---
title: "CER — Ceramics Directive"
description: "The Ceramics Directive caps the lead and cadmium that ceramic tableware, cooking ware and storage vessels for food contact may release into food, and requires a written declaration of compliance from the manufacturer or an EU-established seller. Non-compliant articles have been banned since 17 October 1989, and the declaration rules of Commission Directive 2005/31/EC apply from 20 May 2006."
type: "guide"
url: "https://www.conphora.com/regulations/cer/"
markdown: "https://www.conphora.com/regulations/cer.md"
locale: "en"
language: "en"
published: "1984-10-17"
updated: "2026-09-11"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Council Directive 84/500/EEC"
celex: "31984L0500"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31984L0500"
tags: ["CER", "Food & Cosmetics"]
license: "Free to quote with attribution and a link to the page"
---

# CER — Ceramics Directive

The Ceramics Directive caps the lead and cadmium that ceramic tableware, cooking ware and storage vessels for food contact may release into food, and requires a written declaration of compliance from the manufacturer or an EU-established seller. Non-compliant articles have been banned since 17 October 1989, and the declaration rules of Commission Directive 2005/31/EC apply from 20 May 2006.

## Key facts

- **Official title:** Council Directive 84/500/EEC of 15 October 1984 on the approximation of the laws of the Member States relating to ceramic articles intended to come into contact with foodstuffs
- **Reference:** Council Directive 84/500/EEC
- **CELEX:** 31984L0500
- **Act type:** Directive
- **In force:** 1984-10-17
- **Applies from:** 1989-10-17
- **Enforced by:** Member States enforce the national laws transposing the directive through the official controls of the food contact materials framework, Regulation (EC) No 1935/2004, of which the directive is a specific measure; in Denmark, Fødevarestyrelsen (the Danish Veterinary and Food Administration) administers the rules: executive order nr. 681 of 25 May 2020 on food contact materials was issued by Fødevarestyrelsen under the Danish food act (sections 25, 25 a, 49(1) and 60(3)) and delegated powers, it implements the directive, extends the same lead and cadmium limits to enamelled articles and glassware, adds a mouth-rim limit for drinking vessels and makes Fødevarestyrelsen the authority to be notified when non-compliant materials are withdrawn. The toolkit is the marketing ban for non-compliant articles, the operator's duty to withdraw them, notify Fødevarestyrelsen and inform or recall from consumers, the authorities' right to demand the declaration of compliance and the underlying test documentation, temporary national suspension of the EU limits on health grounds, and national sanctions that must be effective, proportionate and dissuasive, which in Denmark are fines and up to two years' imprisonment for intentional or grossly negligent infringements that harm or endanger health or seek an economic gain.
- **Category:** Food & Cosmetics

## Who it applies to

**Covered by the act:** Ceramic articles which, in their finished state, are intended to come into contact with foodstuffs, or which are in contact with foodstuffs and are intended for that purpose (Art. 1(2)); Ceramic means manufactured from a mixture of inorganic materials with a generally high argillaceous or silicate content, to which small quantities of organic materials may have been added, shaped and then permanently fixed by firing; the articles may be glazed, enamelled and/or decorated (Art. 1(3)); Articles are sorted into three categories: articles which cannot be filled and fillable articles no deeper than 25 mm (category 1), all other articles which can be filled (category 2), and cooking ware and packaging and storage vessels with a capacity of more than three litres (category 3); in practice that covers plates, dishes and other flatware, cups, mugs, bowls, jugs and other hollowware, cooking ware and ceramic storage vessels (Art. 2(4)); Vessels fitted with a ceramic lid, tested as vessel and lid separately with the sum related to the vessel alone (Art. 2(3)); The manufacturer of the finished article, the seller established in the Union that issues the declaration, and the importer into the Union that must hold the test documentation (Art. 2a and Annex III)

**Derived and downstream products:** Article 1(1) still calls the directive a specific directive under Article 3 of Directive 76/893/EEC; Directive 89/109/EEC repealed that directive and provided that references to it are construed as references to Directive 89/109/EEC (Art. 10), and Regulation (EC) No 1935/2004 in turn repealed Directive 89/109/EEC and provided that references to the repealed directives are construed as references to the regulation (Art. 26), so the reference in Article 1(1) is read as a reference to Regulation (EC) No 1935/2004, and Directive 2005/31/EC describes the ceramics directive as a specific measure within the meaning of Article 5 of that regulation, so the framework's general requirements, labelling, traceability and controls apply on top of the lead and cadmium limits; Because the framework regulation does not apply to materials and articles supplied as antiques, antique ceramics fall outside the food contact regime, while the directive itself contains no antiques clause (Regulation (EC) No 1935/2004, Art. 1(3)(a)); Article 4(1)(a) required the Council to set, within three years of notification, limitations for the areas of ceramic articles that touch the mouth; the consolidated text of 20 May 2005 contains no such rim limit, so the EU limits apply to the vessel as a whole, whereas the Danish order sets a separate mouth-rim limit for drinking vessels (bilag 4, kategori I, point 3); Ceramics are one of the 17 material groups in Annex I to Regulation (EC) No 1935/2004; glass and enamelled metal are separate groups with no EU specific measure, so national rules under Article 6 of the framework regulation apply to them, and Denmark applies the ceramics limits to enamelled articles and glassware nationally (order nr. 681 of 25 May 2020, § 14); Good manufacturing practice under Regulation (EC) No 2023/2006 applies to every business operator manufacturing ceramic food contact articles from 1 August 2008, at all stages up to but excluding the production of starting substances (Art. 1, Art. 2 and Art. 8)

**Roles under the act:**

- **Business operator (any stage of manufacture, processing or distribution)** — The natural or legal persons responsible for ensuring that the requirements of the food contact materials framework are met within the business under their control; a business is any undertaking, whether for profit or not and whether public or private, carrying out any activity related to any stage of manufacture, processing and distribution of materials and articles. For ceramics the directive names three of them: the manufacturer, the seller established in the Community and the importer.
- **Manufacturer of the finished ceramic article** — The company which manufactures the finished ceramic article, whose identity and address must appear in the declaration of compliance; it issues that declaration for articles not yet in contact with food and must make the analysis results, test conditions and the name and address of the testing laboratory available to the national competent authorities on request.
- **Importer into the Union, or seller established in the Union responsible for placing on the market** — The importer who imports the ceramic article into the Community, whose identity and address must appear in the declaration of compliance alongside the manufacturer's and who, like the manufacturer, must make the supporting test documentation available to the authorities on request; as a seller established within the Community it may itself issue the declaration. Under the framework regulation its name and address must accompany the article as the seller responsible for placing on the market established within the Community, and the Danish order treats the importer like the producer for withdrawal and notification.
- **Distributor, wholesaler or retailer** — A business at the marketing stages after manufacture or import, up to and including the retail stage, that holds ceramic articles for sale or transfers them; the declaration of compliance must accompany the articles at every one of those stages, the labelling information must be displayed at retail in a language purchasers easily understand, and the business must be able to identify its suppliers and customers.

## Key dates

- 1984-10-15: Council Directive 84/500/EEC adopted by the Council in Luxembourg
- 1984-10-17: Directive notified to the Member States; the transposition periods of Article 5 run from this date
- 1984-10-20: Publication in OJ L 277 of 20 October 1984, page 12
- 1987-10-17: Three years after notification: Member States must permit trade in ceramic articles that comply with the directive; deadline for the Council to set limits for the areas that touch the mouth and for the Commission to re-examine the limits and the lighting conditions of the test
- 1989-10-17: Five years after notification: placing on the market of ceramic articles that do not comply with the directive is prohibited; Member States may also prohibit their manufacture
- 2004-12-03: Regulation (EC) No 1935/2004 in force: the framework for all food contact materials, with ceramics as one of the 17 material groups for which specific measures may be adopted; Directive 89/109/EEC repealed
- 2005-05-20: Commission Directive 2005/31/EC in force, the twentieth day after publication in OJ L 110 of 30 April 2005: it inserts Article 2a on the declaration of compliance, replaces Annex II with performance criteria for the analytical method and adds Annex III
- 2006-05-20: Deadline for Member States to adopt and publish the laws transposing Directive 2005/31/EC; trade in and use of ceramic articles complying with it must be permitted from this date
- 2006-10-27: Article 17 of Regulation (EC) No 1935/2004 applies: traceability systems to identify the businesses from which and to which ceramic articles were supplied
- 2007-05-20: Manufacture and importation into the Community of ceramic articles that do not comply with Directive 2005/31/EC (declaration of compliance, supporting documentation, analytical performance criteria) prohibited
- 2008-08-01: Regulation (EC) No 2023/2006 on good manufacturing practice applies to all sectors and to all stages of manufacture, processing and distribution of food contact materials, up to but excluding the production of starting substances, ceramics included
- 2019-12-14: Regulation (EU) 2017/625 on official controls applies and repeals Regulation (EC) No 882/2004, which Article 24(3) of the framework regulation still cites
- 2020-07-01: Danish executive order nr. 681 of 25 May 2020 on food contact materials in force, replacing order nr. 1248 of 30 October 2018: it implements the directive, applies the same lead and cadmium limits to ceramic and enamelled articles and glassware, adds a mouth-rim limit and requires the ceramics declaration of compliance up to and including retail
- 2025-07-17: TRIS notification 2025/0387/DK received: Denmark notifies a draft order that would repeal order nr. 681 of 25 May 2020, take effect on 1 January 2026 and apply lower lead and cadmium limits, expressed in micrograms, to ceramic and enamelled articles and glassware from 1 July 2026; standstill extended to 19 January 2026, Spain issued a detailed opinion, and as at 17 September 2026 Retsinformation still lists order nr. 681 as the order in force

## What you must do

### Manufacturer of the finished ceramic article

- Keep the lead and cadmium released by each article within the limit for its category: 0,8 mg/dm² lead and 0,07 mg/dm² cadmium for category 1 (non-fillable or up to 25 mm deep), 4,0 mg/l and 0,3 mg/l for category 2 (other fillable articles), 1,5 mg/l and 0,1 mg/l for category 3 (cooking ware, packaging and storage vessels above three litres).
- Determine migration with the Annex I test: 4 % (v/v) acetic acid freshly prepared, 22 ± 2 °C for 24 ± 0,5 hours, fillable articles filled to within 1 mm of the overflow point (6 mm along a flat or sloping rim), non-fillable articles immersed after protecting the non-contact surface, the sample covered and kept in total darkness when cadmium is determined, and lidded vessels tested as vessel and lid separately.
- Use an instrumental method of analysis that meets the Annex II performance criteria: detection limits of at most 0,1 mg/l lead and 0,01 mg/l cadmium, quantification limits of at most 0,2 and 0,02 mg/l, recovery of 80 to 120 %, freedom from matrix and spectral interference, a blank for each series, and samples washed in household detergent at about 40 °C and not handled on the test surface afterwards.
- Rely on the tolerance only as the directive allows: an article exceeding a limit by no more than 50 % still passes if at least three other articles of the same shape, dimensions, decoration and glaze are tested and their average does not exceed the limit, with none of them exceeding it by more than 50 %.
- Issue the written declaration of compliance for articles not yet in contact with food, so that it accompanies them at every marketing stage up to and including retail, stating your identity and address and those of the importer into the Union, the identity of the article, the date, and the confirmation that the article meets the relevant requirements of the directive and of Regulation (EC) No 1935/2004; make it easy to match to the goods and renew it when substantial changes in production alter the lead or cadmium migration.
- Keep appropriate documentation demonstrating compliance with the migration limits, containing the results of the analysis carried out, the test conditions and the name and address of the laboratory that performed the testing, and make it available to the national competent authorities on request.
- Manufacture under good manufacturing practice with a documented quality assurance system, a quality control system and records of specifications, formulae, processing and controls available to the authorities, so that the articles do not transfer constituents to food in quantities that endanger health, change the food unacceptably or spoil its taste or smell.
- Manufacture under good manufacturing practice with a documented quality assurance system and a quality control system, so that the articles do not transfer constituents to food in quantities that endanger health, change the food unacceptably or spoil its taste or smell.
- Keep documentation on specifications, formulae, processing and quality control results and make it available to the competent authorities on request.
- Label articles not yet in contact with food with the words for food contact, a specific indication of use or the Annex II symbol unless the article is clearly intended for food contact, any special instructions for safe use, your name or trade name and address, and the identification that ensures traceability; keep systems that identify the businesses you supplied and were supplied by.
- Label articles not yet in contact with food with the words for food contact, a specific indication of use or the Annex II symbol, unless the article is clearly intended for food contact, and with any special instructions for safe and appropriate use.
- Put your name or trade name and address or registered office on the article, its packaging, a label or the accompanying documents.
- Label or otherwise identify the articles so that they can be traced.
- Keep systems and procedures that identify the businesses you supplied and the businesses that supplied you, and make that information available to the competent authorities on demand.

### Importer into the Union, or seller established in the Union responsible for placing on the market

- Import only ceramic articles that meet the category limits: since 20 May 2007 Member States must prohibit the importation into the Union of ceramic articles that do not comply with the directive as amended by Directive 2005/31/EC.
- Make sure a written declaration of compliance accompanies the articles from your first sale onwards; it may be issued by the manufacturer or by you as a seller established in the Union, and it must name both the manufacturer of the finished article and you as the importer, identify the article, carry a date and confirm compliance with the directive and Regulation (EC) No 1935/2004.
- Hold the supporting documentation, the analysis results, test conditions and the name and address of the testing laboratory, and make it available to the national competent authorities on request; the directive places this duty on the importer into the Union as well as on the manufacturer.
- Put your name or trade name and address on the article, its packaging or a label as the seller responsible for placing on the market established within the Union, ensure the for food contact indication and any instructions are present, and keep traceability records of your suppliers and customers.
- Put your name or trade name and address on the article, its packaging or a label as the seller established in the Union responsible for placing it on the market.
- Check that the for food contact indication and any special instructions for use are on the article, its packaging or a label.
- Keep systems and procedures that identify your suppliers and your business customers, and make that information available to the competent authorities on demand.
- In Denmark, if you consider or have reason to believe that ceramics you imported do not meet the food safety requirements and are no longer under your control, withdraw them from the market, notify Fødevarestyrelsen immediately and, where they have reached consumers, inform the consumers effectively and if necessary recall the articles.
- In Denmark, also check drinking vessels against the mouth-rim limit and apply the same limits and test to enamelled articles and glassware, and make the ceramics declaration and background documentation available in the form the Danish order prescribes, including the option of publishing the declaration on your website if the next links in the chain are informed.
- In Denmark, also check drinking vessels against the mouth-rim limit, and apply the same limits and test to enamelled articles and glassware.
- In Denmark, make the ceramics declaration and background documentation available in the form the Danish order prescribes; the declaration may be published on your website if the next links in the chain are informed.

### Distributor, wholesaler or retailer

- Sell only ceramic articles that are accompanied by the written declaration of compliance; the directive requires it at all marketing stages up to and including the retail stage for articles not yet in contact with food.
- At the retail stage, display the labelling information on the article, its packaging, a label or a clearly visible notice nearby, and do not sell articles whose for food contact indication and instructions are not given in a language purchasers easily understand.
- Keep systems and procedures that identify the businesses from which and to which the articles were supplied, and make that information available to the competent authorities on demand.
- In Denmark, do not market food contact materials that fail the general requirements, and as the responsible business withdraw non-compliant ceramics you have distributed, notify Fødevarestyrelsen and inform consumers where the articles have reached them.

### Business operator (any stage of manufacture, processing or distribution)

- Ensure that the ceramic articles under your control do not, under normal or foreseeable conditions of use, transfer their constituents to food in quantities that could endanger human health, bring about an unacceptable change in the composition of the food or deteriorate its taste, smell or appearance, and that their labelling, advertising and presentation do not mislead consumers.
- Operate an effective and documented quality assurance system proportionate to the size of the business, a quality control system that detects and corrects failures, and documentation on specifications, processing and control results available to the authorities.
- Operate an effective and documented quality assurance system proportionate to the size of the business, and a quality control system that detects and corrects failures.
- Keep documentation on specifications, processing and quality control results, and make it available to the competent authorities on request.
- Have documentation available that demonstrates compliance with the specific measure and hand it to the competent authorities on demand; a food business that fills or uses ceramic articles must in Denmark use only compliant materials and only for their intended purpose.
- Where a specific measure applies, have documentation available that demonstrates compliance with it, and hand it to the competent authorities on demand.
- Cooperate with the official controls that Member States carry out under the Union rules on official food and feed controls, now Regulation (EU) 2017/625, with the EU and national reference laboratories for food contact materials supporting the analytical work.

## Requirements

Each duty above as an identified requirement (29); ids are permanent and shared with the compliance engine.

### evidence

- `cer-mfr-keep-lead-cadmium` (Manufacturer of the finished ceramic article, product, before-market) — Keep the lead and cadmium released by each article within the limit for its category: 0,8 mg/dm² lead and 0,07 mg/dm² cadmium for category 1 (non-fillable or up to 25 mm deep), 4,0 mg/l and 0,3 mg/l for category 2 (other fillable articles), 1,5 mg/l and 0,1 mg/l for category 3 (cooking ware, packaging and storage vessels above three litres). [Art. 2(1) and Art. 2(4)]
- `cer-mfr-issue-written-declaration` (Manufacturer of the finished ceramic article, product, before-market) — Issue the written declaration of compliance for articles not yet in contact with food, so that it accompanies them at every marketing stage up to and including retail, stating your identity and address and those of the importer into the Union, the identity of the article, the date, and the confirmation that the article meets the relevant requirements of the directive and of Regulation (EC) No 1935/2004; make it easy to match to the goods and renew it when substantial changes in production alter the lead or cadmium migration. [Art. 2a(1) and Annex III]
- `cer-mfr-keep-appropriate-documentation` (Manufacturer of the finished ceramic article, product, before-market) — Keep appropriate documentation demonstrating compliance with the migration limits, containing the results of the analysis carried out, the test conditions and the name and address of the laboratory that performed the testing, and make it available to the national competent authorities on request. [Art. 2a(2)]
- `cer-imp-provide-danish-declaration-form` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — In Denmark, make the ceramics declaration and background documentation available in the form the Danish order prescribes; the declaration may be published on your website if the next links in the chain are informed. [§ 15(1) and (2) and bilag 5, point 4]
- `cer-op-ensure-ceramic-articles` (Business operator (any stage of manufacture, processing or distribution), product, before-market) — Ensure that the ceramic articles under your control do not, under normal or foreseeable conditions of use, transfer their constituents to food in quantities that could endanger human health, bring about an unacceptable change in the composition of the food or deteriorate its taste, smell or appearance, and that their labelling, advertising and presentation do not mislead consumers. [Art. 3]
- `cer-op-provide-compliance-documentation` (Business operator (any stage of manufacture, processing or distribution), product, before-market) — Where a specific measure applies, have documentation available that demonstrates compliance with it, and hand it to the competent authorities on demand. [Art. 16(1)]

### data

- `cer-dist-retail-stage-display` (Distributor, wholesaler or retailer, product-market, at-listing) — At the retail stage, display the labelling information on the article, its packaging, a label or a clearly visible notice nearby, and do not sell articles whose for food contact indication and instructions are not given in a language purchasers easily understand. [Art. 15(4) and Art. 15(7)]

### mark

- `cer-mfr-label-food-contact-use` (Manufacturer of the finished ceramic article, product, before-market) — Label articles not yet in contact with food with the words for food contact, a specific indication of use or the Annex II symbol, unless the article is clearly intended for food contact, and with any special instructions for safe and appropriate use. [Art. 15(1), points (a) and (b), and Art. 15(2)]
- `cer-mfr-mark-name-address` (Manufacturer of the finished ceramic article, product, before-market) — Put your name or trade name and address or registered office on the article, its packaging, a label or the accompanying documents. [Art. 15(1), point (c)]
- `cer-mfr-label-traceability` (Manufacturer of the finished ceramic article, product, before-market) — Label or otherwise identify the articles so that they can be traced. [Art. 15(1), point (d), and Art. 17(2)]
- `cer-imp-mark-name-address` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — Put your name or trade name and address on the article, its packaging or a label as the seller established in the Union responsible for placing it on the market. [Art. 15(1), point (c)]

### procedure

- `cer-mfr-determine-migration-annex` (Manufacturer of the finished ceramic article, product, before-market) — Determine migration with the Annex I test: 4 % (v/v) acetic acid freshly prepared, 22 ± 2 °C for 24 ± 0,5 hours, fillable articles filled to within 1 mm of the overflow point (6 mm along a flat or sloping rim), non-fillable articles immersed after protecting the non-contact surface, the sample covered and kept in total darkness when cadmium is determined, and lidded vessels tested as vessel and lid separately. [Art. 2(2), Art. 2(3) and Annex I, points 1 to 4]
- `cer-mfr-use-instrumental-method` (Manufacturer of the finished ceramic article, product, before-market) — Use an instrumental method of analysis that meets the Annex II performance criteria: detection limits of at most 0,1 mg/l lead and 0,01 mg/l cadmium, quantification limits of at most 0,2 and 0,02 mg/l, recovery of 80 to 120 %, freedom from matrix and spectral interference, a blank for each series, and samples washed in household detergent at about 40 °C and not handled on the test surface afterwards. [Annex II, points 2, 4 and 5 (M1)]
- `cer-mfr-rely-tolerance-directive` (Manufacturer of the finished ceramic article, product, before-market) — Rely on the tolerance only as the directive allows: an article exceeding a limit by no more than 50 % still passes if at least three other articles of the same shape, dimensions, decoration and glaze are tested and their average does not exceed the limit, with none of them exceeding it by more than 50 %. [Art. 2(5)]

### submission

- `cer-imp-consider-have-reason` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, on-event) — In Denmark, if you consider or have reason to believe that ceramics you imported do not meet the food safety requirements and are no longer under your control, withdraw them from the market, notify Fødevarestyrelsen immediately and, where they have reached consumers, inform the consumers effectively and if necessary recall the articles. [§ 7]
- `cer-dist-market-food-contact` (Distributor, wholesaler or retailer, product, on-event) — In Denmark, do not market food contact materials that fail the general requirements, and as the responsible business withdraw non-compliant ceramics you have distributed, notify Fødevarestyrelsen and inform consumers where the articles have reached them. [§ 6(1) and § 7]

### verification

- `cer-imp-import-ceramic-articles` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — Import only ceramic articles that meet the category limits: since 20 May 2007 Member States must prohibit the importation into the Union of ceramic articles that do not comply with the directive as amended by Directive 2005/31/EC. [Art. 2(1), point (b); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01984L0500-20050520 · Art. 2(4)]
- `cer-imp-make-sure-written` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — Make sure a written declaration of compliance accompanies the articles from your first sale onwards; it may be issued by the manufacturer or by you as a seller established in the Union, and it must name both the manufacturer of the finished article and you as the importer, identify the article, carry a date and confirm compliance with the directive and Regulation (EC) No 1935/2004. [Art. 2a(1) and Annex III]
- `cer-imp-check-food-contact-labelling` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — Check that the for food contact indication and any special instructions for use are on the article, its packaging or a label. [Art. 15(1), points (a) and (b)]
- `cer-imp-check-mouth-rim-limits` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, before-market) — In Denmark, also check drinking vessels against the mouth-rim limit, and apply the same limits and test to enamelled articles and glassware. [§ 14 and bilag 4]
- `cer-dist-sell-ceramic-articles` (Distributor, wholesaler or retailer, product, before-market) — Sell only ceramic articles that are accompanied by the written declaration of compliance; the directive requires it at all marketing stages up to and including the retail stage for articles not yet in contact with food. [Art. 2a(1)]

### standing

- `cer-mfr-apply-good-manufacturing-practice` (Manufacturer of the finished ceramic article, company, ongoing) — Manufacture under good manufacturing practice with a documented quality assurance system and a quality control system, so that the articles do not transfer constituents to food in quantities that endanger health, change the food unacceptably or spoil its taste or smell. [Art. 3(1); https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R2023 · Art. 4, Art. 5 and Art. 6]
- `cer-mfr-keep-gmp-documentation` (Manufacturer of the finished ceramic article, company, ongoing) — Keep documentation on specifications, formulae, processing and quality control results and make it available to the competent authorities on request. [Art. 7]
- `cer-mfr-keep-traceability-systems` (Manufacturer of the finished ceramic article, company, ongoing) — Keep systems and procedures that identify the businesses you supplied and the businesses that supplied you, and make that information available to the competent authorities on demand. [Art. 17(2)]
- `cer-imp-hold-supporting-documentation` (Importer into the Union, or seller established in the Union responsible for placing on the market, product, ongoing) — Hold the supporting documentation, the analysis results, test conditions and the name and address of the testing laboratory, and make it available to the national competent authorities on request; the directive places this duty on the importer into the Union as well as on the manufacturer. [Art. 2a(2)]
- `cer-imp-keep-traceability-systems` (Importer into the Union, or seller established in the Union responsible for placing on the market, company, ongoing) — Keep systems and procedures that identify your suppliers and your business customers, and make that information available to the competent authorities on demand. [Art. 17(2)]
- `cer-dist-keep-systems-procedures` (Distributor, wholesaler or retailer, company, ongoing) — Keep systems and procedures that identify the businesses from which and to which the articles were supplied, and make that information available to the competent authorities on demand. [Art. 17(2)]
- `cer-op-apply-good-manufacturing-practice` (Business operator (any stage of manufacture, processing or distribution), company, ongoing) — Operate an effective and documented quality assurance system proportionate to the size of the business, and a quality control system that detects and corrects failures. [Art. 5 and Art. 6]
- `cer-op-keep-gmp-documentation` (Business operator (any stage of manufacture, processing or distribution), company, ongoing) — Keep documentation on specifications, processing and quality control results, and make it available to the competent authorities on request. [Art. 7]

## Penalties

The directive contains no penalty article of its own: Member States had to amend their national laws so that trade in compliant ceramic articles was permitted from 17 October 1987 and the placing on the market of non-compliant articles was prohibited from 17 October 1989, and they may prohibit the manufacture of non-compliant articles. Sanctions come from the framework: Member States lay down the rules on sanctions for infringements of Regulation (EC) No 1935/2004, which must be effective, proportionate and dissuasive, enforce the rules through official controls, and may temporarily suspend or restrict the application of the EU limits on their territory where they have detailed grounds for concluding that an article endangers human health although it complies. In Denmark, executive order nr. 681 of 25 May 2020 prohibits the marketing of food contact materials that fail the general requirements, obliges the responsible business, producer or importer to withdraw non-compliant materials, notify Fødevarestyrelsen and inform or recall from consumers, and punishes with a fine infringements of the lead and cadmium limits and test rules for ceramic and enamelled articles and glassware, of the declaration and documentation duty, of Articles 3, 4(1) and (3) to (6), 11(5), 15 and 17 of the framework regulation and of Articles 4 to 7 of the good manufacturing practice regulation; the penalty rises to imprisonment of up to two years where the infringement was intentional or grossly negligent and harmed or endangered health or sought an economic gain, and companies can be held criminally liable.

## Checklist

1. Confirm each article is ceramic under Article 1(3) (inorganic mixture, shaped and fixed by firing, possibly glazed, enamelled or decorated) and is intended for food contact; treat decorative pieces, glass and enamelled metal separately and check the Danish rules for the latter two.
2. Classify every article into category 1, 2 or 3 from its shape, internal depth (25 mm) and capacity (three litres), and note lidded vessels and drinking vessels for the lid rule and, in Denmark, the rim limit (Article 2(3) and 2(4); bilag 4).
3. Have the food contact surface tested under Annex I conditions, 4 % acetic acid for 24 hours at 22 °C, by a laboratory whose instrumental method meets the Annex II detection, quantification and recovery criteria, and keep the report with the test conditions and the laboratory's name and address (Article 2a(2)).
4. Compare the results with the category limits, applying the 50 % tolerance only with three further articles of the same shape, dimensions, decoration and glaze (Article 2(5)); pay particular attention to coloured glazes and decorations, which Fødevarestyrelsen recommends making without lead and cadmium.
5. Draw up the written declaration of compliance with the four Annex III elements, manufacturer and importer identity and address, article identity, date and the confirmation of compliance with the directive and Regulation (EC) No 1935/2004, and make sure it travels with the goods up to and including retail (Article 2a(1)).
6. Set a trigger for renewing the declaration and retesting when a glaze, decoration, firing process or supplier changes in a way that could alter lead or cadmium migration (Annex III, last paragraph).
7. Apply the framework duties: good manufacturing practice with documented quality assurance and control (Regulation (EC) No 2023/2006), labelling with the for food contact indication where needed and the responsible seller's name and address (Article 15), and traceability records of suppliers and customers (Article 17).
8. In Denmark, register the withdrawal and notification procedure towards Fødevarestyrelsen (§ 7 of order nr. 681 of 25 May 2020) and decide whether the declaration will accompany the goods or be published on your website with the chain informed (§ 15(2)).
9. Follow the Danish draft order notified as TRIS 2025/0387/DK, which would lower the lead and cadmium limits to microgram levels from 1 July 2026, and the Commission's work on revised EU limits for lead, cadmium and other metals from ceramic and vitreous food contact materials, so that new products are designed to the coming limits.

## Questions

### What are the lead and cadmium limits under the Ceramics Directive?

Three categories. Category 1, articles which cannot be filled and fillable articles whose internal depth from the lowest point to the plane through the upper rim does not exceed 25 mm: 0,8 mg/dm² lead and 0,07 mg/dm² cadmium. Category 2, all other articles which can be filled: 4,0 mg/l lead and 0,3 mg/l cadmium. Category 3, cooking ware (with no capacity threshold) and packaging and storage vessels with a capacity of more than three litres: 1,5 mg/l lead and 0,1 mg/l cadmium. For a vessel with a ceramic lid the vessel's limit applies to the sum of the two extraction levels. Denmark applies the same numbers under order nr. 681 of 25 May 2020 and adds a category I rim limit for drinking vessels.

### Which articles does the directive cover, and which are outside it?

It covers ceramic articles which, in their finished state, are intended to come into contact with foodstuffs or are already in contact with foodstuffs for that purpose. Ceramic means manufactured from a mixture of inorganic materials with a generally high argillaceous or silicate content, possibly with small quantities of organic materials, shaped and permanently fixed by firing, glazed, enamelled or decorated or not. Decorative ceramics not meant for food are outside it, and so are glass and enamelled metal, which are separate material groups under the framework regulation without an EU specific measure; articles supplied as antiques are outside the framework regulation altogether.

### How is lead and cadmium migration from ceramics tested?

The article is washed in a household detergent solution at about 40 °C, rinsed and dried, then brought into contact with a freshly prepared 4 % (v/v) acetic acid solution at 22 ± 2 °C for 24 ± 0,5 hours. Fillable articles are filled to no more than 1 mm from the overflow point, or 6 mm measured along a flat or slightly sloping rim; non-fillable articles are immersed after the non-contact surface has been protected. The sample is covered, in usual laboratory lighting when only lead is determined and in total darkness when cadmium is determined. Lead and cadmium in the solution are then measured by an instrumental method meeting the Annex II criteria: detection limits of 0,1 mg/l lead and 0,01 mg/l cadmium, quantification limits of 0,2 and 0,02 mg/l and recovery of 80 to 120 %. For category 1 the result is related to the area of the free liquid surface, for categories 2 and 3 to the volume.

### Do I need a declaration of compliance for ceramic tableware, and what must it contain?

Yes, since Directive 2005/31/EC. Ceramic articles not yet in contact with food must be accompanied at the marketing stages up to and including retail by a written declaration under Article 16 of Regulation (EC) No 1935/2004, issued by the manufacturer or by a seller established in the Union. It must give the identity and address of the company that manufactures the finished article and of the importer into the Union, the identity of the article, the date, and the confirmation that the article meets the relevant requirements of the directive and of the framework regulation; it must allow easy identification of the goods and be renewed when substantial changes in production alter the lead or cadmium migration. Member States had to permit compliant articles from 20 May 2006 and prohibit manufacture and import of non-compliant ones from 20 May 2007.

### Who is responsible when ceramics are imported from outside the EU?

The importer into the Union. The directive requires the manufacturer or the importer to make the documentation proving compliance with the limits, with the analysis results, the test conditions and the name and address of the testing laboratory, available to the national competent authorities on request, and the declaration of compliance must name the importer alongside the manufacturer; as a seller established in the Union the importer may issue the declaration itself. Under the framework regulation the importer's name and address must accompany the article as the seller responsible for placing on the market, and in Denmark the importer must withdraw non-compliant ceramics, notify Fødevarestyrelsen and inform consumers.

### Are the Danish rules for ceramics different from the EU directive?

Denmark implements the directive through executive order nr. 681 of 25 May 2020, in force since 1 July 2020. The lead and cadmium limits in its bilag 4 are the same numbers as the directive's, but the order applies them to enamelled articles and glassware as well as ceramics and adds a category I limit for the mouth rim of drinking vessels, tested on a 2 cm band along the upper edge; mugs must meet both the rim limit and the category II limit. The declaration of compliance for ceramics must accompany the goods up to and including retail, or may be published on the producer's or importer's website if the next links in the chain are informed, and infringements are fined, with up to two years' imprisonment in aggravated cases. A draft replacement order with much lower limits was notified to the Commission as TRIS 2025/0387/DK in July 2025; as at 17 September 2026 Retsinformation still lists order nr. 681 as the order in force.

### Is the EU going to lower the lead and cadmium limits for ceramics?

The Commission says on its revision page that exposure to lead and cadmium may be of concern, that those metals are sometimes released in significant amounts from ceramic and vitreous food contact materials, and that it has initiated action to lower the migration limits for lead and cadmium and to introduce limits for aluminium, arsenic, barium, cobalt, chromium and nickel, with transition and derogation options for artisanal producers. No amending act has been adopted: the consolidated text of the directive is still that of 20 May 2005, and the Commission describes itself as working towards revised legislation after a roadmap of 18 December 2020 and a public consultation from 5 October 2022 to 11 January 2023. Denmark has meanwhile notified a draft national order with lower limits: it bases the ceramics limits on the safeguard clause in Article 18 of the framework regulation and the glass and enamel limits on the national-measures clause in Article 6.

### What happens if an article exceeds a limit only slightly?

Article 2(5) gives a tolerance: where an article exceeds the limit by no more than 50 %, it is still recognised as compliant if at least three other articles with the same shape, dimensions, decoration and glaze are tested under Annexes I and II, the average lead or cadmium extracted from them does not exceed the limit, and none of them exceeds it by more than 50 %. Denmark carries the same rule in § 14(2) of order nr. 681 of 25 May 2020. An article that fails beyond that must not be placed on the market, and in Denmark must be withdrawn with notification to Fødevarestyrelsen.

## What changed

- 2026-09-11 (guidance): **Guide rebuilt from the consolidated text and the Danish order** — The body was rewritten from the consolidated text of 20 May 2005, Directive 2005/31/EC, Regulation (EC) No 1935/2004 and executive order nr. 681 of 25 May 2020. The old text gave no figures; the limits, test conditions, declaration content and dates are now quoted from the acts. Two corrections: the transposition dates run from the notification of 17 October 1984 (trade in compliant articles permitted from 17 October 1987, non-compliant articles banned from 17 October 1989), and the current Danish limits are the same numbers as the directive's, extended to enamel and glass with a rim limit, while the lower Danish limits exist only as a notified draft.
- 2025-07-17 (guidance): **Denmark notifies a draft order with lower lead and cadmium limits (TRIS 2025/0387/DK)** — The draft would repeal order nr. 681 of 25 May 2020 on 1 January 2026 and, from 1 July 2026, allow ceramic and enamelled articles and glassware on the Danish market only within new limits expressed in micrograms per dm² or litre, with articles lawfully marketed before that date sold until stocks are exhausted. Denmark bases the ceramics limits on the safeguard clause of Article 18 of Regulation (EC) No 1935/2004 and the glass and enamel limits on Article 6; the Commission and Latvia commented, Spain issued a detailed opinion and the standstill was extended to 19 January 2026. As at 17 September 2026 Retsinformation still lists order nr. 681 as in force.
- 2020-07-01 (guidance): **Danish executive order nr. 681 of 25 May 2020 in force** — The order implements Directive 84/500/EEC as amended by Directive 2005/31/EC, replaces order nr. 1248 of 30 October 2018, applies the directive's lead and cadmium limits to ceramic and enamelled articles and glassware with a mouth-rim limit for drinking vessels, requires the ceramics declaration of compliance up to and including retail, and penalises infringements with fines and up to two years' imprisonment.
- 2008-08-01 (applies): **Good manufacturing practice regulation applies** — Regulation (EC) No 2023/2006 applies to all sectors and to all stages of manufacture, processing and distribution of the material groups in Annex I to the framework regulation, up to but excluding the production of starting substances, ceramics included: documented quality assurance and quality control systems and records available to the authorities.
- 2007-05-20 (applies): **Manufacture and import of ceramics without the 2005 requirements prohibited** — From this date Member States prohibit the manufacture and importation into the Community of ceramic articles that do not comply with the directive as amended by Directive 2005/31/EC.
- 2006-05-20 (applies): **Declaration of compliance and new analytical criteria apply** — Deadline for transposing Directive 2005/31/EC; from this date Member States permit trade in and use of ceramic articles complying with the amended directive, with the written declaration of compliance under Article 2a and Annex III and an analytical method meeting the Annex II performance criteria.
- 2005-05-20 (amendment): **Commission Directive 2005/31/EC in force** — The amending directive of 29 April 2005, published in OJ L 110 on 30 April 2005, inserted Article 2a on the written declaration of compliance and the supporting documentation, replaced Annex II with performance criteria for the method of analysis and added Annex III with the content of the declaration.
- 2004-12-03 (applies): **Framework Regulation (EC) No 1935/2004 in force** — The framework regulation entered into force on the twentieth day after publication in OJ L 338 of 13 November 2004, repealed Directive 89/109/EEC (which had repealed Directive 76/893/EEC, the basis cited in Article 1(1) of the ceramics directive) and lists ceramics in Annex I as a group for which specific measures are adopted; its general requirements, labelling, declaration, traceability, control and sanction articles apply to ceramic articles alongside the directive.
- 1989-10-17 (applies): **Non-compliant ceramic articles banned from the market** — Five years after notification, Member States must prohibit the placing on the market of ceramic articles that do not comply with the directive; they may also prohibit or continue to prohibit their manufacture.
- 1987-10-17 (applies): **Trade in compliant ceramic articles must be permitted** — Three years after notification, Member States must have amended their laws so that trade in ceramic articles complying with the directive is permitted; the same deadline applied to the Council's decision on mouth-contact limitations and the Commission's re-examination of the limits, neither of which appears in the consolidated text.
- 1984-10-17 (in-force): **Council Directive 84/500/EEC notified to the Member States** — Adopted on 15 October 1984 and published in OJ L 277 on 20 October 1984, the directive took effect on notification to the Member States on 17 October 1984, harmonising the lead and cadmium limits and the test and analysis methods for ceramic articles intended to come into contact with foodstuffs.

## CER in plain terms

The Ceramics Directive, formally Council Directive 84/500/EEC, is the EU's specific measure for one material and two hazards: lead and cadmium migrating from ceramic articles into food. It concerns the possible migration of lead and cadmium from ceramic articles which, in their finished state, are intended to come into contact with foodstuffs, or which are in contact with foodstuffs and are intended for that purpose (Art. 1(2)). Rather than a general safety principle, it gives measurable limits per category of article, a single migration test in 4 % acetic acid, and performance criteria for the analysis (Art. 2 and Annexes I and II). Since Commission Directive 2005/31/EC it also requires a written declaration of compliance and supporting test documentation for the authorities (Art. 2a and Annex III).

As a directive it works through national law. It was notified to the Member States on 17 October 1984; three years later trade in compliant articles had to be permitted and five years later, from 17 October 1989, the placing on the market of non-compliant articles had to be prohibited (Art. 5). The 2005 amendment had to be transposed by 20 May 2006, with manufacture and import of non-compliant articles prohibited from 20 May 2007 (Directive 2005/31/EC, Art. 2).

> **Official text**
> Read the directive on EUR-Lex: [Council Directive 84/500/EEC (CELEX 31984L0500)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31984L0500), or the [consolidated text of 20 May 2005](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01984L0500-20050520) that includes the declaration of compliance and the updated analytical criteria of Directive 2005/31/EC.

## Scope

Ceramic articles are articles manufactured from a mixture of inorganic materials with a generally high argillaceous or silicate content, to which small quantities of organic materials may have been added; they are first shaped and the shape is permanently fixed by firing, and they may be glazed, enamelled and/or decorated (Art. 1(3)). Stoneware, earthenware, porcelain and bone china plates, mugs, bowls, jugs, casseroles and storage jars are the typical cases. Glass and enamelled metal are not ceramic articles: they are separate material groups in Annex I to Regulation (EC) No 1935/2004 without an EU specific measure, so national rules under Article 6 of that regulation govern them (Regulation (EC) No 1935/2004, Art. 6 and Annex I). Decorative ceramics not intended for food are outside the directive, and the declaration of compliance was introduced precisely to distinguish food contact ceramics from decorative articles (Directive 2005/31/EC, recital 3). Materials and articles supplied as antiques are outside the framework regulation altogether (Regulation (EC) No 1935/2004, Art. 1(3)(a)).

Article 1(1) still describes the directive as a specific directive under Article 3 of Directive 76/893/EEC. Directive 89/109/EEC repealed that directive and provided that references to it are to be construed as references to Directive 89/109/EEC (Art. 10); Regulation (EC) No 1935/2004 then repealed Directive 89/109/EEC and provided that references to the repealed directives are to be construed as references to the regulation (Art. 26). The reference in Article 1(1) is therefore read as a reference to Regulation (EC) No 1935/2004, and Directive 2005/31/EC accordingly calls the ceramics directive a specific measure within the meaning of Article 5 of that regulation (recital 1). The practical consequence is that the framework's general requirements, labelling, declaration, traceability, controls and sanctions apply to ceramic articles on top of the lead and cadmium limits, and that ceramics manufacturers must work under the good manufacturing practice rules of Regulation (EC) No 2023/2006, which apply since 1 August 2008 (Art. 8).

The duties fall on the manufacturer of the finished article, on the seller established within the Union that may issue the declaration, and on the importer into the Union, which must hold the test documentation (Art. 2a and Annex III, point 1); distributors and retailers must see that the declaration accompanies the goods, since it is required at all marketing stages up to and including the retail stage (Art. 2a(1)).

## What you must do

### The limits

The quantities of lead and cadmium transferred from ceramic articles shall not exceed the limits laid down in Article 2(4), which sorts articles into three categories by shape and capacity. Category 1 covers articles which cannot be filled and articles which can be filled but whose internal depth, measured from the lowest point to the horizontal plane passing through the upper rim, does not exceed 25 mm: 0,8 mg/dm² lead and 0,07 mg/dm² cadmium. Category 2 covers all other articles which can be filled: 4,0 mg/l lead and 0,3 mg/l cadmium. Category 3 covers cooking ware and packaging and storage vessels having a capacity of more than three litres: 1,5 mg/l lead and 0,1 mg/l cadmium (Art. 2(1) and 2(4)).

Where a ceramic article consists of a vessel fitted with a ceramic lid, the limit that may not be exceeded is the one that applies to the vessel alone; the vessel and the inner surface of the lid are tested separately under the same conditions, and the sum of the two extraction levels is related to the surface area or the volume of the vessel alone (Art. 2(3)). An article that exceeds a limit by no more than 50 % is nevertheless recognised as compliant if at least three other articles with the same shape, dimensions, decoration and glaze are tested and the average does not exceed the limit, with none of them exceeding it by more than 50 % (Art. 2(5)).

Article 4(1)(a) required the Council to determine, within three years of notification, limitations for those areas of ceramic articles with which the mouth is intended to come into contact, and Article 4(2) required the Commission to re-examine the limits with a view to reducing them. Neither a rim limit nor reduced limits appear in the consolidated text of 20 May 2005; the rim question has been answered nationally in Denmark (see Enforcement and penalties).

### The migration test

Migration is determined by the test in Annex I using a method of analysis meeting Annex II (Art. 2(2)). The simulant is 4 % (v/v) acetic acid in a freshly prepared aqueous solution, and the test runs at 22 ± 2 °C for 24 ± 0,5 hours (Annex I, points 1 and 2.1). When lead is determined the sample is covered by an appropriate means of protection and exposed to the usual lighting conditions of a laboratory; when cadmium, or lead and cadmium, are determined the sample is covered so that the surface tested is kept in total darkness (Annex I, point 2.2). Fillable articles are filled to a level no more than 1 mm from the overflow point, or no more than 6 mm measured along a flat or slightly sloping rim; articles that cannot be filled have the non-contact surface covered with a protective layer resistant to the acid and are then immersed so that the food contact surface is completely covered (Annex I, point 3). The surface area of a category 1 article is the area of the meniscus formed by the free liquid surface when filled as prescribed (Annex I, point 4).

Annex II, as replaced by Directive 2005/31/EC, no longer prescribes a single technique: any instrumental method may be used that meets its performance criteria, namely detection limits of at most 0,1 mg/l for lead and 0,01 mg/l for cadmium, quantification limits of at most 0,2 mg/l and 0,02 mg/l, recovery of added lead and cadmium within 80 to 120 %, and freedom from matrix and spectral interference (Annex II, point 4). The sample must be clean and free from grease, washed in a household liquid detergent solution at about 40 °C, rinsed in tap water and then distilled water, drained and dried, and not handled on the test surface afterwards; a blank is run on the reagent for each series of determinations (Annex II, point 5).

### Declaration of compliance and documentation

At the marketing stages up to and including the retail stage, ceramic articles which are not yet in contact with foodstuffs must be accompanied by a written declaration in accordance with Article 16 of Regulation (EC) No 1935/2004, issued by the manufacturer or by a seller established within the Community (Art. 2a(1)). Annex III lists its content: the identity and address of the company which manufactures the finished ceramic article and of the importer who imports it into the Community; the identity of the ceramic article; the date of the declaration; and the confirmation that the article meets the relevant requirements of the directive and of Regulation (EC) No 1935/2004. The declaration must permit easy identification of the goods for which it is issued and must be renewed when substantial changes in production bring about changes in the migration of lead and cadmium (Annex III).

Behind the declaration sits the evidence. Appropriate documentation demonstrating that the articles comply with the migration limits must be made available by the manufacturer or the importer into the Community to the national competent authorities on request, and it must contain the results of the analysis carried out, the test conditions and the name and address of the laboratory that performed the testing (Art. 2a(2)).

### Framework duties

Because the directive is a specific measure under Regulation (EC) No 1935/2004, every business operator in the chain must also ensure that ceramic articles are manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities that could endanger human health, bring about an unacceptable change in the composition of the food or deteriorate its organoleptic characteristics, and that their labelling, advertising and presentation do not mislead consumers (Art. 3). Articles not yet in contact with food must carry the words for food contact, a specific indication of use or the Annex II symbol unless they are clearly intended for food contact, any special instructions for safe use, the name or trade name and address of the manufacturer, processor or seller responsible for placing on the market established within the Community, and the identification that ensures traceability (Art. 15). Retail trade is prohibited if the use information is not given in a language easily understood by purchasers (Art. 15(4)). Business operators must have systems that identify the businesses from which and to which articles were supplied (Art. 17(2)), and manufacturers must run documented quality assurance and quality control systems with records available to the authorities (Regulation (EC) No 2023/2006, Art. 4 to Art. 7).

### Obligations by role

Manufacturers keep migration within the category limits, test under Annex I with an Annex II-conforming method, issue the declaration of compliance and hold the test documentation (Art. 2, Art. 2a and Annex III). Importers make sure the declaration names them and accompanies the goods, hold the same documentation for the authorities and label the articles with their name and address as the seller responsible for placing on the market (Art. 2a and Annex III; Regulation (EC) No 1935/2004, Art. 15(1)(c)). Distributors and retailers sell only ceramics accompanied by the declaration, display the labelling information at retail and keep traceability records (Art. 2a(1); Regulation (EC) No 1935/2004, Art. 15(7) and Art. 17(2)).

### What is changing

The Commission states on its revision page that current exposure to lead and cadmium may be of concern, that those metals are sometimes released in significant amounts from both ceramic and vitreous food contact materials, and that it has initiated action to lower the migration limits for lead and cadmium and to introduce limits for aluminium, arsenic, barium, cobalt, chromium and nickel from ceramic and vitreous food contact materials, with tailored transition plans, supply chain controls and conditional derogations discussed for artisanal and traditional producers. No amending act has been adopted; the consolidated text remains that of 20 May 2005.

Denmark has moved first. On 17 July 2025 the Commission received TRIS notification 2025/0387/DK of a draft order that would repeal order nr. 681 of 25 May 2020 on 1 January 2026 and, from 1 July 2026, allow ceramic and enamelled articles and glassware on the Danish market only within new limits expressed in micrograms per dm² or per litre, with articles lawfully marketed before that date sold until stocks are exhausted (draft, § 10 and § 16). Denmark told the Commission that the ceramics limits are a safeguard measure under Article 18 of Regulation (EC) No 1935/2004 and the glass and enamel limits national measures under Article 6; the Commission and Latvia commented, Spain issued a detailed opinion and the standstill was extended to 19 January 2026. As at 17 September 2026, Retsinformation still lists order nr. 681 of 25 May 2020 as the order in force, so the limits below remain the applicable Danish law.

## Enforcement and penalties

The directive has no penalty article of its own. Member States had to amend their national laws so that trade in compliant articles was permitted from 17 October 1987 and the placing on the market of non-compliant articles was prohibited from 17 October 1989, and they may prohibit the manufacture of non-compliant articles (Art. 5). Enforcement and sanctions come from the framework: Member States carry out official controls under the Union rules on official food and feed controls (Regulation (EC) No 1935/2004, Art. 24; Article 24(3) still cites Regulation (EC) No 882/2004, which Regulation (EU) 2017/625 repealed with effect from 14 December 2019, so the reference is read as a reference to Regulation (EU) 2017/625 in accordance with its Article 146(2) and the correlation tables in its Annex V), lay down effective, proportionate and dissuasive sanctions (Art. 25) and may temporarily suspend or restrict the application of the EU limits on their territory where they have detailed grounds for concluding that an article endangers human health although it complies (Art. 18).

In Denmark, Fødevarestyrelsen (the Danish Veterinary and Food Administration) administers the rules. Executive order nr. 681 of 25 May 2020 on food contact materials was issued by Fødevarestyrelsen under the Danish food act (sections 25, 25 a, 49(1) and 60(3)) and delegated powers, and has been in force since 1 July 2020 (§ 25); § 7 makes Fødevarestyrelsen the authority to be notified when a business withdraws non-compliant materials. The order implements the directive as amended (footnote 1). Its § 14 and bilag 4 apply the directive's limits, 0,8 mg/dm² lead and 0,07 mg/dm² cadmium for category I, 4,0 mg/l and 0,3 mg/l for category II and 1,5 mg/l and 0,1 mg/l for category III, to ceramic and enamelled articles and glassware alike, and add a category I limit for the mouth rim of drinking vessels, tested on a 2 cm band along the upper edge inside and outside; mugs and similar drinking vessels must meet both the rim limit and the category II limit (bilag 4, note 2, and bilag 6, part A, points 2.3 and 4). The 50 % tolerance with three further articles is carried over in § 14(2). The ceramics declaration of compliance must accompany the goods up to and including retail, or may be published on the producer's or importer's website if the next links in the chain are informed (§ 15 and bilag 5, point 4). A business, producer or importer that has reason to believe its food contact materials do not meet the safety requirements must withdraw them, notify Fødevarestyrelsen immediately and inform or recall from consumers (§ 7). Infringements of §§ 6 to 12 and 14 to 15, of Articles 3, 4(1) and (3) to (6), 11(5), 15 and 17 of the framework regulation and of Articles 4 to 7 of the good manufacturing practice regulation are punished with a fine, rising to imprisonment of up to two years where the infringement was intentional or grossly negligent and harmed or endangered health or sought an economic gain; companies can be held criminally liable (§ 17, § 18 and § 19). Fødevarestyrelsen's ceramics page recommends that producers use glazes without lead and cadmium, and its 2023 control project tested 47 ceramic, porcelain and enamelled articles from Danish producers, importers and wholesalers without finding an exceedance of the limits.

## How Conphora helps

Conphora monitors the Ceramics Directive, the framework regulation and the Danish order and maps your ceramic articles against the category limits, flagging missing migration tests, wrong category classification, gaps in the declaration of compliance and the test documentation, and articles that would fail the lower limits in the notified Danish draft before they become enforcement problems. The platform keeps the declarations, laboratory reports and traceability records in one place and alerts you when the EU limits or the Danish order change.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Council Directive 84/500/EEC on ceramic articles intended to come into contact with foodstuffs, consolidated text of 20 May 2005 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01984L0500-20050520)
- [Council Directive 84/500/EEC as published in OJ L 277, 20 October 1984 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31984L0500)
- [Document information, dates and relationships for CELEX 31984L0500 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31984L0500)
- [Commission Directive 2005/31/EC amending Directive 84/500/EEC as regards a declaration of compliance and performance criteria of the analytical method (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32005L0031)
- [Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food, consolidated text of 27 March 2021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R1935-20210327)
- [Commission Regulation (EC) No 2023/2006 on good manufacturing practice for food contact materials (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R2023)
- [Council Directive 89/109/EEC on materials and articles intended to come into contact with foodstuffs, repealing Directive 76/893/EEC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31989L0109)
- [Regulation (EU) 2017/625 on official controls, repealing Regulation (EC) No 882/2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R0625)
- [Food contact materials: legislation (European Commission, DG SANTE)](https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/legislation_en)
- [Revision of EU rules on food contact materials (European Commission, DG SANTE)](https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/revision-eu-rules_en)
- [TRIS notification 2025/0387/DK, draft Danish order on food contact materials (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084)
- [TRIS 2025/0387/DK, Denmark's response of 7 November 2025 (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084/message/113713/EN)
- [TRIS 2025/0387/DK, notified draft text in Danish (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084/text/D/DA)
- [Bekendtgørelse nr. 681 af 25. maj 2020 om fødevarekontaktmaterialer og om straffebestemmelser for overtrædelse af relaterede EU-retsakter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2020/681)
- [Keramik, materialetyper (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/foedevaresikkerhed/emballage-og-udstyr/materialetyper/keramik)
- [Køkkengrej og kemi i maden, herunder keramik, arvegods og loppefund (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/alt-om-mad/kemi-i-maden/koekkengrej)
- [Fødevarekontaktmaterialer, lovstof (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/lovstof/foedevarekontaktmaterialer-lovstof)
- [Dokumentation for fødevarekontaktmaterialer (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/foedevaresikkerhed/emballage-og-udstyr/dokumentation)
- [Slutrapport: Metaller fra FKM af keramik, control project 2023 (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/Media/638653560024818056/Slutrapport%20-%20Keramik%202023.pdf)

*This guide is for general information and is not legal advice.*

## Sources

- [Council Directive 84/500/EEC on ceramic articles intended to come into contact with foodstuffs, consolidated text of 20 May 2005 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01984L0500-20050520)
- [Council Directive 84/500/EEC as published in OJ L 277, 20 October 1984 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31984L0500)
- [Document information, dates and relationships for CELEX 31984L0500 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:31984L0500)
- [Commission Directive 2005/31/EC amending Directive 84/500/EEC as regards a declaration of compliance and performance criteria of the analytical method (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32005L0031)
- [Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food, consolidated text of 27 March 2021 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R1935-20210327)
- [Commission Regulation (EC) No 2023/2006 on good manufacturing practice for food contact materials (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R2023)
- [Council Directive 89/109/EEC on materials and articles intended to come into contact with foodstuffs, repealing Directive 76/893/EEC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31989L0109)
- [Regulation (EU) 2017/625 on official controls, repealing Regulation (EC) No 882/2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R0625)
- [Food contact materials: legislation (European Commission, DG SANTE)](https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/legislation_en)
- [Revision of EU rules on food contact materials, including lead and cadmium from ceramic and vitreous materials (European Commission, DG SANTE)](https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/revision-eu-rules_en)
- [TRIS notification 2025/0387/DK, draft Danish order on food contact materials with lower lead and cadmium limits (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084)
- [TRIS 2025/0387/DK, Denmark's response of 7 November 2025 on the legal basis of the ceramics, glass and enamel limits (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084/message/113713/EN)
- [TRIS 2025/0387/DK, notified draft text in Danish (European Commission)](https://technical-regulation-information-system.ec.europa.eu/en/notification/27084/text/D/DA)
- [Bekendtgørelse nr. 681 af 25. maj 2020 om fødevarekontaktmaterialer og om straffebestemmelser for overtrædelse af relaterede EU-retsakter (Retsinformation)](https://www.retsinformation.dk/eli/lta/2020/681)
- [Keramik, materialetyper (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/foedevaresikkerhed/emballage-og-udstyr/materialetyper/keramik)
- [Køkkengrej og kemi i maden, herunder keramik, arvegods og loppefund (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/alt-om-mad/kemi-i-maden/koekkengrej)
- [Fødevarekontaktmaterialer, lovstof (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/lovstof/foedevarekontaktmaterialer-lovstof)
- [Dokumentation for fødevarekontaktmaterialer (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/kost-og-foedevarer/foedevaresikkerhed/emballage-og-udstyr/dokumentation)
- [Slutrapport: Metaller fra FKM af keramik, control project 2023 (Fødevarestyrelsen)](https://foedevarestyrelsen.dk/Media/638653560024818056/Slutrapport%20-%20Keramik%202023.pdf)

_Reviewed 2026-09-24 by Conphora compliance team_