SG 076/26
The Netherlands introduces updated rules strengthening migration limits for lead and cadmium in food contact ceramics.
On May 4, 2026, the Netherlands issued Regulation of the Minister of Health, Welfare and Sport of April 23, 2026 (reference 4375777-1097324-WJZ), amending the requirements for food contact ceramics under the Commodities Act (Regulation on Packaging and Consumer Products) (‘the Regulation’). This revision is related to the Decision of the Benelux Committee of Ministers concerning ceramic articles intended to come into contact with food.
What does this new regulation require?
Key changes to paragraph 1 of Chapter VI to Annex A of the Regulation include:
- Strengthening the migration limit values for lead and cadmium (see Table 1 below)
- Emphasizing the elements that must be considered by the economic operator placing the articles on the market when assessing the migration of lead and cadmium, including:
- Composition of substances used in the manufacture of ceramic articles
- Possible use of substances containing lead or cadmium in the manufacture of ceramic articles, including the interior, underglaze or the exterior of the product
- Additional documentation or information from suppliers
- Tests performed on similar materials or articles
- Quality control measures
- Authorizing the application of Article 2(2) of Directive 84/500/EEC (consolidated version to 2005) when the above provision does not ensure sufficient certainty regarding compliance with the updated migration limits for lead and cadmium
- Directing the application of Article 2a of Directive 84/500/EEC to ceramic articles that demonstrate compliance with the revised migration limits for lead and cadmium, provided that the documentation confirms adherence to the new migration limits.
- Repositioning subparagraph 1.3 to 1.2.7 for the determination of the migration of other constituents from ceramic articles
| Ceramic article category¹, ² | Cadmium | Lead |
|---|---|---|
| Category I Articles which cannot be filled and articles which can be filled, the internal depth of which, measured from the lowest point to the horizontal plane passing through the upper rim, does not exceed 25 mm | ≤ 4 µg/dm² | ≤ 6 µg/dm² |
| Category II All other articles which can be filled | ≤ 20 µg/L | ≤ 30 µg/L |
| Category III Cooking ware; packaging and storage vessels having a capacity of more than three liters | ≤ 7 µg/L | ≤ 10 µg/L |
| ¹If a ceramic article consists of a vessel with a ceramic lid, the specific migration limits for lead and cadmium apply only to the vessel ²Where a ceramic article does not exceed the specific migration limits for lead and cadmium by more than 50%, that article must be deemed to be in compliance with the requirements of this regulation if at least three other articles with the same shape, dimension, decoration and glaze are subjected to a test carried out in accordance with Annexes I and II of Directive 84/500/EEC and the average quantities of lead and/or cadmium extracted from those articles do not exceed the established limits, with none of those articles exceeding those limits by more than 50% | ||
Table 1
Who is impacted?
The latest amendment affects stakeholders across the food contact ceramic materials and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in the Dutch market.
When does it apply?
The new law will become effective on May 29, 2026.
Food contact ceramics that comply with the Commodities Act (Regulation on Packaging and Consumer Products) as it stood on May 28, 2026, and were first placed on the market before December 1, 2026, may remain on the market until stocks are exhausted.
We help manufacturers and suppliers of food contact materials (FCM) achieve compliance with markets worldwide while supporting sustainability and market growth through product certification. Our experts offer extensive experience in testing materials and articles for multiple markets, ensuring they meet regulatory and environmental standards.
We provide comprehensive FCM testing, including migration tests, along with expert guidance on evolving regulations, compliance issues and documentation review. Our expertise ensures your products meet the appropriate territorial regulations for food contact materials and helps pave the way for compliance. Contact us to learn more, or visit our website. In the end, it’s only trusted because it’s tested.
© SGS Société Générale de Surveillance SA. This publication or website is a property of SGS Société Générale de Surveillance SA. All contents including website designs, text, and graphics contained herein are owned by or licensed to SGS Société Générale de Surveillance SA. The information provided is for technical and general information purposes only and offers no legal advice. The information is no substitute for professional legal advice to ensure compliance with the applicable laws and regulations. All information is provided in good faith “as is”, and SGS Société Générale de Surveillance SA makes no representation or warranty of any kind, express or implied, and does not warrant that the information will be error-free or meet any particular criteria of performance or quality.
