Food Contact Materials – The Revision is a continuously updated logbook (“work in progress”). It is prompted by the ongoing revision of the EU regulatory framework for food contact materials (FCMs) — and by an invitation to contribute my practical perspective as a ceramic maker in an interview. Before I say anything “off the cuff”, I’m organising my questions, research, and thoughts here — transparently, step by step.
Contents (working draft)
- Problem description
- Background / how we got here
- Problems in enforcement and in the Commission’s approach
- A change of perspective: what I would do if I were the authority (inspection logic & proposals)
- Sources & documents
1. Problem description
If you look at the current revision of the EU rules on food contact materials (FCMs), one thing stands out immediately — something that feels unusually “big” for ceramics: this is not about minor corrections, but about a recalibration of the logic by which safety will be described, demonstrated, and enforced in the future. A Commission scoping paper (05/08/2025) outlines core principles that are explicitly meant to apply across materials — not as a separate universe only for plastics, but as a framework for all FCMs.
For ceramic makers, the concrete pressure point is easy to name: the Commission is working on a significant tightening of requirements around the release of metals from ceramics — and, at the same time, on extending the scope to additional “vitreous” materials (in other words, glass-like materials). The direction is clear: ceramics are not being treated as a footnote in the revision, but as an area in which limit values, testing and evidence logic, and enforcement practice are being reorganised.
This is not only a “limit values” debate. The core issue runs deeper: it is about how food safety should be ensured in the future along the supply chain (information on composition, risk-based assessment, verifiable quality assurance) — and how much weight is placed on documented process and substance information versus measured results on the finished product. And if measured results on the finished product are meant to play a bigger role, the next practical question follows immediately: how extensive will testing be — and who will ultimately pay for it? These costs are not trivial. A CNC position statement puts this very starkly: a study conducted by the CNC reportedly found that analysing an entire production range is financially out of reach for many micro-workshops; the tests alone can amount to “up to several years of turnover”. (CNC = Collectif National des Céramistes, the French ceramic makers’ association.) Here is the link to the original in French, and here the English translation.
And the effect becomes even more severe as soon as the testing scope is expanded: the CNC explicitly notes that moving from 2 to 8 monitored substances/parameters further exacerbates the problem — up to scenarios where, in the worst case, the revenues earned over decades might barely suffice to pay for the first major round of analyses.
One important point (and it is quite clear in the underlying simulation) is that what is monetised is essentially laboratory fees only, based on a 2017 laboratory quotation (e.g., €213 net with a rim sample / €158 net without a rim sample). These figures do not capture the full burden. In practice, additional — often decisive — costs arise that are clearly visible in the scenario but not calculated as euro amounts: producing the test pieces (materials, labour time, energy/firings, rejects), opportunity costs (test pieces replace saleable ware), potential loss of pieces through destructive testing, as well as logistics and administrative workload (shipping, documentation, variant management).
On top of that, because the lab prices used are from 2017, it is plausible that real analysis prices today are significantly higher — depending on the laboratory and the parameter set, possibly even on the order of a doubling.
But even at the level of supply-chain thinking, a tension emerges for artisanal ceramics that I want to unpack in this logbook: ceramics are not a material where you can simply “calculate up” relevant properties from a list of raw ingredients. Firing creates a new material; what may later be released, if anything, is a property of the matrix, the firing process, and the surface. At the same time, any tightening in this area affects small workshops differently than industrial mass production — and the question is how to organise safety in a way that is both robust and practically workable.
The Commission is clearly caught between two imperatives: it must ensure food safety, but it cannot — and must not — risk driving small artisanal producers into ruin through a proof and testing regime that becomes effectively unworkable. My impression is that the Commission recognises this tension — and that the planned interview is intended precisely to calibrate the real-world consequences better.
My starting point is not “who is right”, but: what data and what collection logic actually underpin the problem description? In reviewing public sources, I noticed gaps and ambiguities in the way data are collected and presented; I have therefore sent a follow-up question to the FCM team.
Status: 6 March 2026
So far I have not received a reply; therefore I am publishing the current state of my research and the questions that follow from it as a basis for discussion. My entry point into this research was a sentence from an email I received from the European Commission on 26 January 2023 (DG SANTE — short for “Direction générale Santé”, i.e. the European Commission’s Directorate-General for Health and Food Safety). The message stated, in essence, that with regard to metal migration from ceramic and “vitreous” food contact materials, “the main concern” was lead and cobalt, “mainly from EU artisanal and cheaply manufactured imports”. I wanted to understand exactly where this concern comes from and how it was established.
The data base
My first step was to comb through the published data from FCM controls carried out so far, looking for ceramic-specific risk drivers. To my surprise, I could not find any data that gave me genuinely usable clues, because the relevant data fields were not designed around ceramic criteria — and I have the impression that descriptions/classifications are not applied consistently across Member States. Frequently mentioned categories were, for example, mugs/cups and tableware in general, and decorated ware appears to be overrepresented — but how are you supposed to infer from that where the actual risks lie, and what a truly targeted measure would even look like?
What would be needed instead are descriptive risk criteria that cannot currently be extracted reliably from the existing tests/notifications, because they are typically neither captured as structured data fields nor broken down publicly: material group or firing proxy (earthenware/low-fired vs. high-fired stoneware/porcelain), firing atmosphere and “kiln-formed” processes (oxidation/reduction; wood/salt/soda), decoration techniques (under-/in-/overglaze, decoration firing, transfer printing/decals), contact zone (rim/inside surface vs. outside), and glaze-matrix information (e.g. Seger formula/network structure) — in other words, what you would need to answer not only “it migrates”, but also “why does it migrate?”
I therefore asked the Commission the following:
Is there an aggregated risk picture behind that statement that distinguishes, for example, by origin (EU vs. non-EU or specific countries/regions), by product groups (mugs/cups/plates etc.), and — crucially for ceramics — by manufacturing and decoration characteristics (e.g. overglaze/enamel decoration, decals/transfers, decoration on food-contact surfaces such as rims)?
More specifically, I asked:
- Do DG SANTE/JRC (or Member State enforcement data) already contain a more structured/aggregated analysis for ceramic and vitreous FCMs that can support genuinely risk-based targeting — even if the raw data are not public?
- If so, is there any public summary you can point me to — or, if not public, could you at least confirm whether such variables (decoration type / food-contact zone / firing range as a proxy) are being considered in the analysis?
- If not, would you consider it a useful working hypothesis that ceramics may need additional, sector-specific data fields in order to make “Pillar A” (accountability/transparency/information exchange) genuinely workable and proportionate for SMEs in the ceramics sector?
The research base
Status: 7 March 2026
I wanted to understand the problem properly — not just that “metals in ceramics” are being discussed, but how large the problem actually is and what it hinges on in practice. In the Commission’s email of 26 January 2023, a logic becomes visible that is entirely plausible from an analytical point of view: what is measured are elements in the test eluate — regardless of whether they occur in the glaze as an oxide, as a network constituent, or in some other binding form. For ceramics, the translation work starts right there: in glaze chemistry there are not simply “good” and “bad” substances, but rather robust or vulnerable glaze matrices — and that depends on composition, firing conditions, atmosphere, microstructure, decoration and contact zone. For example, the mere presence of lead in a glaze does not automatically mean that lead can be released; there are indeed food-safe lead glazes. Release depends primarily on how firmly the lead is bound within the glaze’s chemical structure. Conversely, even a glaze that a manufacturer considers “safe” based on their own tests can become problematic in a workshop context—if, for instance, the firing regime differs from what the glaze producer assumed, or if glazes are combined in ways that affect the final matrix and surface behaviour. From this perspective, ceramics is an end-product chemistry problem: the decisive variable is the fired glaze matrix under the actual production conditions—not the upstream bill of substances.
This gap becomes particularly clear with aluminium/Al₂O₃. In ceramics, Al₂O₃ is traditionally regarded as a stabiliser of the glaze matrix — while aluminium as an element is at the same time being discussed as a possible migration signal. A phone call with glaze chemist and author Wolf Mattes sharpened this tension: he could hardly imagine aluminium being released from well-fired, stable glazes in relevant quantities, and in the same breath points to aluminium cookware, whose surface can be visibly attacked after years of use without that automatically being framed as a “scandal”. That is why my core question is not “a substance list: yes or no”, but: under which ceramic conditions is anything actually released — and where are the real hotspots? (Wolf Mattes was one of the most respected glaze specialists in German ceramics: a ceramic engineer, author, and long-time lecturer at the ceramic school in Höhr-Grenzhausen. He was known not only for his deep technical knowledge of glazes and ceramic surfaces, but also for his generosity in sharing that knowledge with others. For discussions around food contact materials, his voice matters because he brought together practical studio experience, glaze chemistry, and historical-technical understanding with unusual clarity)
The next step was obvious: if the topic is so present politically and regulatorily, there ought to be a ceramics-specific body of research that goes beyond broad categories — studies that do not merely report “ceramics”, but break ceramics down in a way that you can actually learn from: which material groups stand out (earthenware vs. stoneware/porcelain)? which decoration techniques drive the risk (underglaze, overglaze, transfer printing)? which contact zones are critical (rim/inside surface)? what role do firing conditions, temperature range and atmosphere play? That is what I looked for — in publicly available sources, in enforcement summaries, and in what is visible from consultations.
So far, my finding is sobering: I have not found any publicly accessible studies or datasets that answer these questions for ceramics in a way that a studio could translate into genuinely risk-based practice. Either the categories remain too broad (“decorated tableware”), or the relevant ceramic features do not appear as data fields at all — and where data do exist, the description practice between Member States seems so uneven that a consistent risk picture is hard to discern. This is not a final verdict; it is simply the current state of my research: I see a gap between the problem claim and a ceramics-appropriate evidence base.
That is why I framed my questions to the European Commission (DG SANTE) in a way that targets this gap: is there already a robust, aggregated risk picture behind the statements — and if so, how is it structured? And if not: what additional data fields would be needed to make ceramics assessable on a risk basis at all, rather than through broad categories and a “full testing” logic?
Quote (from my questions to the EU Commission / DG SANTE):
Could you confirm whether DG SANTE/JRC sees the same imbalance at EU level — namely an overweight of toxicology/element-based analytics (“element in eluate”) compared to ceramics-specific materials-science evidence? If yes: how did this imbalance develop in your view, and what concrete steps do you plan to take to close it (e.g., targeted ceramic research and typologies, more informative data fields in enforcement datasets, or guidance that makes results interpretable for ceramic producers)?
Finally, to what extent does the same evidence gap apply to the other candidate metals/metalloids currently under consideration for ceramic/vitreous FCMs (e.g., cobalt, nickel, chromium, barium, arsenic)? In other words: do you have ceramics-specific evidence/typologies for these as well (glaze/decor type, firing range proxies, food-contact zone), or is the evidence base largely “element in eluate” across the board?
I have sketched and linked what such a study could look like for Al₂O₃ here.
Conclusion
Unless and until the European Commission provides more robust findings, the conclusion from a ceramics perspective is sobering: at present, it is not even possible to formulate a precise problem description—let alone to interpret toxicological measurements on a risk basis in terms of ceramic causes (matrix, firing, decoration, contact zone). As long as this gap is not closed, it remains my working hypothesis for the next steps in this logbook: we are currently discussing “elements in the eluate” rather than ceramics—and the translation into a practice that can act in a targeted and proportionate way is missing. If this working hypothesis holds, I do not consider it productive to further tighten limit values or add additional substances to the directive before it is even clear where the real hotspots lie and how they can be reliably addressed using ceramics-appropriate criteria.
2. Looking back
How “Pb/Cd” turned into a systemic problem (and why ceramics end up caught in the middle)
When people talk about ceramics and food contact today, it often sounds like a new debate. In reality, the core problem is old: the legal logic does not automatically force a “test every glaze” approach—but enforcement can end up exactly there. And once that happens, producer responsibility turns into a barrier to market access.
2.1 Starting point: ceramics as a special case in the EU system
Ceramics have long been treated as a special area within EU food contact materials (FCM) law: not as a world of positive lists like plastics, but traditionally through limit values and test methods—historically focused above all on lead and cadmium—plus the general framework logic (“no release in quantities harmful to health”, demonstrate compliance, keep supporting documentation). In Germany, this is complemented by the obligation to provide a written declaration of compliance, including “supporting documents” that must be available on request. That sounds manageable. The devil, however, lies in the question of how this compliance is supposed to be “demonstrated” in enforcement—and whether, in practice, it collapses into a single standard method.
2.2 Craft production vs. serial logic: what the CNC position statement puts into words
The first EU ceramics-specific measure is old: the Ceramic Directive 84/500/EEC was adopted on 15 October 1984, published in the Official Journal on 20 October 1984, and notified to the Member States on 17 October 1984. That notification date is the key reference point, because the original implementation deadlines (“three and five years after notification”) are tied to it.
In the CNC submissions, this historical starting point is then framed very clearly as part of the problem: the practical architecture of the rules (and even more so the test protocols) is visibly written for industrial serial production—while the way micro-businesses actually work (“craft”, VSE/SME) is not taken into account. CNC does not present this as a vague feeling, but points to very concrete mechanisms: laboratory protocols assume batch logic (several identical pieces), may destroy samples, and proceed as if unique pieces and highly variable firing processes simply did not exist. CNC puts it quite bluntly: this industrial logic means that craft workshops end up structurally “falling out of the system”—not because they work unsafely, but because the evidence architecture is, in practice, impossible for them to fulfil.
CNC study on the financial burden created by testing requirements
2.3 Germany as an early “testing country” — my experience in 2016
In 2016, my own workshop was subject to an official sampling/control by the district of Mecklenburgische Seenplatte — as part of what, in my recollection, became an increasingly widespread system of routine sampling across Germany from around 2014 onwards. One point is crucial here and often gets lost in day-to-day discussions: such sampling was not automatically a “cost trap” for producers. Under the logic applied at the time, the costs of laboratory analyses were only to be borne by the producer if an actual violation was found.
All the more striking, then, is what happened in my case: the Schleswig-Holstein state laboratory clearly attempted to charge me for the analyses — not because a limit value had been exceeded, but via a formal route (an allegedly missing manufacturer indication). The district authority, however, rejected that. Even this detail shows how quickly the focus can shift: from a risk-based sampling approach towards a cost-and-obligation logic that has very real consequences for small workshops.
The second point is at least as important: back then, testing did not focus only on the substances for which the EU Ceramic Directive explicitly sets limit values (traditionally: lead and cadmium), but also included additional elements — in my case zinc, barium and cobalt. That raises questions that remain open to this day: why were these elements tested, on what data basis, and what is the underlying logic — especially when such additional screening costs money and at the same time creates the impression that the legal “target logic” (Pb/Cd) and the practical testing logic (multi-element screening) are drifting apart?
2.4 2018: enforcement practice tips over
By 2018 at the latest, what is framed as a general obligation to provide evidence had turned into a very concrete routine: a leaflet/guidance document issued by the district of Mecklenburgische Seenplatte states, in essence, that ceramics should be tested with each glaze intended for food contact, and that further testing should be added whenever glazes are changed. This is not an isolated case. This is the tipping point: “demonstrate compliance” becomes, in practice, “test per glaze”.
What is striking is this: so far I have not been able to identify any specific administrative instruction or any change in the underlying rules that would explain why this shift happened. The EU Ceramic Directive itself was not suddenly “tightened” at that time. The tipping point therefore seems to be less a new legal norm than an enforcement interpretation — in other words, a decision about which kind of evidence is deemed “sufficient”, and above all who is expected to bear the costs.
And this is where the issue becomes systemic: for workshops with a small number of stable glazes, this is annoying but manageable. For workshops with a large glaze diversity — especially where surfaces are formed in the kiln or vary within a firing process — such a requirement turns into a de facto exclusion from the market, and in the worst case into a de facto occupational ban.
2.5 In parallel: in Brussels, the “expansion logic” has long been underway
While this is already tangible in practice in Germany, preparatory work has been running at EU level for quite some time. In consultation materials and strategy papers, the idea appears early on that, alongside Pb/Cd, further metals should be brought more strongly into focus (e.g., aluminium, arsenic, barium, cobalt, chromium, nickel). At the same time — interestingly — it is acknowledged that this can be problematic for micro/small/medium enterprises, and possible “relief” directions are discussed, for instance through supply-chain information and quality control (“to reduce the need to test the final articles”).
This is exactly the crux for ceramics: supply-chain documentation misses the core of the problem. From a raw-material or component list you cannot infer whether — and if so what — is actually released from the fired glaze matrix. Ceramics is an end-product chemistry problem: what matters are firing regime, matrix, microstructure, decoration and contact zone — not the shopping list.
You can see this particularly clearly with aluminium/Al₂O₃ (see the section on the evidence base): Al₂O₃ is present in virtually all glazes and is often regarded in ceramics as a stabiliser. If such an “everywhere constituent” is suddenly discussed as a possible migration signal, it becomes obvious that you cannot meaningfully make this “manageable” through supply-chain paperwork. Without ceramics-specific typologies and data fields, a supply-chain logic is, at best, bureaucracy — and at worst, a justification for pushing the testing burden back onto the last producer in the chain.
DG SANTE website on FCM-Revision
2.6 2022/23: Consultation — CNC makes the cost and protocol problem tangible
During the 2022–2023 consultation period, the issue becomes concrete: CNC did not only submit a position paper, but also added a cost/impact simulation. It illustrates very plainly what it means for a small workshop when enforcement effectively thinks “colour by colour / glaze by glaze / model by model” — including the requirement to provide several identical pieces for each analysis. In the end, this mirrors what I have already seen in German enforcement logic: what is already practice in one place becomes visible elsewhere as the risk of being generalised EU-wide.
2.7 2025/26: Scoping Paper and interview invitation — “Level Playing Field” becomes official
In the Scoping Paper (August 2025), the meta-problem is stated quite openly: non-harmonised rules, non-harmonised enforcement, multiple testing regimes — this is not only bureaucratic, it distorts the internal market. And in early 2026 the Commission specifically invited SMEs to interviews, among other things to better understand “simplification” and improved information exchange.
This is the point where I pause: some of the structural problems are being recognised — but the direction of the solution will decide whether ceramics is finally addressed on a genuinely risk-based basis, or whether we end up with little more than a new justification for a system that, in practice, once again lands on “test every glaze”.
3. Problems in enforcement and in the overall approach
In the Scoping Paper, the Commission itself describes that the internal market for FCMs currently functions only to a limited extent: for many materials, harmonised EU rules are missing; national measures differ widely or are outdated — resulting in uneven levels of health protection, unnecessary burdens, and in some cases even “multiple testing regimes”.
At the same time, it is acknowledged that official controls in Member States often take place only to a limited extent and that resources, expertise and validated test methods are not sufficiently available everywhere. This creates a structural level-playing-field problem that becomes particularly visible in ceramics as soon as “evidence of compliance” is interpreted in practice as a de facto testing obligation per glaze. I wanted to understand this more precisely, and I asked follow-up questions:
To avoid misunderstandings: could you please clarify what DG SANTE means by the lack of a “level playing field” in this context? Specifically:
- Is the concern primarily about differences between Member States in enforcement intensity and interpretation, or about differences between imports and EU production, or both?
- Since when has this been recognised as a material problem in the FCM revision process?
- What concrete measures (if any) have been taken so far to address it — and if none, what were the main constraints (competence boundaries, resources, data gaps, etc.)?
The second part of my questions follows directly from this. “Pillar A” of the revision aims to increase accountability, transparency and information exchange along the supply chain. That sounds like order. But from the perspective of a micro-business, fairness is not decided on paper, but in enforcement reality: will new obligations ultimately be implemented most strictly in those places where enforcement is already very strict — while import controls inevitably remain selective? If so, then, ironically, “harmonisation” would end up amplifying the very distortions it is supposed to reduce.
That is why I explicitly linked this to a further question to the Commission: whether DG SANTE/JRC is taking this risk — “more obligations = more imbalance” — into account, and what safeguards are envisaged to prevent the revision from unintentionally strengthening competition distortions:
From an SME perspective, the practical risk is that additional documentation and testing expectations will be implemented most strictly in Member States with already strong enforcement, while imports are inevitably controlled in a more selective, risk-based manner.
Could you confirm whether this concern is shared within DG SANTE/JRC — and, if so, what design principles you are considering to prevent the revision from unintentionally strengthening competition distortions (e.g., proportionate, risk-based requirements; harmonised enforcement guidance; better alignment of import vs internal market controls)?
With my next question, I was aiming at the central mismatch: in packaging logic, supply-chain documentation is often a workable proxy. For ceramic glazes, however, the relevant property only emerges in the firing. That is why I wanted to know whether the Commission is truly taking this difference into account when designing “Pillar A”.
Could you please clarify whether DG SANTE considers this ceramics-specific mismatch when shaping obligations under “Pillar A” (i.e., the limits of upstream documentation for predicting release), and whether any ceramics-specific guidance or typologies are envisaged to avoid disproportionate burdens with limited safety benefit?
For the further course of this logbook, this is my pivot point: I am taking the Scoping Paper as a starting point, but I will organise the next steps around whether the revision ultimately becomes workable in practice — in a way that increases safety without “regulating” market access through an evidence architecture. If DG SANTE sets clear guardrails here (risk-based, consistent, import-proof), a robust system can emerge. If not, the very thing I have already experienced in German enforcement risks repeating itself: obligations that do not concentrate where the risk is highest, but where enforcement is easiest for authorities to apply.
3.1 Level playing field within the EU (enforcement visibility / implementation differences)
To make the “Level playing field” issue more concrete, I would like to share one clear observation from practice. In a glaze seminar in Hungary (2023), all Hungarian ceramic colleagues I spoke with indicated that they had never experienced sampling or requests for a declaration of compliance, and all stated that the ceramics-specific EU rules were not known to them. I mention this as a factual experience, not as a blame assignment — but it is striking, because it occurred roughly nine years after (to my recollection) systematic controls had already become established in Germany.
This impression of very uneven implementation is also reflected in the public reporting “visibility” of official controls: across EU alert and notification systems, reporting activity is concentrated in a small number of Member States (Germany, the Netherlands and Belgium are consistently among the most active). From a ceramics-technical perspective, one might intuitively expect higher risk and therefore higher detection rates in regions with a strong tradition of low-fired earthenware and highly decorated wares, where chemical durability can be more challenging and colourful decoration may involve a wider palette of metals. Yet the highest reporting activity appears to come from countries that are historically associated with higher-fired tableware, which should, on material grounds alone, be less likely to show problematic release. Thats why I wanted to know:
Could you confirm whether DG SANTE’ internal picture matches this pattern — i.e., high “visibility” reporting in a few Member States that are not necessarily the most obvious candidates from a ceramics-technical risk perspective? If not, what explains the difference? If yes, what concrete measures has the Commission taken (or plans to take) to reduce this structural unfairness and to ensure that enforcement and compliance expectations are more consistent across Member States?
From an SME perspective, the key risk is that certain enforcement interpretations would create a de facto occupational ban. That would almost inevitably trigger legal challenges based on proportionality and unequal treatment, and it could undermine the credibility and enforceability of the future framework.
Is DG SANTE explicitly taking this risk into account — and if so, what design choices are being made to keep the system legally robust (proportionate, predictable and consistently enforceable across Member States and for imports)?
3.1 Level Playing Field between EU producers and non-EU imports (especially China)
When I started researching this topic, it quickly became clear to me that this is where the by far biggest problems lie. Three sober findings emerged:
First: the scale is not a side note.
When it comes to ceramic tableware and kitchenware, we are talking about true mass goods. For 2023, EU import volumes (WITS/Comtrade) are around 198,684,000 kg for HS 691200 (ceramic table/kitchenware, not porcelain) and an additional 182,709,000 kg for HS 691110 (porcelain). Together, that is roughly 381,393,000 kg — i.e. about 381,000 tonnes of import volume per year, for these two product groups alone — and China dominates this flow with roughly 84% of the import volume. This is not “a bit of competition”; it is a central part of the market.
Second: this import reality also shows up in the notification systems.
In parallel with import volumes, China appears repeatedly in EU warning and notification systems for food contact materials as a relevant country of origin — both in scientific analyses of RASFF data (serious alerts and border rejections) and in annual reports from the networks. For me, the key point is not whether a specific percentage is stated somewhere, but that a pattern becomes visible: import volume and reporting “visibility” are not living in completely separate worlds.
Third: import controls are not automatically harmonised — and they are not even wired the same way everywhere.
This point is less spectacular, but crucial: EU audit reports show that food contact materials are treated differently from other product groups at certain points in the border-control workflow (for example, exemptions from TRACES/CHED requirements). This does not automatically mean “no controls”. But it makes visible that the architecture of import controls is not organised identically everywhere — and that without harmonised data capture, it is not even possible to quantify the real testing density at the border in a serious way.
My interim conclusion: this is more than “uneven enforcement” — in its effects, it is a major economic-policy scandal.
If import flows can only be controlled selectively, while within the internal market evidence logics emerge that effectively push SMEs toward “test every glaze / every variant” — and in the extreme can amount to a de facto occupational ban — then this is not a level playing field, but a structural imbalance. The EU places the heaviest burden on its own small producers, even though the reality of import controls cannot possibly apply the same standard. This distorts competition — and it not only undermines acceptance of the system, it ultimately does not serve food safety either: paperwork- and full-testing logics tie up resources where enforcement is easiest, instead of concentrating them, on a risk basis, where the real hotspots lie.
I therefore put the following questions to the Commission:
- Is DG SANTE already aware of such disproportionalities under the current system (i.e., not only as a future risk)?
- Since when has this “level playing field” problem been recognised as a material issue specifically in relation to ceramic/“vitreous” FCMs and metal migration?
- What concrete steps have been taken in the past to mitigate these disproportionalities — and what concrete steps are planned going forward to prevent them from worsening under the revision?
And I formulated an urgent recommendation:
One expectation I would like to state explicitly is this: before any further tightening of obligations is introduced under the revision, the existing disproportionalities and unfair outcomes in implementation should be addressed. Otherwise, the revision risks amplifying distortions that already exist today.
From my perspective, the risk of a de facto occupational ban is not only a hypothetical future scenario. Based on my experience with enforcement practice in Germany, I am concerned that stricter, more literal interpretations may become more common in the coming years (among other things through routine staff turnover and standardisation within administrations). If compliance expectations are interpreted in a way that effectively requires extensive laboratory evidence per glaze/per variant, this can very quickly become existential for craft workshops.
A concrete and, in my view, readily implementable step would therefore be to establish an EU-wide principle for a genuinely level playing field in enforcement intensity: internal-market controls should, like border controls, be conducted on a risk-based, selective sampling basis, rather than evolving into de facto “test every glaze / every variant” expectations for SMEs. This would not weaken safety; it would shift effort from blanket paperwork toward targeted control where risk is highest, and it would prevent the most compliant SMEs in strict-enforcement Member States from being driven out of lawful production while imports remain necessarily subject to selective controls.
To be continued soon…
7. Sources & documents (as of 26 Feb 2026)
Public sources (linked)
- European Commission: Revision of the EU rules on food contact materials (FCMs)
- Position statement by the Collectif National des Céramistes (CNC) as part of the revision of the Food Contact Materials Regulation, consultation from October 2022 to January 2023
Sources for „The Database“
1) Email from DG SANTE FCM Team (SANTE-FCM-REVISION@ec.europa.eu), 26 Jan 2023
– Internal email I received; includes the phrasing “main concern lies with … lead and cobalt … EU artisanal and cheaply
manufactured imports”.
2) European Commission – Revision of EU rules on food contact materials (FCMs)
– General revision page and the section referring to ceramics/vitreous FCMs and metals:
https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/revision-eu-rules_en
3) RASFF Annual Report 2020 (European Commission)
– For public-facing categorisation of FCM notifications (incl. “Ceramics, decorated glass” and related hazards):
4) Systematic analysis of serious RASFF notifications on food contact materials (FCM) 2012–2019
– Used as evidence that origin-country patterns (e.g., China) can be prominent in FCM alerts/border rejections:
https://pmc.ncbi.nlm.nih.gov/articles/PMC8065728/5) BfR (German Federal Institute for Risk Assessment) – Opinion on ceramic crockery (lead/cadmium release)
– Used for the link between release, glaze quality, and firing temperature; also mentions cobalt as a relevant topic in context:
Klicke, um auf ceramic-crockery-bfr-recommends-lower-release-of-lead-and-cadmium.pdf zuzugreifen
(HTML landing page)
6) JRC publication (example of ceramics/vitreous FCM work on migration testing / method development)
https://publications.jrc.ec.europa.eu/repository/handle/JRC140298
(direct PDF used earlier)
Klicke, um auf JRC140298_01.pdf zuzugreifen
Working documents (not publicly linked here)
– European Commission Scoping Paper of 05/08/2025 (working draft / discussion paper; not provided as a PDF here)
(Note: I link only to publicly accessible documents. If internal working documents are relevant, I mention them at most as context, without publishing them.)