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Selling kitchenware and food contact articles in the EU

In the EU, kitchenware, tableware and containers that touch food must meet Regulation (EC) No 1935/2004 and be made under good manufacturing practice. Plastics follow Regulation (EU) No 10/2011, with a Union list, migration limits and a declaration of compliance; ceramics have lead and cadmium limits; materials without EU measures may face national rules.

Updated · Each section links to the official source it comes from

Framework
Regulation (EC) No 1935/2004
Manufacturing
Good manufacturing practice, Regulation (EC) No 2023/2006
Plastics
Regulation (EU) No 10/2011; overall migration limit 60 mg/kg food or 10 mg/dm²
Ceramics
Directive 84/500/EEC limits on lead and cadmium
Label
'For food contact', a specific use, or the symbol
Imports
Melamine and polyamide kitchenware from China and Hong Kong checked at entry

Before a product goes on sale

The questions to answer, in the order they usually come up.

  1. 1Is the article made under good manufacturing practice, and traceable? Read more
  2. 2For plastics, are the substances on the Union list, and does migration testing support the declaration of compliance? Read more
  3. 3For ceramics and other materials, which EU or national rules apply? Read more
  4. 4Does the label or listing carry the food contact indication, instructions, name and address? Read more
  5. 5Is it melamine or polyamide kitchenware from China or Hong Kong? Read more

The rules, by area

What each area covers, the texts that set it, and what the official pages say.

The framework Regulation and good manufacturing practice

The general rules for each material and article that touches food.

  • Food contact materials include food packaging and containers, machinery to process food, and kitchenware and tableware; they must comply with Regulation (EC) No 1935/2004 when placed on the European market.
  • Under normal or foreseeable conditions of use, they may not transfer their constituents to food in quantities that could endanger human health, bring an unacceptable change in the food's composition, or spoil its taste and odour (Article 3).
  • Their labelling, advertising and presentation may not mislead consumers.
  • Regulation (EC) No 2023/2006 on good manufacturing practice requires premises fit for purpose, staff aware of critical production stages, documented quality assurance and quality control, and suitable starting materials.
  • Traceability is required at each stage: businesses have systems to identify the businesses from which and to which materials and articles are supplied, and make that information available to authorities on demand (Article 17).

How we help: Compliant Always keeps your manufacturing records, supplier declarations and traceability data with each article and lot, dated. Ask about this

Plastic food contact materials

The most detailed of the specific EU measures.

  • Regulation (EU) No 10/2011 sets rules on the composition of plastic food contact materials and a Union list of substances permitted in their manufacture, with restrictions on their use.
  • Specific migration limits are set for listed substances on the basis of EFSA's assessment, and the overall migration of all substances may not exceed 60 mg/kg of food or 10 mg/dm² of contact surface.
  • Migration is usually tested with food simulants, such as 3% acetic acid for acidic foods, under standardised time and temperature conditions.
  • A declaration of compliance passes down the manufacturing chain, up to but not including retail, backed by supporting documentation that is provided to authorities on request.
  • Regulation (EU) 2024/3190 restricts bisphenol A and other hazardous bisphenols in certain food contact materials, with transitional provisions; it was corrected by Regulation (EU) 2026/250.
  • Recycled plastic materials follow Regulation (EU) 2022/1616.

How we help: Compliant Always reads your declarations of compliance and migration reports against the Union list, and shows which are missing or out of date. Ask about this

Ceramics and other materials

Specific EU measures beyond plastics, and national rules.

  • Specific EU measures cover ceramics, regenerated cellulose film, plastics including recycled plastic, and active and intelligent materials.
  • Directive 84/500/EEC limits lead and cadmium released from ceramics: 0.8 mg/dm² lead and 0.07 mg/dm² cadmium for flat articles and those no deeper than 25 mm; 4.0 mg/l and 0.3 mg/l for other articles that can be filled; and 1.5 mg/l and 0.1 mg/l for cooking ware and for packaging and storage vessels over three litres.
  • Where a specific EU measure requires it, articles are accompanied by a written declaration that they comply with the rules, with documentation available to authorities on demand (Article 16).
  • Where there are no specific EU measures, member states may keep or adopt national provisions, which may differ from one member state to another.

How we help: Compliant Always records which material rules apply to each article, national ones included, and keeps the test reports behind each. Ask about this

Labelling

What a food contact article carries when it is sold.

  • Articles not yet in contact with food carry the words 'for food contact', a specific indication of use such as coffee machine, wine bottle or soup spoon, or the symbol in Annex II; this is not needed for articles clearly intended to touch food (Article 15).
  • They also carry any special instructions for safe and appropriate use, the name and address of the manufacturer, processor or seller established in the EU, and labelling or identification for traceability.
  • Retail sale is prohibited if the food contact indication and instructions are not in a language easily understood by purchasers, and a member state may require its own official languages.
  • At retail, the information goes on the article or its packaging, on a label, or on a clearly visible notice next to the article.

How we help: Compliant Always reads each label and listing against Article 15 and shows which particulars are missing. Ask about this

Melamine and polyamide kitchenware from China and Hong Kong

Import checks for two plastics.

  • Since 1 July 2011, melamine or polyamide kitchenware originating in or consigned from China or Hong Kong must meet the import rules of Regulation (EU) No 284/2011.
  • Consignments are notified to the competent authorities at the point of entry at least two working days before arrival.
  • Each consignment has a declaration and a laboratory report on primary aromatic amines for polyamide, or formaldehyde for melamine.

How we help: Compliant Always keeps each consignment's declaration and laboratory report with the shipment, and shows what is missing before it leaves. Ask about this

Who answers for what

WhoWhat they answer forHow we help
ManufacturerGood manufacturing practice, compliance with the material rules, the declaration of compliance and its supporting documents.Declarations, migration reports and manufacturing records kept by article and lot.
ImporterArticles brought into the EU, including notification and documents for melamine and polyamide kitchenware from China and Hong Kong.Each consignment's documents read and dated before it ships.
Brand or sellerThe label, its instructions and the name and address on it.Labels and listings checked against Article 15.
Material supplierCompliance information on the materials and substances it supplies, passed down the chain.Supplier declarations collected once and shown to each customer that asks.

Member states

The Regulations apply directly, but materials without a specific EU measure may fall under national rules that differ between member states. Member states may also set label languages.

Questions businesses ask

Which EU law covers kitchenware and food contact materials?
Regulation (EC) No 1935/2004, with good manufacturing practice under Regulation (EC) No 2023/2006 and specific measures for plastics, ceramics, regenerated cellulose film and active and intelligent materials.
Do plastic kitchen products need a declaration of compliance?
Yes. Plastic food contact materials need a declaration of compliance through the supply chain, up to but not including retail, backed by supporting documentation provided to authorities on request.
What is the overall migration limit for plastics in the EU?
60 mg of all migrating substances per kg of food, or 10 mg per dm² of contact surface. Specific migration limits also apply to listed substances.
What are the lead and cadmium limits for ceramic tableware?
Under Directive 84/500/EEC: 0.8 and 0.07 mg/dm² for flat articles; 4.0 and 0.3 mg/l for other fillable articles; and 1.5 and 0.1 mg/l for cooking ware and vessels over three litres.
What must a kitchenware label show?
'For food contact', a specific use, or the symbol, unless clearly intended for food; special instructions for safe use where needed; the name and address of the business responsible in the EU; and traceability information.
Is bisphenol A banned in food contact materials?
Regulation (EU) 2024/3190 restricts bisphenol A and other hazardous bisphenols in certain food contact materials and articles, with transitional provisions.
Are there import checks on melamine kitchenware?
Yes, for melamine or polyamide kitchenware from China or Hong Kong: consignments are notified two working days before arrival, with a declaration and a laboratory report.
What if there are no EU rules for my material?
The framework Regulation still applies, and member states may keep or adopt national provisions for materials without specific EU measures. These may differ between member states.
Do I need to keep traceability records for kitchenware?
Yes. Businesses keep systems that identify who supplied them and whom they supplied, and make that information available to authorities on demand.
Which language must food contact information be in?
A language easily understood by purchasers. A member state may require one or more of its official languages for the labelling particulars.
How does Compliant Always help with selling in the EU?
Our team reads the rules for the markets you sell in. Compliant Always shows which apply to your product, keeps the documents behind each one ready, and watches the sources for changes. It shows what the requirements say and what your documents show; you decide.

Sources

Compliant Always is a product of Lettuce Labs LLC. It shows what requirements say and what your documents show. It is not legal advice, and you decide.

Tell us what you make, and we will show you the rules for it.

Name the product and the markets you sell in. We will come back to you with what applies in the EU and what your paperwork needs to show.

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