- Regulation (EU) 2023/988 — GPSR
- Regulation (EC) No 1935/2004 and Directive 84/500/EEC for ceramics in food contact
- Regulation (EC) No 1907/2006 — REACH
Who has to appoint one
Sellers outside the Union placing decorative homeware on the EU market. Ceramics and glassware raise a specific issue: if the article can plausibly be used for food, the food contact regime applies with lead and cadmium release limits, whatever the marketing says.
Thresholds and exemptions
None. Handmade and artisan pieces are in scope, and small production runs are the most frequent source of non-compliant glazes.
What must appear on the label
Manufacturer and responsible person details with an EU address, product identifier or batch number, and where the article is food contact, the glass-and-fork symbol or an equivalent indication together with any restriction such as 'not dishwasher safe' or 'not for hot liquids'. Where an article is decorative only, a clear indication that it is not intended for food.
Marketplace fields
Marketplaces check the responsible person block, and ceramics from certain origins face reinforced import controls with lead and cadmium testing at the border.
Documentation you must hold
Technical documentation and risk analysis. For food contact articles, the declaration of compliance and release test reports for lead and cadmium. REACH evidence for decorative coatings and any metal components.
Standards and testing
Lead and cadmium release testing under Directive 84/500/EEC for ceramic articles, and the equivalent for glassware where relevant. Thermal shock and mechanical strength testing for items intended to hold hot liquids. Stability testing for candle holders and tall vessels.
Language requirements
Use restrictions and warnings in the language of each member state of sale.
When it applies
Before the product is made available.
How long records are kept
Ten years for the documentation.
What happens if you do not comply
Border rejection under reinforced import controls, withdrawal, and Safety Gate alerts for lead and cadmium migration, which is one of the most common findings for imported ceramics.
Who enforces it
Food safety authorities for the contact aspects, market surveillance authorities for the rest, and border control posts.
Where the boundary lies
A decorative bowl that looks like a serving bowl will be treated as food contact material by an inspector, and the burden is on the seller to show it is not intended for food. Candle holders bring fire safety obligations; scented candles bring CLP classification and poison centre notification.
Questions we are asked
- Our ceramics are decorative only — do we still need migration testing?
- If the article is reasonably expected to be brought into contact with food, yes. Labelling it decorative does not settle the question if the shape says otherwise.
- Are glazes from outside the EU a problem?
- They are the main source of failures. Lead-based glazes remain in use in several producing countries and exceed EU release limits.
Who signs for you
EU representative Europe Services, SE — Na Čečeličce 425/4, Smíchov, 150 00 Praha 5, Czech Republic
UK representative REP27 LTD — Unit 82a James Carter Road, Mildenhall, Suffolk IP28 7DE, United Kingdom