Food Contact Material Safety

The basic rule: what the law says

The Materials and Articles in Contact with Food (England) Regulations 2012 (SI 2012/2619) implement retained EU Regulation 1935/2004 in UK law. Equivalent regulations apply in Scotland, Wales, and Northern Ireland. The core principle is straightforward: any material or article intended to come into contact with food must not transfer its constituents to food in quantities that could:

• Endanger human health.
• Bring about an unacceptable change in the composition of the food.
• Cause deterioration in the organoleptic properties of the food (that is, its taste, smell, or appearance).

This applies to everything from a ceramic mug to a wooden spoon to a resin serving board. If you market it for food use, or if a reasonable consumer would expect to use it with food, these regulations apply to you.

The regulations also require traceability. You must be able to identify your suppliers (of glazes, clays, food-safe finishes) and, ideally, the customers you have sold to. Keeping records of batches and materials is both a legal requirement and good business practice.

Ceramics: lead and cadmium migration limits

Ceramics get their own specific legislation because of the historical use of lead and cadmium in glazes. The Ceramic Articles in Contact with Food (England) Regulations 2006 set strict migration limits for these two metals.

The limits are:

• Flatware (plates, saucers, flat items): lead must not exceed 0.8 mg/dm²; cadmium must not exceed 0.07 mg/dm².
• Hollowware (mugs, bowls, jugs, items with a depth greater than 25 mm): lead must not exceed 1.5 mg/dm²; cadmium must not exceed 0.3 mg/dm².
• For very small hollowware and storage vessels, different limits may apply; check the regulations for your specific product type.

These limits are tested by filling or covering the item with a dilute acid solution (typically 4% acetic acid) for 24 hours at 22°C, then measuring how much lead or cadmium has migrated into the solution.

Why this matters for craft potters: many traditional and decorative glazes contain lead or cadmium compounds. Even glazes labelled as "lead-free" may contain trace amounts. If you sell pottery for food use at a craft fair, your glazes must meet these migration limits. Using a glaze that looks beautiful but leaches lead into someone's morning tea is not just a regulatory problem; it is a serious health risk.

Other materials: wood, bamboo, resin, and glass

Ceramics are not the only craft products caught by food contact regulations. If you sell any of the following for food use, you must comply:

Wood and bamboo: Chopping boards, serving boards, salad servers, spatulas, and other wooden kitchenware are popular craft fair items. The wood itself must be suitable for food contact (untreated hardwoods are generally acceptable), and any finish applied must be food-safe. Mineral oil, food-grade linseed oil, and certain waxes are commonly used. Varnishes and stains not designed for food contact are not acceptable. Bamboo composite products (where bamboo fibre is mixed with melamine or other binders) have come under particular scrutiny; some have been found to release formaldehyde or melamine above safe levels.

Resin: Epoxy resin boards, coasters, and serving platters have become popular craft items. Not all resins are food-safe once cured. If you sell resin items for food use, you need to use a resin that is certified as food-safe and compliant with food contact regulations. Check your resin supplier's data sheets; they should confirm compliance with UK food contact requirements.

Glass: Handmade glass items (drinking glasses, bowls, carafes) must also comply. Clear glass is generally low risk, but coloured glass and glass decorated with enamels or paints may contain heavy metals. The same migration principles apply.

For all these materials, the general rule from Regulation 1935/2004 applies: no transfer of substances in harmful quantities, no unacceptable changes to food composition, and no deterioration of taste, smell, or appearance.

Testing and certification

If you sell food contact items, you should be able to demonstrate compliance. The strongest evidence is laboratory testing.

For ceramics: You can send samples to a UKAS-accredited laboratory for migration testing. The lab will test for lead and cadmium migration using the standardised acid extraction method. Costs vary, but expect to pay in the region of £100 to £300 per test depending on the lab and the number of items. You do not need to test every individual piece, but you should test representative samples from each glaze and clay combination you use.

For commercial glazes: If you buy glazes from a reputable supplier, they should provide compliance data or a declaration of conformity confirming the glaze meets food contact requirements when fired according to their instructions. Keep these documents on file. Note that firing temperature matters: a glaze that is food-safe at cone 6 may not be food-safe at cone 06.

For wood finishes and resins: Your supplier should provide a technical data sheet or declaration of conformity confirming the product is suitable for food contact. If they cannot provide this, do not use it on food contact items.

A declaration of conformity is a document you (or your supplier) prepare stating that the product complies with the relevant regulations. For food contact materials, this should reference the Materials and Articles in Contact with Food Regulations 2012 and, for ceramics, the Ceramic Articles in Contact with Food Regulations 2006.

The "decorative only" route

If your ceramics, glassware, or other items are not intended for food use, you can mark them as decorative only. This exempts them from food contact material regulations, but you must be clear and honest about it.

To use this exemption properly:

• Label the item clearly with "Not for food use" or "For decorative purposes only."
• The label must be visible at the point of sale (not hidden under the item or inside the packaging).
• Do not market the item in a way that suggests food use. A mug shape with a "decorative only" sticker is likely to raise questions from Trading Standards, because a reasonable consumer would expect to drink from a mug.
• Consider the item's form: if it looks like functional tableware (a plate, a bowl, a cup), it will be harder to argue it is purely decorative.

This route works well for wall plates, decorative vases, ornamental bowls, and sculptural pieces. It is less convincing for items that are obviously functional tableware. If an item could reasonably be used with food, even if you label it "decorative only," enforcement officers may still consider it within scope of the regulations.

Enforcement: OPSS and Trading Standards

Food contact material regulations are enforced by local authority Trading Standards officers and, at a national level, by the Office for Product Safety and Standards (OPSS). The Food Standards Agency (FSA) also has a role in setting policy around food contact materials.

Trading Standards officers can and do visit craft fairs. They have the power to:

• Inspect products and request documentation (declarations of conformity, test certificates, supplier data sheets).
• Take samples for laboratory testing.
• Issue improvement notices requiring you to take corrective action.
• Seize and detain non-compliant products.
• Prosecute in serious cases, particularly where there is a risk to public health.

In practice, most officers take an advisory approach with small makers, especially if you can show you are trying to comply. Having your paperwork organised (test certificates, supplier declarations, batch records) makes a significant difference. If you cannot produce any evidence of compliance, that is a much harder conversation.

What would Trading Standards ask to see?

Food contact materials are regulated under retained Regulation (EC) No 1935/2004 and enforced by Trading Standards and the FSA. If you sell any product intended to come into contact with food (mugs, bowls, chopping boards, coasters marketed for food use), an officer can ask for documentation proving the materials comply with migration limits.

They can request:

• **A Declaration of Conformity.** A formal statement, prepared by you or your material supplier, that the product complies with the relevant food contact materials regulations. For ceramics, this includes the Ceramic Articles in Contact with Food Regulations 2006 covering lead and cadmium migration limits.
• **Migration test certificates.** For ceramics: lead and cadmium migration testing from a UKAS-accredited laboratory. For other materials: appropriate migration testing for the material type.
• **Supplier declarations or data sheets.** For glazes, food-safe finishes, resins, or any material that contacts food. These should confirm compliance when used according to the supplier's instructions.
• **Batch and material records.** Which glaze or finish was used on which products. For ceramics: firing temperature records, since the same glaze can behave differently at different temperatures.
• **Traceability records.** Who supplied your raw materials (clays, glazes, finishes) and when. Required under the general traceability provisions of Regulation (EC) No 1935/2004, Article 17.

A Declaration of Conformity is the document that ties everything together: it references your test certificates, identifies your products, and states the regulations you are declaring compliance with. Most small makers who have had their glazes tested have the test certificate but not the formal declaration. **Your StallSync Event Passport can hold your Declaration of Conformity, test certificates, and supplier data sheets, giving you a complete food contact compliance file accessible on your phone.**

Practical steps for compliance

Here is a summary of what you need to do if you sell food contact items at craft fairs:

• Use food-safe materials from reputable suppliers who provide compliance documentation, safety data sheets, or declarations of conformity.
• For ceramics: use glazes that are certified food-safe and fire them at the correct temperature. If you use your own glaze recipes, get representative samples tested at a UKAS-accredited lab.
• For wood: use food-grade finishes only. Keep records of which finish you used on which products.
• For resin: use a resin certified for food contact. Keep the supplier's compliance documentation.
• Keep records: maintain a file of test certificates, supplier declarations, and batch records. Bring copies to craft fairs.
• Label correctly: if an item is for food use, make sure it is compliant. If it is purely decorative, label it clearly as "Not for food use" or "For decorative purposes only."
• Stay informed: glaze formulations and regulations can change. Check your suppliers' updates and keep an eye on OPSS guidance.
• If in doubt, get it tested. A laboratory test is the most robust way to prove compliance, and the cost is modest relative to the risk of selling a non-compliant product.