Which products are covered
Food-contact rules apply to any material or article intended to come into contact with food, or which can reasonably be expected to. In a homeware range that includes plates, bowls, cups and mugs, cutlery, glassware, decanters, glass teapots, serving trays, butter dishes, creamers, ice buckets and storage jars.
Decorative items that look like tableware are a grey area. A painted ceramic bowl sold as a decoration should be clearly labelled as not for food use. If it looks like a fruit bowl and has no such label, a market surveillance authority may treat it as food-contact.
This article is a practical overview, not legal advice. Check the current texts or ask your national authority before you place a new line on the market.
The framework: Regulation (EC) 1935/2004
The framework regulation applies to all food-contact materials. Its core rule is simple: materials must not transfer their constituents to food in quantities that could endanger health, change the composition of the food unacceptably or affect its taste and smell. It also requires:
- Labelling. The words "for food contact", a specific use such as "wine glass", or the glass-and-fork symbol, unless the use is obvious.
- Traceability. The importer must be able to identify who supplied the item and to whom it was sold.
- Good manufacturing practice. Regulation (EC) 2023/2006 requires documented quality assurance at the manufacturer.
Specific rules by material
| Material | Specific rule | Typical document |
|---|---|---|
| Ceramics, stoneware, porcelain | Directive 84/500/EEC, lead and cadmium migration limits | Declaration of compliance and migration test report |
| Plastics (melamine, PP, acrylic, tritan) | Regulation (EU) 10/2011 | Declaration of compliance and migration test report |
| Glass | No specific EU measure; framework applies, some national rules | Supplier declaration, migration test on decorated rim areas on request |
| Stainless steel cutlery | Framework; national rules and Council of Europe guidance | Material specification and metal release test on request |
| Wood and bamboo | Framework; national rules in some countries | Supplier declaration, details of coatings and oils |
Ceramics: lead and cadmium
For ceramics the risk is in the glaze and the decoration. Directive 84/500/EEC sets limits for lead and cadmium migration and requires a written declaration of compliance at each stage of marketing up to retail. The supporting test report is done on the finished article, in the glaze and colour you buy.
- Each glaze colour is a separate test, because pigments differ.
- Decoration on the rim, where the lips touch, is the most sensitive area.
- Reactive and handmade glazes vary, so ask how the factory controls the batch.
Plastics: Regulation (EU) 10/2011
Plastic serving trays, picnic plates, acrylic glasses and melamine bowls fall under the plastics regulation. Only substances on the Union list may be used, and both overall migration and specific migration limits apply. A declaration of compliance is mandatory.
Watch out for plastics filled with bamboo or other plant fibres. These fillers are not authorised additives, and products made from them have been withdrawn from the EU market. We do not offer them.
Glass and decorated glass
Plain soda-lime or borosilicate glass is generally a low-risk material. Decorated glass is different: printed rims, gold bands and coloured coatings can release metals. If a glass has decoration within the lip area, ask for a migration test on that area. For glass teapots and double-wall mugs, also check the stated temperature range and whether the item is suitable for a hob, a microwave or a dishwasher, per supplier data and confirmed on the sample.
What to request from the supplier
- Declaration of compliance for each item and material, naming the regulations it refers to.
- Migration test report from an accredited laboratory, on the item as supplied, with the test date and the item reference.
- Material specification. Body and glaze for ceramics, polymer type for plastics, grade of stainless steel for cutlery.
- Use conditions. Hot or cold food, dishwasher, microwave, oven, as declared by the manufacturer.
- Batch identification so that a report can be linked to the goods delivered.
We request these documents per item and pass on what the manufacturer provides. Our quality and compliance page lists the documents by category.
Common problems with documents
Most document problems are not about dangerous products but about paperwork that does not match the goods.
- Old reports. A test from several years ago on a different glaze does not cover this season's colour.
- Wrong item. The report covers a plate from the same factory, not the mug you ordered.
- Raw material only. A certificate for the polymer granulate is useful, but the declaration must cover the finished article.
- No use conditions. A melamine bowl tested at room temperature is not covered for hot soup.
- Missing link to the batch. Without an item reference and date, the report cannot be matched to the delivery.
Check the documents before production is released, not when the goods are already at the border. Market surveillance authorities in several EU countries sample tableware at import and in shops, and a missing declaration alone can stop a sale.
Labels and the GPSR
Food-contact law sits next to the General Product Safety Regulation, not instead of it. Tableware and glassware still need the importer's name and address, a type or batch number and any warnings in the language of the country of sale. Care information such as "not dishwasher safe" for gold-rimmed glass is good practice and prevents complaints.
Private label tableware
When you change a glaze, add a logo or print a decoration, the existing reports no longer cover the item. Budget for new tests on the final article before production is released. Our private label page explains how we schedule this, and the tableware and glassware categories show what is available.
