# DRAFT — Xieli Cap Making Co., Ltd (metal lid) — one declaration covering the COMPLETE closure

Prepared for Hoi Vu Company Limited PPWR dossier, 3/9/2026.
Genre model: sample dossier §12 rows 8–9 (Silgan White Cap closure declarations — heavy metals + PFAS, covering the gasket compounds, the coatings and the closure as a whole).
Evidence base: register §2 Metal lid rows (three EMTEK reports on Sealing Compound 1), §11 (SGS Shanghai SHAEC26013380302 on Jiangsu Suxun chromium-plated steel sheet — chain to Xieli unconfirmed); requests pack B3. This draft IS B3 item 3 (the closure-wide declaration) with B3 item 4 (the Suxun chain confirmation) built in as a signer confirmation.

**Language note.** Xieli Cap is a Chinese supplier: this English version is the operative letter to be signed and chopped. A simplified-Chinese companion (`draft-xieli-metal-lid-closure-260903.cn.md`) exists for fast internal review; a Vietnamese mirror (`draft-xieli-metal-lid-closure-260903.vi.md`) exists for the Hoi Vu file.

> **Signer must complete before returning:**
> - [[FILL: XIELI CAP MAKING CO., LTD full registered address, Jinjiang, Fujian, China]]
> - [[FILL: reference number]]
> - [[FILL: date of issue]]
> - [[FILL: closure type designation and nominal diameter(s) of the twist-off closures supplied]]
> - [[FILL: shell base material — chromium-plated (tin-free) steel sheet / tinplate — must match section 1]]
> - [[CONFIRM: the Jiangsu Suxun sentence in section 2(b). If the shell steel is NOT sourced from Jiangsu Suxun New Materials Technology Co., Ltd, strike that sentence and initial it; the shell statement then rests on the raw-material-supplier sentence that follows.]]
> - [[FILL — optional: internal lacquer / coating supplier name(s) in section 2(c), or delete the bracket]]
> - [[FILL — optional: PFAS test references for shell and lacquer in section 3(b), or delete that bracket]]
> - [[FILL: signer name, title, date]]

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**XIELI CAP MAKING CO., LTD (福建省晋江市协立制盖有限公司)**
[[FILL: full registered address, Jinjiang, Fujian, China]]

Ref: [[FILL: reference number]]
Date: [[FILL: date of issue]]

To: Hoi Vu Company Limited — Cau Giat Industrial Cluster, Duy Tan Ward, Ninh Binh Province, Viet Nam

**Subject: Declaration of conformity of the twist-off metal closures supplied to Hoi Vu Company Limited, with reference to Articles 5(4) and 5(5) of Regulation (EU) 2025/40 (PPWR)**

Dear Sir or Madam,

**1. Product and packaging role.** XIELI CAP MAKING CO., LTD supplies twist-off metal closures (type / nominal diameter(s): [[FILL]]) to Hoi Vu Company Limited for sealing the 370 ml, 720 ml and 1,000 ml glass jars exported to the European Union. The closures are primary packaging in direct contact with food. Each closure consists of: (a) a metal shell made of [[FILL: chromium-plated (tin-free) steel sheet / tinplate]]; (b) a PVC sealing gasket ("Sealing Compound 1"); and (c) an internal lacquer (food-contact coating) on the inner surface of the shell.

**2. Heavy metals — Article 5(4).** We hereby declare that the sum of the concentrations of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium (Cr(VI)) in the closures supplied to Hoi Vu does not exceed 100 mg/kg (0.01% by weight), in accordance with Article 5(4) of Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation), which reproduces the requirement previously established by Article 11 of Directive 94/62/EC. Specifically:

(a) *PVC sealing gasket.* Tested by EMTEK Dongguan, report no. EDG2607100108C00101R of 16 July 2026, on sample "Sealing Compound 1" (PVC): Cd, Pb, Hg and Cr(VI) all not detected; the four-metal sum is not detected, against the legal limit of 100 mg/kg, cited in the report to Regulation (EU) 2025/40.

(b) *Metal shell.* [[CONFIRM: We confirm that the shell of the closures supplied to Hoi Vu is manufactured from the chromium-plated steel sheet (镀铬板) of Jiangsu Suxun New Materials Technology Co., Ltd, Shuyang, Jiangsu, covered by SGS Shanghai report no. SHAEC26013380302 (job SHP26-016946) of 18 May 2026, in which Pb, Hg and Cd were all not detected (MDL 2 mg/kg) and Cr(VI) was not detected by the surface method; on the basis of these results, the four-metal sum of the shell material does not exceed 100 mg/kg. — if this is not correct, strike this sentence and initial it]] Based on the technical information given by our raw material suppliers, the sum of Pb + Cd + Hg + Cr(VI) in the shell material as supplied does not exceed 100 mg/kg. We do not perform any specific tests for this purpose beyond the assessments carried out by our raw material suppliers.

(c) *Internal lacquer.* Based on the technical information given by our coating suppliers [[FILL — optional: supplier name(s)]], the sum of Pb + Cd + Hg + Cr(VI) in the internal lacquer applied to the closures does not exceed 100 mg/kg. We do not perform any specific tests for this purpose beyond the assessments carried out by our raw material suppliers.

(d) *Closure as a whole.* On the basis of (a), (b) and (c) above — the tested sealing gasket, the shell material and the internal lacquer — the closures as a whole supplied to Hoi Vu comply with Article 5(4): the sum of Pb + Cd + Hg + Cr(VI) does not exceed 100 mg/kg.

**3. PFAS — Article 5(5).** With reference to points (a), (b) and (c) of Article 5(5) of Regulation (EU) 2025/40, we hereby declare that:

(a) *PVC sealing gasket.* Per- and polyfluoroalkyl substances (PFAS) are not intentionally added to the gasket. This is supported by: EMTEK Suzhou report no. ESZ2605070317C00101R of 13 May 2026 — PFAS screen of 306 substances, all not detected (specification limit 0.025 mg/kg); and EMTEK Suzhou report no. ESZ2605210275C00101R of 29 May 2026 — total fluorine not detected (MDL 30), against the specification limit of 50 mg/kg.

(b) *Metal shell and internal lacquer.* Based on the technical information given by our suppliers of steel and coatings, PFAS are not intentionally added to the shell material or to the internal lacquer at any stage of their manufacture. [[FILL — optional: "Supported by test report no. …, issued by …, dated …" — delete this bracket if no test data is held.]]

(c) *Closure as a whole.* PFAS are not intentionally added to the closures supplied to Hoi Vu.

**4. Supporting test reports.**

| Component | Laboratory | Report no. | Date | Sample | Key result |
|---|---|---|---|---|---|
| PVC sealing gasket | EMTEK Dongguan | EDG2607100108C00101R | 16/7/2026 | Sealing Compound 1 (PVC) | Cd, Pb, Hg, Cr(VI) all ND; four-metal sum ND; limit 100 mg/kg; cited to (EU) 2025/40 |
| PVC sealing gasket | EMTEK Suzhou | ESZ2605070317C00101R | 13/5/2026 | Sealing Compound 1 | PFAS, 306 substances screened — all ND (limit 0.025 mg/kg) |
| PVC sealing gasket | EMTEK Suzhou | ESZ2605210275C00101R | 29/5/2026 | Sealing Compound 1 | Total fluorine ND (MDL 30; limit 50 mg/kg) |
| Shell steel (per confirmation in section 2(b)) | SGS Shanghai | SHAEC26013380302 (job SHP26-016946) | 18/5/2026 | Chromium-plated steel sheet; applicant Jiangsu Suxun New Materials Technology Co., Ltd | Pb, Hg, Cd all ND (MDL 2 mg/kg); Cr(VI) ND by surface method |

**5. Validity.** This declaration is valid for twelve (12) months from the date of issue.

**6. Signature.**

for XIELI CAP MAKING CO., LTD

Name: [[FILL]]
Title: [[FILL]]
Date: [[FILL]]
Signature: ______________________
Company seal / chop


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### Notes for the file (not part of the letter)

- The SGS report is RoHS-worded, not PPWR-worded; this declaration folds its all-ND results into the Article 5(4) confirmation — exactly what register §11 recommends ("ask Xieli/EMTEK to fold this into the whole-closure declaration rather than leave it as arithmetic in the file"). The signer's [[CONFIRM]] is the written chain confirmation B3 item 4 asks for.
- One method caveat stands behind section 2(b): three bulk ND values (MDL 2 mg/kg) plus one surface ND value for Cr(VI) (µg/cm²). The sum statement rests on the signer's confirmation, not on dossier arithmetic.
- Ungrounded facts left as [[FILL]]: Xieli registered address, ref no., issue date, closure type and diameters, shell base material (chromium-plated vs tinplate), lacquer supplier name, any PFAS tests for shell/lacquer.
- Register §2 says Xieli is the lid supplier "for all three" deliverable sizes (370/720/1,000 ml); the 500 ml reference jar is not named in the letter.