Key takeaways
- FDA tests six units. Flatware is judged on the average; hollowware, cups, mugs and pitchers on any one unit.
- The strictest FDA lead levels are for cups, mugs and pitchers (0.5 µg/mL) and large hollowware (1.0 µg/mL).
- EU limits depend on category: flat or shallow ware in mg/dm², deeper ware in mg/L, with tighter limits for cooking ware and storage vessels over 3 litres.
- EU ceramics need a written declaration of compliance up to retail, backed by test results and the lab's name.
- Decorative pieces sold in the US that look usable for food must carry the “Not for food use” label and a permanent base marking.
- Leach tests are lab work. Inspection makes sure the shipped goods match the glaze, decoration and supplier that were tested.
US FDA action levels
FDA uses Compliance Policy Guides (CPGs) to decide when ceramic ware is adulterated. Ware above these levels can be detained at import or face legal action. Six units are tested with the methods FDA names: ASTM C738, AOAC 973.32 and 973.82, or FDA Laboratory Information Bulletins 4123 and 4126.
| Category | Basis | Lead (µg/mL) | Cadmium (µg/mL) |
|---|---|---|---|
| Flatware (internal depth 25 mm or less) | Average of 6 units | 3.0 | 0.5 |
| Small hollowware (under 1.1 L), other than cups and mugs | Any one of 6 units | 2.0 | 0.5 |
| Cups and mugs | Any one of 6 units | 0.5 | 0.5 (small hollowware) |
| Large hollowware (1.1 L or more), other than pitchers | Any one of 6 units | 1.0 | 0.25 |
| Pitchers | Any one of 6 units | 0.5 | 0.25 (large hollowware) |
Decorative ware. Under 21 CFR 109.16, ceramics that look suitable for food are presumed to be food ware unless they carry both a conspicuous stick-on label and a permanent statement molded or fired onto the base, such as “Not for Food Use. May Poison Food”, in letters at least 3.2 mm high (1.6 mm if space is short). A hole bored through the food surface is the alternative. FDA also advises against labeling ware with any extractable lead as “lead free”.
California. Lead and cadmium are on the Proposition 65 list. For ceramic tableware, the leach levels used to decide whether a warning is needed come from court-approved settlements, not an OEHHA regulation, and they are set separately from FDA's levels. US retailers often write them into purchase terms, so confirm the figures with your buyer.
EU limits under Directive 84/500/EEC
| Category | Lead | Cadmium |
|---|---|---|
| 1: Articles that cannot be filled, or can be filled with internal depth of 25 mm or less | 0.8 mg/dm² | 0.07 mg/dm² |
| 2: All other articles that can be filled | 4.0 mg/L | 0.3 mg/L |
| 3: Cooking ware; packaging and storage vessels over 3 litres | 1.5 mg/L | 0.1 mg/L |
If an article exceeds a limit by no more than 50%, it can still pass if at least three more articles of the same shape, size, decoration and glaze are tested, their average is within the limit and none exceeds it by more than 50%. A vessel with a ceramic lid is judged against the vessel's limit, with the vessel and the inside of the lid tested separately and added together.
Since Directive 2005/31/EC, ceramics not yet in contact with food must come with a written declaration of compliance at every stage up to and including retail. It is issued by the manufacturer or an EU seller. The manufacturer or EU importer must give authorities, on request, the test results, the test conditions and the lab's name and address. See also EU food contact rules and LFGB.
Revision status. As of 14 October 2026 we found no adopted EU act that replaces these limits. In 2026 the Netherlands (in force 29 May 2026), Luxembourg and Belgium adopted much lower national limits under Benelux decision M (2024) 5. Industry summaries of the Dutch rule give, for category 1, 6 µg/dm² lead and 4 µg/dm² cadmium; category 2, 30 µg/L lead and 20 µg/L cadmium; category 3, 10 µg/L lead and 7 µg/L cadmium. Check the national text before you rely on these figures.
How the leach test works
The EU method in Annex I of Directive 84/500/EEC fills the article with 4% (v/v) acetic acid to within 1 mm of the overflow point, or immerses articles that cannot be filled. The test runs for 24 hours at 22 ± 2 °C. When cadmium is measured, the sample is kept in total darkness; lead-only tests run under normal lab lighting. For flat articles, the result is related to the surface area of the liquid. The methods FDA cites use the same principle of a 24-hour acetic acid leach on the food surface.
The acid stands in for acidic foods such as vinegar, fruit juice and tomato sauce. Common causes of high results are lead-containing glazes or colors on the food surface and glazes that were not fired properly.
What this means for exporters in India
- Khurja (Uttar Pradesh). A long-standing pottery and ceramics cluster making glazed stoneware, mugs, planters and tableware. Mugs and pitchers face the strictest FDA levels, so glaze and decoration choices matter most there.
- Morbi (Gujarat). India's largest ceramics cluster, mostly tiles and sanitaryware. Units that also make tableware or mugs need the same leach testing as any other tableware maker.
- Jaipur blue pottery. Low-fired, glazed and hand-painted, and often sold as décor. If a bowl or plate could be used for food, it must either pass leach tests or, in the US, carry the 109.16 label and fired base marking.
- Mixed suppliers. Buying houses often consolidate ware from several small units. Each glaze, color and kiln is a separate risk, so tests should match the actual supplier and batch.
What inspection can check, and what needs a lab
| An inspector at the factory can check | Needs lab testing |
|---|---|
| Glaze color, decoration and decal placement match the tested sample, including on the rim and food surface | Lead and cadmium leach results to FDA or EU methods |
| Signs of underfiring: soft or chalky glaze, pinholes, crazing, unfused areas | Retesting after a change of glaze, decal supplier or kiln |
| US decorative ware carries the stick-on label and permanent base statement, or a bored hole | |
| Declarations of compliance, test reports and lot codes match the order, supplier and batch |
How Clear To Load checks this in India
On a home décor and handicrafts inspection in India, our inspector compares glazes and decorations with the tested sample, checks markings and labels, and reviews the declaration and test reports against the order. For leach tests, we draw random samples from finished stock, seal them and send them to an ISO/IEC 17025-accredited lab you choose or we suggest, through lab testing coordination.
The report arrives within 24 hours of the inspection with a verdict of Cleared to load, Hold or Not cleared. To add ceramics checks to an order, book an inspection.
Sources
- FDA CPG Sec. 545.450, Pottery (Ceramics) – Lead Contamination
- FDA CPG Sec. 545.400, Pottery (Ceramics) – Cadmium Contamination
- 21 CFR 109.16, Ornamental and decorative ceramicware (eCFR)
- FDA guidance: Safety of imported traditional pottery and use of the term “lead free”
- Directive 84/500/EEC, consolidated with Directive 2005/31/EC (EUR-Lex)
- Intertek: The Netherlands tightens requirements for food-contact ceramics (2026)