For a factory supplying dinnerware into the European Union, the sale does not end with a clean shipment - it ends with a Declaration of Compliance and the documentation that backs it. This guide explains what EU food contact law requires of ceramic tableware, the lead and cadmium migration limits a buyer should verify, and the papers a supplier trading into the EU should be able to produce without hesitation.
How EU food contact law is structured
If you have bought ceramic from China for the American market, the EU approach can feel different, because it is built in layers rather than around a single "approval".
- Framework Regulation (EC) No 1935/2004 is the base. It lays down the general safety principle: materials must not release constituents into food at levels harmful to health, and must not change food's composition, taste or odour unacceptably. It also creates the requirement for compliance documentation (Article 16) and traceability (Article 17).
- Good Manufacturing Practice (EC) No 2023/2006 applies to all stages of manufacture. It requires documented quality systems, suitable starting materials, and controls over critical production steps - in short, that the factory can show how it keeps every firing line consistent.
- Directive 84/500/EEC (as amended) is the specific measure for ceramics. It sets the migration limits for lead and cadmium and the conditions for testing them.
So when a European importer asks a supplier for "EU compliance", what they are really asking for is a coherent set of documents showing that a specific, traceable article stays under the Directive's limits and was made under controlled conditions.
The lead and cadmium migration limits that matter
The core evidence for ceramic tableware is a migration test - the article is filled with a 4 % acetic acid solution, held at 22 C for 24 hours, and the lead and cadmium that transfer into the solution are measured. The results are compared with the Directive's limits, which depend on the article's shape:
| Category | What it covers | Lead (Pb) limit | Cadmium (Cd) limit |
|---|---|---|---|
| Category 1 | Articles that cannot be filled, or fillable articles no deeper than 25 mm - plates, saucers, shallow flatware | 0.8 mg/dm² | 0.07 mg/dm² |
| Category 2 | All other fillable articles - cups, mugs, bowls, dinnerware with capacity up to 3 litres | 4.0 mg/l | 0.3 mg/l |
| Category 3 | Cooking ware and packaging or storage vessels over 3 litres | 1.5 mg/l | 0.1 mg/l |
Two practical points for buyers. First, the same surface can sit in different categories - a coffee mug is Category 2, a dinner plate is Category 1 - so a single "compliant" line is not enough; the test report should cover each article shape and each decoration you plan to sell. Second, the Directive also recognises the average rule: if an article exceeds a limit by no more than 50 %, it can still pass if a batch of four samples averages within the limit. What a buyer should ask for is the actual recorded values, not just a verb "compliant", so the batch can be judged against the same rule the authorities will apply.
The Declaration of Compliance: what it must contain
Under Article 16 of the Framework Regulation, ceramic articles that have not yet been in contact with food must, at all marketing stages up to and including retail, be accompanied by a written Declaration of Compliance. It is issued by the manufacturer, or by a seller/importer established in the EU, and the Directive (through 2005/31/EC) requires four pieces of information:
- the identity and address of the company that manufactures the finished ceramic article and of the importer who imports it into the EU;
- the identity of the ceramic article (form, size, colour, decoration) so the certificate maps to a specific SKU, not to a family of products;
- the date of the declaration;
- confirmation that the article meets the requirements of the Directive and Regulation (EC) No 1935/2004.
That is a deliberately small set of fields. A compliant import must also be able to show the supporting documentation - the results of the analysis, the test conditions, and the name and address of the laboratory that performed the tests - when the national competent authority asks. In practice this means the Declaration of Compliance is only as valuable as the migration report and lab traceability behind it.
Traceability: one step back, one step forward
Article 17 of the Framework Regulation requires every operator to keep systems that allow identification of whom they bought from and whom they supplied to - "one step back and one step forward". For a buyer this is the insurance that a problem, whether a glaze batch or a decoration pigment, can be isolated to a firing and recalled before it spreads. When a supplier's batch number cannot be tied to a test date and a customer, the whole compliance story becomes hard to trust, whatever the certificate says.
The German LFGB angle, and why language matters
Because the EU framework delegates some detail to national rules, the paperwork can vary by destination. The clearest example is Germany, covered by the German Food and Feed Code (LFGB, Lebensmittel- und Futtermittelgesetzbuch) and the national Bedarfsgegenständeverordnung (Consumer Goods Ordinance). There, the written declaration for ceramics must be supplied in the German language, must be available at the point of sale, and for online sales should be retrievable on the seller's website. The core requirement - a compliant article backed by a declaration - is the same, but a document in the wrong language does not satisfy the national rule.
The practical upshot: a buyer distributing across Germany, France and the Nordics should confirm in the contract whose job it is to provide local-language declarations, and should ask a supplier like a seasoned LFGB-compliant dinnerware factory whether their standard documentation package already covers the language and format each market expects.
The buyer's pre-PO checklist for EU ceramic tableware
Before signing off samples or a first container, put the following in writing:
- Migration test report per article shape and decoration (4 % acetic acid, 24 h), showing actual lead and cadmium values compared against the 84/500/EEC category that applies.
- Declaration of Compliance naming both the manufacturer and the EU importer, identifying the specific article, dated, and confirming conformity with 1935/2004.
- Supporting documentation - lab identity, test conditions, original analysis - ready to show a national authority on request.
- Laboratory credibility - independent, recognised test house, and reports fresh enough to cover the batch you are actually buying, not a generic five-year-old figure.
- German-language declaration if the ware will be placed on the German market (LFGB / Bedarfsgegenständeverordnung).
- Traceability system - batch numbers mapped to glaze/decor lots and to customers (one step back, one step forward).
- GMP documentation showing controlled production under Regulation (EC) No 2023/2006.
- Consistency clause tying "compliant" to the exact article number, so a glaze or decoration change that affects migration triggers re-testing rather than silent substitution.
A factory that can table all eight points - fresh test data, a clean Declaration of Compliance, and real traceability - is materially lower risk than one that offers a low price and a photocopied certificate. Before you commit to a first EU programme, ask for the documentation package and check it; the paperwork, not the glaze, is what keeps your container moving.