What CER is and why it matters
The Ceramics Directive — formally Council Directive 84/500/EEC on the approximation of the laws of the Member States relating to ceramic articles intended to come into contact with foodstuffs — is the EU’s specific measure controlling how much lead and cadmium may migrate out of ceramic tableware and cookware into the food it touches. If you make, import or sell plates, cups, bowls, mugs, jugs, baking dishes or any other ceramic article meant for food contact, this directive sets the limits your products must meet. Lead and cadmium are used in ceramic glazes, decorations and pigments, and both are toxic; the directive exists because these metals can leach into food and drink, especially acidic foods, and accumulate in the body.
CER matters because it is a concrete, testable requirement sitting underneath the wider EU food-contact-materials framework. While the general rules say food-contact articles must not transfer their constituents to food in quantities that could endanger health, CER turns that principle into hard migration limits and a defined test method for one specific material — ceramics — and two specific hazards — lead and cadmium. For a brand, that means compliance is not a matter of judgement but of measurable values.
📄 Official text: Council Directive 84/500/EEC on ceramic articles in contact with food — on EUR-Lex →
Who CER applies to
CER applies to any ceramic article intended to come into contact with food, and the duties fall across the supply chain:
- Manufacturers — anyone producing ceramic tableware, cookware, storage or serving articles for food contact. They are responsible for ensuring the finished article does not release lead and cadmium above the limits and for holding the test evidence that proves it.
- Importers — businesses bringing ceramic articles from outside the EU into the Union market. They must verify that the products meet the migration limits and that a written declaration of compliance is available, taking on responsibility where there is no EU-based manufacturer.
- Distributors and retailers — wholesalers and sellers who place ceramic food-contact articles on the market must be able to show, on request, that the articles are accompanied by the required declaration of compliance.
The directive applies specifically to ceramic articles — articles made from a mixture of inorganic materials, generally of high alumina or silica content, to which other materials may be added, and which are fired. It covers the article in its finished form, including any glaze, enamel or decoration applied to the food-contact surface.
Key dates and timeline
- 1984 — Council Directive 84/500/EEC was adopted, harmonising national rules on lead and cadmium release from ceramic food-contact articles into a single EU set of limits and a common test method.
- 2005 — the directive was amended by Commission Directive 2005/31/EC, which updated the provisions on the written declaration of compliance and the rules on methods of analysis, reflecting developments in the wider food-contact-materials framework.
Because CER is a directive rather than a regulation, it does not apply directly; it is transposed into the national law of each Member State, which is where its requirements become enforceable on businesses.
Core requirements
Migration limits for lead and cadmium
The heart of CER is a set of maximum quantities of lead and cadmium that may migrate from a ceramic article into food. The limits are expressed by reference to the shape of the article, because shape determines how much surface contacts the food and for how long. The directive distinguishes three categories:
- Articles which cannot be filled, and articles which can be filled but where the internal depth measured from the lowest point to the horizontal plane passing through the upper rim does not exceed a set shallow threshold — flatware such as plates and shallow dishes. For these the limit is set per unit of surface area.
- All other articles which can be filled — cups, bowls, jugs and similar hollowware. For these the limit is set per unit of volume.
- Cooking ware; packaging and storage vessels having a capacity above a defined large volume — for which a stricter limit applies, reflecting prolonged contact and heating.
The article is judged against the limit for the category into which it falls, and the limits for lead and for cadmium are specified separately.
Migration test conditions
CER prescribes how the article is tested. The ceramic surface that would contact food is brought into contact with a standard test solution of acetic acid — a food simulant chosen because acidic conditions promote the release of lead and cadmium — at a defined temperature and for a defined contact time intended to represent realistic use. The quantity of lead and cadmium that has migrated into the solution is then measured by analysis and compared against the limit for the article’s category. The directive also sets out how repeat testing and tolerances are handled where a result is close to the limit.
Written declaration of compliance
Ceramic articles that are not yet in contact with food, when marketed at stages before the retail stage, must be accompanied by a written declaration of compliance. This declaration confirms that the article meets the requirements of the directive and identifies the article and the responsible business. It allows each actor in the supply chain — and the enforcement authority — to confirm compliance without re-testing every consignment, and supporting documentation with the test results must be made available to the competent authorities on request.
Relationship to the FCM framework
CER does not stand alone. It sits beneath Regulation (EC) No 1935/2004, the framework regulation on materials and articles intended to come into contact with food. That framework sets the general safety principle — food-contact materials must not endanger health, change the composition of the food unacceptably, or alter its taste, odour or appearance — together with overarching rules on traceability and declarations. CER is the specific measure that applies those principles to ceramics for lead and cadmium, so a ceramic food-contact article must satisfy both the framework regulation and CER.
Obligations by role
- Manufacturers — ensure articles meet the lead and cadmium migration limits for their category, carry out or commission testing under the prescribed conditions, issue the written declaration of compliance and retain the supporting analytical results.
- Importers — verify migration compliance and the declaration before placing articles on the EU market, and keep documentation available for authorities.
- Distributors and retailers — ensure the declaration of compliance accompanies the articles they handle and cooperate with enforcement checks.
Enforcement
CER is enforced at national level by the Member States’ food-contact-materials and food-safety authorities through the national laws that transpose it. In Denmark, food-contact materials including ceramics are overseen by the Danish Veterinary and Food Administration (Fødevarestyrelsen), which can sample articles on the market, require migration testing and act against products that exceed the limits.
Non-compliant ceramic articles — typically those releasing lead or cadmium above the limits, often from decorated or brightly glazed food-contact surfaces — can be ordered off the market, and unsafe food-contact materials are shared across the EU through the rapid alert system for food and feed (RASFF). The practical consequence for a brand is that a single failing batch can trigger withdrawals and cross-border alerts.
Getting compliant
- Identify which of your articles are ceramic and intended for food contact, and determine the category (flatware, fillable hollowware, or cooking ware / large storage vessels) for each.
- Have the food-contact surface tested for lead and cadmium migration under the directive’s acetic-acid test conditions.
- Confirm results are within the limit for each article’s category, paying particular attention to decorated rims and brightly coloured glazes.
- Issue a written declaration of compliance for articles marketed before the retail stage.
- Retain the analytical test results and make them available to authorities on request.
- Check that you also meet the overarching obligations of the FCM framework regulation.
Related guides
How Conphora helps
Conphora monitors CER and maps your ceramic food-contact articles against its requirements, flagging where migration testing, category classification or the written declaration of compliance is missing before it becomes an enforcement problem. The platform helps you generate and keep the right documentation, and alerts you when the rules change so your compliance stays current.
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Sources and further reading
- Council Directive 84/500/EEC on ceramic articles in contact with food — EUR-Lex
- Fødevarestyrelsen (Danish Veterinary and Food Administration) — foedevarestyrelsen.dk
This guide is for general information and is not legal advice.
Last updated: 12 June 2026