Key takeaways
- Regulation 1935/2004 covers every food contact material, including ceramics, glass, metals, wood, coatings and plastics. Article 3 bans transfer of constituents that endanger health or change the food's composition, taste or smell.
- Goods sold empty must be marked “for food contact”, carry the glass-and-fork symbol or show an obvious use, plus the name and EU address of the responsible business (Article 15).
- Plastics (Regulation 10/2011) and ceramics (Directive 84/500/EEC) need a written declaration of compliance backed by test documentation.
- Germany's LFGB has no certificate or mark of its own. An “LFGB test report” is a lab report against EU and German food contact rules.
- Inspection checks symbols, labels, traceability and documents; migration and heavy metal results need an accredited lab.
What Regulation 1935/2004 requires
Regulation (EC) No 1935/2004 is the EU framework for all food contact materials and articles. Annex I lists the material groups that may be covered by specific measures, among them ceramics, glass, metals and alloys, wood, cork, plastics, rubbers, paper and board, textiles, and varnishes and coatings.
| Article | Requirement |
|---|---|
| Article 3, general requirements | Made under good manufacturing practice so that, in normal or foreseeable use, they do not transfer constituents to food in quantities that could endanger health, bring an unacceptable change in the food's composition or spoil its taste or smell. Labelling and presentation must not mislead. |
| Article 15, labelling | Items sold empty must carry “for food contact”, a specific use (such as “soup spoon”) or the glass-and-fork symbol in Annex II; any special instructions for safe use; and the name and address of the manufacturer, processor or seller established in the EU. Not needed for (a) where the item is obviously for food. The information must be conspicuous, legible and indelible. |
| Article 16, declaration of compliance | Where a specific EU measure applies, items must be accompanied by a written declaration of compliance, backed by documentation available to authorities on request. |
| Article 17, traceability | Traceability at all stages. Businesses must be able to identify who supplied them and whom they supplied, and goods must be identifiable by labelling or documents. Applies from 27 Oct 2006. |
Good manufacturing practice. Regulation (EC) No 2023/2006 applies from 1 August 2008 to all stages of manufacture, processing and distribution of food contact materials, except production of starting substances. The business must run a documented quality assurance system, a quality control system, and keep records of specifications, formulations and production that matter for compliance.
Specific EU rules for plastics and ceramics
| Material | Rule | Key requirements |
|---|---|---|
| Plastics, including plastic parts of mixed items | Regulation (EU) No 10/2011 | Only authorized substances (Union list); overall migration limit of 10 mg per dm² of food contact surface; specific migration limits per substance; written declaration of compliance (Article 15 and Annex IV) at stages other than retail |
| Ceramics | Directive 84/500/EEC, amended by Directive 2005/31/EC | Lead and cadmium migration limits by article category; written declaration of compliance up to and including retail; test results and lab name available on request |
| Bisphenol A | Regulation (EU) 2024/3190 | Bans BPA in varnishes, coatings, plastics, inks, adhesives and other food contact materials. Most items made with BPA could be first placed on the market only until 20 July 2026 |
| Metals, wood, glass, non-plastic coatings | No specific EU measure | Article 3 still applies; national rules and the Council of Europe resolution on metals and alloys are often used as reference |
Ceramics revision. The 1984 limits (lead 0.8 mg/dm² and cadmium 0.07 mg/dm² for flat ware) are still the EU rules. The Commission has worked on lower limits for years, but as of 14 October 2026 we found no adopted EU act replacing Directive 84/500/EEC. In 2026 the Netherlands, Luxembourg and Belgium set much lower national limits under a Benelux decision. See lead and cadmium in ceramics for the figures.
Germany's LFGB and buyer specifications
The LFGB (Lebensmittel- und Futtermittelgesetzbuch, the German Food and Feed Code) is Germany's national food and consumer goods law. For food contact items, it adopts the EU definition from Regulation 1935/2004. Section 30 bans making or selling consumer goods that can harm health through their chemical makeup. Section 31 bans placing on the market items that do not meet Article 3(1) of Regulation 1935/2004. It also lets the ministry set substance limits by ordinance.
Many German and other EU buyers write “LFGB compliant” or “LFGB test report required” into purchase orders. In practice this means a lab report showing the item meets EU rules and the German rules and recommendations the lab applies to that material. For metals, ceramics or wood, this can include heavy metal release and a sensory test for odour and taste transfer, linked to Article 3. There is no official LFGB certificate, mark or approval. A logo printed on a carton proves nothing on its own, so agree the exact test list with your buyer.
What this means for goods made in India
- Ceramic dinnerware and mugs from Khurja, Jaipur or Gujarat need a ceramic declaration of compliance and lead and cadmium test results from the EU importer's file. Decorated rims and bright colors are the usual risk points.
- Steel, brass, copper and aluminum kitchenware from Moradabad or Delhi NCR has no EU-specific measure. Buyers usually ask for metal release tests and a declaration under Article 3.
- Wooden boards, bowls and servers from Saharanpur or Jodhpur must not transfer oils, stains or lacquers. Any plastic-based coating falls under Regulation 10/2011.
- Bamboo, melamine and mixed items need a check of which parts are plastic. Plastic parts must use only substances on the Union list.
- Labels. The glass-and-fork symbol, any use instructions (for example “not dishwasher safe”) and the EU business address must be on the item, label or packaging before retail sale.
What inspection can check, and what needs a lab
| An inspector at the factory can check | Needs lab testing |
|---|---|
| Glass-and-fork symbol or “for food contact”, use instructions and EU business address on item, label or carton | Overall and specific migration from plastics and coatings (Regulation 10/2011) |
| Batch or lot codes that link goods to the declaration of compliance and test reports (Article 17) | Lead and cadmium release from ceramics (Directive 84/500/EEC) |
| Materials, glazes, linings and finishes match the tested sample | Metal release from steel, brass, copper or aluminum |
| The factory's records of raw materials and process controls, as a basic GMP check | Sensory (odour and taste) tests asked for in LFGB specs |
How Clear To Load checks this in India
On a home décor and handicrafts inspection in India, we check symbols, labels and lot codes on sampled units and cartons, compare materials with the tested sample and photograph the evidence. For migration or LFGB tests, we pull and seal samples for an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination, and check the report against the goods. We have no partner labs and take no lab commissions.
The report arrives within 24 hours of the inspection, after supervisor review, with a verdict of Cleared to load, Hold or Not cleared. To add food contact checks to an order, book an inspection.
Sources
- Regulation (EC) No 1935/2004 on food contact materials (EUR-Lex)
- Regulation (EC) No 2023/2006 on good manufacturing practice (EUR-Lex)
- Regulation (EU) No 10/2011 on plastic food contact materials (EUR-Lex)
- Directive 84/500/EEC on ceramic articles, consolidated (EUR-Lex)
- Regulation (EU) 2024/3190 on bisphenol A (EUR-Lex)
- LFGB §§ 30 and 31 (gesetze-im-internet.de)
- European Commission: Food contact materials legislation