Denmark has established new lower migration limits for lead and cadmium from enamelled articles and glass, and clarified declaration requirements for all food contact materials across multiple product categories.
Denmark Tightens Food Contact Materials Safety Standards
Stricter limits on lead and cadmium apply to enamelled cookware and glass.
What changed
Lower migration limits for lead and cadmium in enamelled articles and glass.
Declaration of compliance required for all food contact materials.
Specific scope defined for HS codes 732392, 732394, 700100, 700800.
Who it affects
Importers of enamelled cookware and glass tableware must ensure products meet new migration limits.
Manufacturers and distributors of food contact materials must provide a verifiable declaration of compliance.
Compliance Overview: Denmark’s New Migration Limits and Declaration Requirements for Food Contact Materials
Denmark has introduced stricter migration limits for lead and cadmium from enamelled articles and glassware, alongside clarified declaration of compliance requirements for all food contact materials (FCMs). These changes are implemented through amendments to the Danish Order on food contact materials and regarding penal provisions on the relevant EU-legislation on food contact materials (hereafter, the Order), supplementing Regulation (EC) No 1935/20041. The new rules aim to enhance consumer health protection by reducing exposure to harmful substances and standardizing documentation obligations for businesses.
Regulation Analysis
1. New Migration Limits for Lead and Cadmium
The Order establishes lower migration limits for lead and cadmium from enamelled articles and glassware, categorized by product type and usage. These limits are specified in Annex 5 of the Order and apply to all such products placed on the Danish market1.
Migration Limits Table
| Category | Lead (Pb) Limit | Cadmium (Cd) Limit | Applicable Products | Source |
|---|---|---|---|---|
| Category A | 1 | |||
| – Articles that cannot be filled | 0.3 µg/dm² | 0.4 µg/dm² | Flatware, plates, decorative items | |
| – Articles that can be filled (internal depth ≤ 25 mm) | 0.3 µg/dm² | 0.4 µg/dm² | Shallow bowls, saucers | |
| – Rim of drinking articles | 0.3 µg/dm² | 0.4 µg/dm² | Glasses, cups, mugs (rim area only) | |
| Category B | 1 | |||
| – Baby bottles | 0.35 µg/L | 2 µg/L | All baby feeding bottles | |
| – Articles intended for drinking | 0.7 µg/L | 2 µg/L | Glasses, cups, mugs (entire article) | |
| – Other fillable articles | 1.5 µg/L | 2 µg/L | Pitchers, vases, storage containers |
Key Notes:
- Limits are mandatory for all enamelled articles and glassware marketed in Denmark, regardless of origin1.
- Section 10 of the Order, which contains these limits, will enter into force on 1 January 2027, while the rest of the Order takes effect on 1 July 20261.
- Compliance is enforced by the Danish Veterinary and Food Administration (DVFA)1.
2. Declaration of Compliance Requirements
The Order clarifies and strengthens the requirements for declarations of compliance (DoC) for all FCMs, aligning with Article 16(2) of Regulation (EC) No 1935/20041. These requirements apply to all FCMs placed on the market before the retail stage (e.g., manufacturers, importers, distributors).
DoC Requirements (Annex 1 of the Order)
The declaration must include the following mandatory information1:
- Identity of the business operator (name, address, contact details).
- Description of the FCM (material type, trade name, intended use).
- Date of issue and validity period (if applicable).
- Confirmation of compliance with:
- Regulation (EC) No 1935/2004 (general FCM framework).
- Relevant EU or Danish specific measures (e.g., migration limits for lead/cadmium).
- Supporting documentation, including:
- Test reports demonstrating compliance with migration limits.
- Information on substances used in manufacturing (e.g., coatings, additives).
- Signature of the responsible person (or authorized representative).
Key Notes:
- The DoC must accompany the FCM at all stages of the supply chain (except retail)1.
- Businesses must retain the DoC for 5 years after the FCM is placed on the market1.
- The requirements apply without prejudice to any EU-specific measures (e.g., plastics, ceramics)1.
- Penalties for non-compliance are outlined in the Order, including fines or product recalls1.
3. Enforcement and Timeline
| Regulation | Key Requirement | Deadline/Threshold | Authority |
|---|---|---|---|
| Danish Order on food contact materials (amending decree) | New migration limits for lead/cadmium from enamelled articles and glass1. | 1 January 2027 | DVFA1 |
| Danish Order on food contact materials | Clarified DoC requirements for all FCMs1. | 1 July 2026 | DVFA1 |
| Regulation (EC) No 1935/2004 | General FCM framework; DoC requirements under Article 16(2)1. | Ongoing | EU/DVFA |
Additional Notes:
- The Danish Business Authority is responsible for notifying these changes under Directive (EU) 2015/15351.
- Stakeholders could submit comments on the draft Order until 13 April 20261.
Summary Answer
Denmark has introduced stricter migration limits for lead and cadmium from enamelled articles and glassware, effective 1 January 2027, with thresholds ranging from 0.3 µg/dm² to 2 µg/L depending on the product category1. Additionally, the Danish Order on food contact materials clarifies declaration of compliance (DoC) requirements for all FCMs, mandating detailed documentation (e.g., test reports, business identification) to accompany products before the retail stage, enforceable from 1 July 20261. These measures supplement Regulation (EC) No 1935/2004 and are enforced by the Danish Veterinary and Food Administration (DVFA)1. Businesses must ensure compliance with both the new migration limits and DoC obligations to avoid penalties1.
Sources
- ↩ Bekendtgørelse om fødevarekontaktmaterialer og om straffebestemmelser for overtrædelse af relaterede EU-retsakter/Danish Order on food contactmaterials and regarding penal provision on the relevant EU-legislation on food contact materials; The attached draft amending the legislative decree establishes new lower migration limits for lead and cadmium from enamelled articles and glass, and clarifies the applicable requirements for declaration of compliance for all food contact materials. https://docs.wto.org/dol2fe/Pages/SS/directdoc.aspx?filename=Q:/G/TBTN26/DNK146.pdf&Open=True