2026 Food Export to the U.S.: Five Things You Must Know (A Disposable PP Corrugated Box Exporter's Guide)

If you are exporting Disposable PP Corrugated Boxes to the U.S., 2026 could be the year with the most regulatory changes in a decade. Here are five things that will determine whether your goods can enter the U.S., whether they will be detained, and how much it will cost if they are.

1. Anti-Dumping and Countervailing Duties Are in Effect—145.91%, Not a Myth

On January 16, 2026, the U.S. Department of Commerce issued final anti-dumping and countervailing duty determinations on polypropylene corrugated boxes imported from China.

The numbers:

• Anti-dumping duty: 83.64%

• Countervailing duty: 62.27%

• Combined anti-dumping/countervailing duty rate: 145.91%

How did this figure come about? In simple terms, Chinese companies did not participate in the response, and the U.S. side applied the "facts available" (AFA) rule—using the highest possible data to determine the rates.

Key details:

• HTS code for the products covered: 3923.10.9000

• Total U.S. imports of this product category from China in 2024 were approximately $150 million

• The antidumping/countervailing duty orders were officially issued on March 16, 2026, and suspension of liquidation has been lifted—all imports are now subject to cash deposit requirements

What this means: If you are still calculating costs based on the old 3% base duty rate, your books are already significantly off. With a 145.91% anti-dumping/countervailing duty combined rate, the cost structure for a full container needs a complete recalculation.

2. FDA Compliance for PP Corrugated Boxes—Don't Assume Packaging Doesn't Need FDA

Many people assume that "packaging doesn't need FDA approval." That assumption is wrong.

The FDA treats all food-contact packaging materials as Food Contact Substances (FCS) and regulates them under the Federal Food, Drug, and Cosmetic Act.

FDA regulations applicable to PP materials:

• Primary regulation: 21 CFR 177.1520—Olefin polymers

• Scope of application: PP products that come into direct or indirect contact with food, including corrugated boxes, trays, meal containers, etc.

The most important point: The FDA does not "certify" or "approve" packaging materials. There is no such thing as an "FDA approved" label. When a supplier says a material "meets FDA standards," it means the material satisfies the requirements of the corresponding section of 21 CFR. Brands should require suppliers to provide written compliance declarations and migration test reports, not rely on "verbal assurances."

Migration testing is central to compliance. Packaging must be tested under simulated use conditions (food type, temperature, contact duration) to ensure that chemical substances do not migrate into food above safe thresholds. For PP corrugated boxes used to transport fresh produce or frozen foods, the test conditions will differ. Make sure to require test reports that match the specific use scenario for your product.

3. The No Toxic Chemicals in Food Packaging Act of 2026—Styrene Polymers Included on the Prohibited List

On June 9, 2026, S. 4724 and H.R. 9231 were introduced in the Senate and House of Representatives, respectively.

Core content of the bill: 15 classes of substances are designated as "unsafe" food contact substances, including:

• Ortho-phthalates

• PFAS (perfluoroalkyl and polyfluoroalkyl substances)

• Bisphenol A, B, S, F, AF and related compounds

• Styrene Polymers

• Formaldehyde, ethylene oxide, benzene, etc.

Direct impact on PP corrugated box exporters:

PP itself does not contain styrene—the restriction on styrene polymers primarily targets polystyrene (PS) foam food containers. However, the bill sends a clear signal: the U.S. is broadly tightening chemical safety standards for food contact materials. If your PP corrugated boxes contain PFAS-based oil/grease-resistant coatings, or use phthalate-containing plasticizers, you will face direct compliance risks in the future.

Three key provisions:

1. No federal preemption: The bill explicitly allows state and local governments to enforce stricter standards. California's Proposition 65 and state-level PFAS bans remain in effect.

2. Protection of vulnerable populations: When reviewing alternative substances, the FDA is required to consider the impact on infants, children, pregnant women, the elderly, and workers .

3. Delayed effective date: The bill would take effect 2 years after enactment, giving industry time to adjust.

The window: If the bill passes in 2026, you will have roughly two years to adjust formulations and switch supply chains. Begin reviewing your ingredient list now.

4. FDA Post-Market Review—No Longer "Once Approved, Forever Valid"

In the past, many believed that once a substance received FDA clearance, it was permanent. On May 12, 2026, the FDA formally finalized its "Enhanced Systematic Process for Post-Market Assessment of Chemicals in Food," marking the start of a new era of full life-cycle review regulation.

Core mechanism:

The FDA continuously monitors safety signals for food contact substances. If new toxicological data, changes in exposure levels, or international regulatory actions emerge, a substance may be reintroduced into the assessment process.

Substances already under review in 2026:

• BHT (Butylated hydroxytoluene): A common antioxidant used in food and food contact materials. The FDA has issued a Request for Information (RFI) .

• 4 phthalate esters (including DEHP): Proposed for group management as "Chemically or Pharmacologically Related" (CPR) substances, with potential for cumulative risk assessment in the future.

Impact on PP corrugated box exporters: If the PP additives, antistatic agents, or flame retardants used in your products are among the chemicals under FDA review, you may need to provide additional safety data in the future. We recommend establishing a raw material composition file and tracking the FDA status of each additive.

5. Customs Review of Packaging Materials Has Intensified—Three Material Categories Under Special Scrutiny

Beyond tariffs and FDA regulations, U.S. Customs and Border Protection (CBP) has significantly increased physical inspections of packaging materials in 2026.

Three material categories under strict scrutiny:

1. Expanded Polystyrene (EPS): Foam plastic. Due to its non-recyclability and environmental harm, it is already restricted in the EU, Canada, Australia, and elsewhere. EPS cushioning packaging for electronics and fragile items is flagged at a high rate, leading to at least 3–7 days of delays, and in severe cases, requiring packaging replacement or payment of environmental handling fees.

2. Chlorinated plastics (PVC/PVDC): Emits dioxins when burned, and is frequently listed on Customs' "high-risk materials" list. This includes not only PVC blisters but also PVC-containing inks, coatings, or shrink films. Once detected, penalties are severe—possibly leading to full container return.

3. Uncertified "biodegradable" plastics: One of the biggest traps of 2026. Many materials marketed as "biodegradable" have no corresponding composting facilities in destination countries. Customs is now requiring internationally recognized certification such as TÜV OK Compost or BPI certification; otherwise, they will be treated as regular plastics and subject to penalties.

Recommendations for PP corrugated box exporters:

• PP material itself is not on the high-risk list (unless PFAS coatings or PVC-containing printing inks are used), but printing inks, labels, tape, and coatings can all become "hidden landmines."

• Request material environmental declarations and ingredient lists from your suppliers.

• If your PP corrugated boxes have printed graphics, confirm whether the ink contains PVC components.

Practical Checklist for Exporters

Tariff level:

• Verify whether your HTS code is 3923.10.9000; if so, immediately include the 145.91% anti-dumping/countervailing duty in your cost model.

• Without considering other stacked duties (base duty, Section 301, IEEPA), this anti-dumping/countervailing duty alone already doubles your cost.

FDA compliance level:

• Require suppliers to provide written compliance declarations meeting 21 CFR 177.1520.

• Request third-party migration test reports, confirming that test conditions match your product's actual use scenario.

• Establish a raw material composition file and track the FDA compliance status of additives used in PP.

Chemical substance risk level:

• Confirm whether your PP corrugated boxes use PFAS oil/grease-resistant coatings or phthalate plasticizers.

• Monitor the progress of S. 4724/H.R. 9231—the styrene polymers prohibition provision could affect future supply chain choices.

• Track FDA post-market assessment developments, particularly concerning BHT and phthalates.

Packaging material level:

• Confirm that printing inks, labels, and tape contain no PVC or PVC derivatives.

• If claiming "biodegradable" properties, prepare internationally recognized certification in advance.

• Request complete material ingredient lists and environmental declarations from your supplier.

The U.S. market in 2026 is no longer a "price first" market. Anti-dumping/countervailing duties can strip away your price competitiveness overnight. FDA regulations can have your entire container detained upon arrival. Chemical substance bans can force you to redesign your product line just after you've finished adjusting it. Doing your compliance homework upfront—is far cheaper than paying hundreds of thousands of dollars in fines after the fact.