Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials
26 submissions from 26 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 39 submissions on this file. Shown here: the 26 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
18 submissions from industry — companies and their trade associations — against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 18 industry submissions for every one from civil society.
Industry 18Civil society 1Public authorities, academia, other 7
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 26 Jun 2019 — it ran from 29 May 2019.
Policy area
Health & food (DG SANTE)
Where it stands
In planning
Adoption expected
30 Jun 2023
How it got here
Impact assess incep26 Jun 2019
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Public consultation, Reg draft, Reg.
The Confederation of Industries Céramiques de France (CICF), which represents the manufacturer of porcelain, pottery and earthenware, welcomes the initial impact assessment on the migration limits for lead, cadmium and possibly other metals from ceramic materials intended to come into contact with foodstuffs. This step is essential to analyse the impact of a possible revision of legislation for our companies.
Filed in French · English published by the European Commission
Feedback from Italy. The Italian Ministry of Health, DGISAN (General Directorate Hygiene, Health, Food & Nutrition) welcome the opportunity to give a feedback on the Inception Impact Assessment on Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials. It is recognized that new scientific knowledge on hazard of some relevant metals requires action.
In relation to the proposed roadmap we highlight some key issues that we believe should be taken into account by the European Commission: I. The document lacks critical definitions of (1) limit values; (2) Legislative scope and (3) test method. What are the definitions of traditional, artisanal and culturally valuable products and (4) what will be the derogations for these product categories?
Filed in Portuguese · English published by the European Commission
Denby Pottery Co Ltd is a ceramic tableware manufacturer in the UK, where it has over 800 employees. We welcome the opportunity to provide feedback on the roadmap of the inception impact assessment and to inform the Commission on migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials.
FEVE input on the Commission’s inception impact assessment on Migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials FEVE – The European Container Glass Federation – is the voice of container glass manufacturers in Europe representing 160 manufacturing sites for glass containers in the EU28 and Switzerland and Turkey from 23 groups of companies.
Confindustria Ceramica endorse the message shared by CerameUnie here reported: The European Federation of Ceramic Table- and Ornamentalware (FEPF) welcomes the start of the “Impact Assessment on migration limits for lead, cadmium, and possibly other metals from ceramic and vitreous food contact materials”, with an inception impact assessment.
The European Federation of Ceramic Table- and Ornamentalware (FEPF) welcomes the start of the “Impact Assessment on migration limits for lead, cadmium, and possibly other metals from ceramic and vitreous food contact materials”, with an inception impact assessment. We believe it is an important and necessary step, in order to assess the framework of the impact assessment.
The Hungarian Association of Ceramic Industry (HACI) represents ca. 1,500 employees working in Ceramic Table- and Ornamentalware Industry in Hungary. As a member of Cerame-Unie FEPF Sector, HACI takes the opinion of FEPF as follows. We welcome the start of current impact assessment. We believe it is an important and necessary step, in order to assess the framework of the impact assessment.
The British Ceramic Confederation (BCC) represents the UK ceramic tableware manufacturing industry. We welcome the opportunity to provide feedback on the roadmap of the inception impact assessment and to inform the initiative on migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials.
This is the feedback from AiCC, Italian Association of Cities of Ceramics, grouping 40 Italian Municipalities recognized, by the Ministry of Economic Development, as "cities of important and ancient ceramic tradition", that are the Cities where the biggest quantity of italian art and craft ceramics is produced.
BV Glas position paper on the Inception Impact Assessment on ceramic and vitreous ma-terials The European Commission is currently reviewing the existing regulatory framework on food contact materials (FCM), in particular Directive 84/500/EC relating to ceramic ar-ticles intended to come into contact with foodstuffs (Ceramics Directive).
A professional association of consultants for holistic health in Germany is a professional association of consultants for holistic health. We see health in a broad sense, in particular by considering human beings in all its aspects: Body, psychological, social, environmental and soul. Our goal is that more and more people are consciously living in a holistic way.
Filed in German · English published by the European Commission
A new ceramics regulation needs to be fit for purpose. Consumer safety is paramount, but legislative change in this area needs to be clearly understood and workable for all of industry, spanning from tiny artisanal producers to large scale operators. Whilst we will be cooperative in the developments of a new Regulation, we do have some specific concerns that we feel need to be taken into account.
CERAMICOLOR is the Italian Association of Ceramic Glaze, Inorganic Pigment and Metal Oxides Manufacturers, which also involves Italian and multinational companies that produce frits, enamels, dyes and ceramic auxiliaries, inorganic pigments and metal oxides. It represents 15 companies.
I am director of the Craft Potters Association of Great Britain, representing 1,500 artisanal ceramicists across Great Britain and Northern Ireland. We favour a two tier approach with some products indelibly marked “for occasional food use" as originally suggested and a more restrictive level for everyday use.
James M Brown Ltd is a ceramic pigment manufacturer in the UK, where it has 70 employees. We welcome the opportunity to provide feedback on the roadmap of the inception impact assessment and to inform the initiative on migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials.
25 June 2019 Steelite International Ltd is a ceramic tableware manufacturer in the UK, where it has 900 employees. We welcome the opportunity to provide feedback on the roadmap of the inception impact assessment and to inform the initiative on migration limits for lead, cadmium and possibly other metals from ceramic and vitreous food contact materials.
Eurocolour welcomes the possibility to comment on the „Inception Impact Assessment on migration limits for lead, cadmium, and possibly other metals from ceramic and vitreous food contact materials”. With regard to the proposed Roadmap we would like to submit the following comments which are highly important and should be taken into consideration by the European Commission.
Glass Alliance Europe supports the development of a harmonised European food contact legislation for glass products and welcomes the announced impact assessment. However, the glass sector considers that essential elements are modified in this proposed legislation, i.e. the major changes introduced by the scope modification and the limit values.
The Ceramic Industry Association represents the interests of German tableware producers, both industrial producers and manufacture. Together with our European umbrella organisation FEPF, we have prepared a response to the inception impact assessment on the Commission’s roadmap on food contact materials, to which we refer in this context (the text below).
Filed in German · English published by the European Commission
“EN ISO 4531 was created taking into account all the new requests regarding food safety. The papers of EFSA and the COE have been fully respected and BfR observed the evolution of the standard to ensure perfect consumers protection. Therefore it exists a very modern standard that fully complies to all needs and is accepted by the industry. We recommend to use this standard to overcome the need of new regulations.”
SAFE thanks the Commission for allowing citizens and interested stakeholders to provide a feedback on the migration limits for lead, cadmium and other materials from ceramic and vitreous food contact materials. We take this opportunity to provide the Commission with inputs on the issues which need to be covered during the impact assessment and we would like to point out some elements that are worthy of concern.
With regard to the modification of the current rules on the transfer of lead and cadmium in ceramic products for food use (EC Standard 84/500) proposed by the European Commission, with a drastic reduction in the levels currently allowed, the Asociación Española de Cities de la Ceramics (the Spanish Ceramics Cities Association), in close cooperation with the national ceramic industry, is of the opinion that the…
Filed in Spanish · English published by the European Commission
Current MRLs for ceramics need to be updated, in orde to reach an adequate level of consumer protection. MRLs for other metals than Cd and PB are needed, in particular for metals for which there are signals that consumer exposure (from all sources, not only food) might be of concern.
The impact assessment should focus first and foremost on the potential impact on public health, after which the potential economic impact can be considered. Migration limits are set in order to protect the health of the consumer. As a result, these limits should be the same for both industrial and traditional and artisanal products.
Filed in Dutch · English published by the European Commission
Before talking about food processing materials and equipment, the attention needs to be paid to objective studies, which have identified the potential harmfulness of their use for humans. It is not possible to discuss and propose new rules and/or guidelines for their common and even industrial use and use, irrespective of this, what has been done so far is only a start which must lead to an update of the outdated…
Filed in Italian · English published by the European Commission
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.
