The question this week is whether or not it is necessary to have a box maker’s certificate on a corrugated box. We asked an industry consultant to give his take on the issue.
If a boxmaker prints a box maker’s certificate on a box, they must do it in compliance with Item 222 and Rule 41 because the presence of the cert implies compliance with those regulations. Using a BMC to overstate a box’s compliance is technically fraud under the Uniform Commercial Code (UCC). There is absolutely no law or government agency rule requiring that you print a cert on any box unless it is a hazardous product or the box is being sold to the government.
Since a box maker’s cert implies compliance with the standards intrinsic to the certification, it actually creates a liability that some shippers wish to avoid; consequently, there are some good reasons to not print the cert. Since certing implies compliance, a boxmaker (and their customer) creates a liability by certing boxes that are in questionable compliance.
These rules are still hotly debated so I would expect a good deal of disagreement among folks who are generally knowledgeable about packaging design mostly because the most seasoned industry designers were trained before the law change and few seemed to have kept up with the regulations.
I always recommend that if you are in doubt, don’t apply a cert. Other consultants give exactly the opposite advice to their clients, again because they haven’t kept up with the changes. I have a number of customers who have stopped certing boxes for various reasons with absolutely no ramifications.
Companies that use on-demand packaging systems never cert their boxes and there are thousands of these systems world-wide so there is a de facto standard that packaging made on demand will not be cert’d. There is also an understanding in the freight industry that boxes made on demand perform better because they fit perfectly, so the freight industry (to the extent that they are keeping up with technology) encourages on demand boxes without certs.
We also apply certs in non-standard locations (such as on minor flaps which conceals the cert when the box is closed) if it simplifies the printing; again with no apparent ramifications. Because of the competitive nature of freight, carriers don’t pick fights about markings if the packaging is reasonably good.
Neither FedEx, UPS nor DHL cert their own boxes, and they collectively are the most ubiquitous shipping services in the world. Perhaps that is the most telling evidence that the box maker’s cert is dead.