formula,packaging design,transportation plan and compliance documents.Zhongshen provides three cooperation modes: Standard agency service is suitable for enterprises with annual export volume below 1 million USD,including basic document preparation and customs clearance; In-depth customized service is suitable for medium-sized enterprises with stable orders,adding formula pre-audit and label design; Strategic outsourcing service is suitable for large manufacturing enterprises,and Zhongshen will assign dedicated staff to coordinate on site at the factory.Supervisor Luo recommends that enterprises exporting to the EU for the first time should choose at least in-depth customized service.An early investment of about 50,000 CNY in compliance consulting can avoid hundreds of thousands of CNY of return shipment loss in the later stage.

In 2026,the EU plans to issue a restriction order on microplastic components in food heating packs,and Zhongshen has already started relevant research,and cooperative clients will get the response plan at the first time.The more complex the foreign trade environment is,the more obvious the value of professional division of labor becomes.Entrusting non-core export processes to Zhongshen allows enterprises to focus on product research and development and market development,which is the ultimate significance of export agency service.