First Step to Entering the European Market: Packaging, Labeling, and Air/Sea Freight Certification Requirements for EU Last-Mile Delivery
I. Preface: EU Last-Mile Compliance – The “First Key” to Unlocking the European Market
For enterprises planning to enter the European market, last-mile delivery compliance is crucial to determining the “success or failure of the first campaign”. As one of the most strictly regulated markets globally, the EU imposes three key thresholds for last-mile delivery: “environmentally friendly packaging”, “tax labeling”, and “safety certification”. According to 2024 data from EU Customs, over 40% of imported goods are detained due to last-mile non-compliance, with “substandard packaging materials”, “missing label information”, and “incomplete certification documents” accounting for more than 75% of cases. This directly causes enterprises to miss sales windows (such as the Christmas peak season), resulting in an average loss of over $20,000 per batch of goods.
This article focuses on the core markets of the 27 EU countries (Germany, France, Italy, Spain, etc.) and breaks down the first-step operations for entering the European market from three modules: “packaging compliance standards”, “labeling specification requirements”, and “air/sea freight certification key points”. It helps enterprises avoid compliance risks and quickly open up the EU last-mile delivery chain.
II. Packaging Compliance: EU “Eco + Safety” Dual Standards, 3 Types of Materials Must Be Avoided
The EU’s requirements for last-mile delivery packaging focus on “recyclability” and “goods protection”. The New EU Packaging Regulation that took effect in 2023 further raises environmental thresholds, while individual countries have clear safety standards for special goods such as fragile items and liquids. Enterprises must first master “material selection + operation specifications”.
(I) Eco-Friendly Materials: Failure to Meet “60% Recyclability Rate” Results in Direct Detention by German Customs
The EU Packaging Directive mandates a minimum 60% recyclability rate for packaging materials and prohibits the use of disposable non-degradable plastics. Countries have added differentiated requirements on this basis, and new entrants often face fines due to “wrong material selection”.
1. EU General Material Standards: 3 Types of Materials Are Preferred
- Cartons: Must comply with the “EN 13501-1 Fire Safety Standard” and “recyclable labeling requirements”. Priority should be given to 100% recycled paper materials (such as German TÜV-certified recycled cartons). Bursting strength is graded based on cargo weight: 3-ply corrugated cartons (bursting strength ≥ 180kPa) for goods ≤ 5kg, 5-ply corrugated cartons (bursting strength ≥ 300kPa) for goods 5-20kg, and 7-ply corrugated cartons (bursting strength ≥ 450kPa) for goods 20-30kg. This avoids transportation damage due to insufficient strength (EU logistics involves an average of 3 transshipments; a damage rate exceeding 5% will affect platform ratings).
- Cushioning Materials: Ordinary foam plastic is prohibited (fully banned in France and the Netherlands). Priority should be given to “paper cushioning parts” (such as corrugated paper partitions, honeycomb paper) or “compostable bioplastics” (complying with the EN 13432 standard, biodegradable within 180 days, e.g., Mater-Bi material from Novamont, Italy). For liquid goods, “double-sealed HDPE plastic bottles + leak-proof trays” must be used, with a single container capacity ≤ 1L. A “liquid leak-proof label” should be attached to prevent leakage from contaminating the entire box of goods (leaked goods are directly destroyed in the EU with no possibility of claims).
- Sealing Materials: Adhesive tape must be “recyclable paper tape” or “biodegradable plastic tape” with a width ≥ 50mm. PVC tape is prohibited (the EU RoHS Directive restricts the content of hazardous substances). Sealing must cover the carton seams to avoid opening during transportation (EU logistics sorting mostly uses robotic arms; an opening rate exceeding 3% will be classified as “non-conforming goods”).
2. Country-Specific Requirements: Germany Requires “Carbon Footprint Certification”, France Bans “Black Packaging”
- Germany: For goods with a value exceeding €22, a “carbon footprint certification report” (issued by third-party institutions such as TÜV and SGS) must be provided, and a “CO₂ emission label” (e.g., “CO₂ 2.5kg/piece”) must be attached to the outer packaging. Failure to provide certification will result in an environmental tax of €0.5 per piece, and the goods will be detained for 3-7 days (port detention fee of €100 per day).
- France: The use of black and dark gray packaging is prohibited (regarded as “non-eco-friendly colors”). Gift packaging must use light colors such as white and beige, with a “Cadeau (gift)” label attached. Price tags must not be placed inside (violating the French Consumer Rights Act), otherwise customers can refuse acceptance and claim compensation.
- Italy: Packaging for food products must use “food-contact-grade materials” (complying with the EU 10/2011 standard). For example, paper packaging must be marked with “food contact grade”, and plastic packaging must have the “LFGB certification label” to avoid fines (up to €5,000 per batch) due to material contamination of food.
(II) Packaging for Special Goods: “Suspension Packaging” for Fragile Items, “Explosion-Proof Isolation” for Batteries
The EU has strict safety standards for packaging fragile items, lithium batteries, and other special goods. Non-compliance will result in classification as “dangerous goods” and customs seizure.
1. Fragile Items (Ceramics, Glass, 3C Products)
- Adopt “double-layer cartons + suspension packaging”: The inner layer uses “airbag bags + EPE foam” to fix the goods (gap between goods and carton ≤ 1cm), and the outer layer uses 5-ply corrugated cartons. “Reinforced paper corner protectors” are attached to the carton corners, and a “red fragile item label” (font size ≥ 24pt, marked with the bilingual “Fragile – Manier avec précaution”) is affixed. Countries such as Germany and Austria also require marking the “maximum stacking height” (e.g., “Max Stack 3 Layers”) on the packaging to avoid crushing during storage.
- 3C products must additionally have an “anti-static label” attached and be wrapped in “anti-static bags” to prevent electrostatic damage to electronic components (the EU CE certification requires electronic goods to have anti-static protection; lack of protection will result in refusal of customs clearance).
2. Lithium Batteries (Mobile Phones, Laptop Accessories)
- Individual batteries must be sealed in “explosion-proof plastic bags”. For bulk transportation, “fire-proof isolation boxes” (complying with the UN 38.3 standard) must be used, with “fire-proof cotton” placed inside. A “lithium battery dangerous goods label” (UN 3480 or UN 3090) should be attached, and a “lithium battery transportation report” (issued by a qualified laboratory) must be provided. Countries such as Germany and the Netherlands require lithium battery goods to be transported separately and not mixed with ordinary goods (mixed transportation will result in detention of the entire batch).
III. Labeling Specifications: EU “Tax + Information” Dual Labels, Missing One Results in Failed Customs Clearance
EU last-mile delivery labels must meet both “tax compliance” and “information completeness” requirements. Although the UK became independent after Brexit, labeling rules are unified within the 27 EU countries. Enterprises must focus on three types of labels: “VAT number labels”, “address labels”, and “product information labels”.
(I) Tax Labels: VAT Number + EORI Number, Both Are Indispensable
Cross-border goods in the EU must have tax information marked in a prominent position on the packaging; otherwise, they will be classified as “smuggling suspects” during customs clearance, facing fines and cargo detention.
1. VAT Number Label
- Format Requirements: Must mark the “EU VAT number” (e.g., German VAT format “DE123456789”, French VAT format “FR12345678901”) with a font size ≥ 12pt and black color. It should be attached to the right of the address label without overlapping with address information.
- Application Scenarios: All EU cross-border goods (regardless of value) must be marked. If using Amazon FBA or eBay overseas warehouses, the “warehouse code” (e.g., Amazon Germany warehouse code “DE89”) must also be marked to avoid wrong warehouse delivery (a wrong delivery rate exceeding 2% will result in platform shipment restrictions).
2. EORI Number Label
- Format Requirements: The EORI number is a “unified EU code” (format “EU + 15-digit number”, e.g., “EU123456789012345”). It should be attached to the top of the packaging with a distance ≥ 5cm from the VAT number label to facilitate customs scanning and identification.
- Application Scenarios: For goods with a value exceeding €150 or weight exceeding 30kg, marking the EORI number is mandatory; for goods below this standard, marking is optional but recommended (can shorten customs clearance time by 1-2 days).
(II) Address Labels: Bilingual Marking + Accurate Postcode, Avoid “Cross-Country Delivery”
Due to different languages across EU countries, address labels must be “marked in both local language and English”. Postcode formats also vary significantly, and errors will cause delivery delays (EU logistics providers charge €15-30 per secondary delivery).
1. Format Standards
- Included Information: Recipient’s name, mobile phone number (with country code, e.g., German mobile number “+4917612345678”), complete address (country + city + street + house number + apartment number), and postcode. Examples:
- German address: “Max Mustermann, +4917612345678, Berliner Straße 10, 10117 Berlin, Deutschland (Germany)”
- French address: “Marie Dubois, +33612345678, Rue de Paris 5, 75001 Paris, France (France)”
- Postcode Requirements: German postcodes are 5 digits (e.g., “10117”), French postcodes are 5 digits (e.g., “75001”), Italian postcodes are 5 digits (e.g., “00100”), and Spanish postcodes are 5 digits (e.g., “28001”). Postcode validity must be verified in advance on the EU Postal Service official website (Europa-Post) to avoid wrong entry (wrong postcodes will cause goods to be sent to other cities, with a retrieval cost exceeding €200 per piece).
2. Special Markings: “Surcharge Notice” for Remote Areas, “Self-Pickup Code” for Self-Pickup Goods
- Remote Areas (e.g., Bavarian mountainous areas in Germany, Corsica in France): “Remote Area – Additional Fee Applicable” must be marked below the address label, and customers must be informed in advance to pay the remote area surcharge (€10-20 per piece) to avoid refusal of acceptance due to fee disputes.
- Self-Pickup Goods (e.g., Amazon collection points, DHL lockers): A “self-pickup code label” (provided by the logistics provider, containing a 12-digit code) must be attached, and the name of the self-pickup point (e.g., “DHL Packstation 123, Berlin”) must be marked to facilitate customers to pick up goods with the code.
(III) Product Information Labels: CE Certification + Country of Origin, Food Requires “Nutrition Facts Table”
The EU requires all imported goods to mark basic product information, especially certification marks and country of origin. Missing information will result in classification as “incomplete information”, preventing entry into the sales process.
1. General Labels
- CE Certification Mark: Electronic, mechanical, and toy products must have the “CE mark” (height ≥ 5mm, clearly distinguishable) attached, along with the “CE certification report number” (e.g., “CE-2024-1234”). Goods without the CE mark are prohibited from being sold in the EU and will be seized by customs (100% seizure rate).
- Country of Origin Label: Must mark “Made in [Country]” (e.g., “Made in China”) with a font size ≥ 10pt. It should be attached to the product packaging or label and must not be altered (the EU anti-dumping policy requires the country of origin to be authentic; false marking will face a fine of 10 times the goods value).
2. Special Category Labels
- Food Products: Must have a “nutrition facts table” (bilingual marking, including calorie, fat, protein content, etc.) and a “best-before date label” (format “Best Before: DD/MM/YYYY”). For example, chocolate must mark the “cocoa content” (e.g., “Cocoa Content ≥ 70%”) to comply with the EU 1169/2011 standard; otherwise, it cannot be sold in supermarkets.
- Textiles: Must mark the “fiber composition” (e.g., “100% Cotton”) and “washing instructions” (icon marking, complying with the ISO 3758 standard). For example, wool products must have the “pure wool certification mark” (issued by the International Wool Secretariat) to avoid customer complaints due to false composition claims.
IV. Air/Sea Freight Certifications: EU “Safety + Eco” Dual Certifications, Missing One Results in Failed Goods Collection
The EU has significantly different certification requirements for air and sea freight goods: air freight focuses on “dangerous goods safety certification”, while sea freight emphasizes “eco and tax certifications”. Enterprises must prepare in advance according to the transportation method to avoid being unable to clear customs after goods arrive at the port.
(I) Air Freight Certifications: “UN38.3” for Lithium Batteries, “Air Transport Condition Assessment” for Dangerous Goods
EU air freight goods must comply with the “IATA Dangerous Goods Regulations (DGR)”, especially for lithium batteries, liquids, and other goods. Incomplete certification will result in refusal of shipment by airlines.
1. Ordinary Goods (Clothing, Furniture, Non-Dangerous Goods)
- A “commercial invoice” (filled in English, including buyer and seller information, goods name, HS code, quantity, unit price, total price, and country of origin) must be provided. The invoice amount must be consistent with the declared value (error ≤ 5%) to avoid fines for underreporting (fine amount: 2-5 times the difference).
- Goods weighing over 30kg must have a “weight label” (marked with “Gross Weight: XX kg”), and goods with dimensions exceeding 150cm (length + width + height) must have an “oversized item label”. Booking with the airline must be made 48 hours in advance (EU air freight peak seasons are June-August and November-December; failure to book will cause 3-5 days of delay).
2. Special Goods Certifications
- Lithium Batteries (Transported Separately or as Battery-Containing Products): A “UN38.3 test report” (issued by an IATA-qualified laboratory, e.g., SGS, Intertek) and a “lithium battery air transport condition assessment certificate” (confirming whether the battery is a “non-restricted dangerous good”) must be provided. A “lithium battery dangerous goods label” (UN 3480 or UN 3090) should be attached. The energy of lithium batteries in a single package must be ≤ 100Wh; exceeding this requires using a “dangerous goods dedicated line” (freight cost increases by more than 50%).
- Liquid Goods (Cosmetics, Food Additives): A “liquid safety test report” (confirming no corrosiveness or flammability) must be provided, and a “liquid label” should be attached. The capacity of a single container must be ≤ 1L, and “leak-proof trays” must be used for bulk transportation to avoid leakage (EU airlines fine over €1,000 per batch for leaked liquid goods).
- Medical Devices (Masks, Thermometers): A “CE certification report” (complying with the EU 2017/745 MDR standard) and a “Free Sale Certificate (FSC)” must be provided, and a “medical device label” should be attached. Otherwise, customs will classify them as “illegal medical products”, facing seizure and criminal penalties.
(II) Sea Freight Certifications: “IMO Label” for Eco-Friendliness, “VAT Deferral Application” for Tax Compliance
EU sea freight goods must comply with the “IMO International Maritime Dangerous Goods Code” and “EU tax compliance requirements”, especially for bulk goods and high-value goods. Incomplete certification will cause port detention.
1. Ordinary Goods (Container Transport)
- A “packing list” (filled in English, including details, weight, volume, and container number of goods in each container) and a “bill of lading (B/L)” (telex release B/L or original B/L; telex release B/L must be marked with “Telex Release”) must be provided. The B/L information must be consistent with the commercial invoice (container number, goods name, and quantity must be correct); otherwise, goods cannot be picked up after document exchange