Cookware Regulations and Standards in the European Union

Posted on Leave a comment

Cookware Regulations in the European Union

Cookware imported and manufactured for sales in the EU are subject to various regulations, substance restrictions, labelling, documentation, and testing requirements. Some of these regulations are specific to various types of food contact materials.

But, there are also regulations and directives that cover consumer products in general, including cookware. Hence, this guide is not only covering food contact materials, but a broad set of compliance requirements for cookware as a category.

More specifically, we break down the requirements depending on the materials, as this impacts the applicable requirement.s


FREE CONSULTATION CALL (US, EU & UK)

  • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
  • Find product requirements
  • Certification and labeling
  • Lab testing

REQUEST A CALL

General cookware requirements

Importers and manufacturers of any type of food contact materials, including cookware, should ensure that they adhere to the requirements of the EU FCM Regulation, the Good Manufacturing Practice for FCM Regulation, and other regulations that cover consumer products in general (e.g. REACH).

EU Food Contact Materials Framework Regulation (EC) 1935/2004

This regulation applies to materials and articles that are meant to be brought into contact with food, are already in contact with food and meant for that purpose, or are expected to come into contact with food under reasonable circumstances.

Product examples

This regulation covers cookware, regardless of the material. Here are some examples of covered products:

  • Stock pots
  • Frying pans
  • Woks

Requirements

Importers and manufacturers of cookware and other products that fall under the scope of the regulation should:

a. Comply with good manufacturing practice (GMP) requirements so that the products do not not alter the food’s composition in an unacceptable manner or endanger humans.

b. Conform to specific measures (e.g., adhering to migration limits for plastic products).

c. Draft a written declaration of compliance, when required by one or more specific measures.

d. Create the relevant label files.

e. Ensure that the products are traceable.

Good Manufacturing Practice for FCM Regulation (EC) 2023/2006

This regulation applies to the manufacture, processing, and distribution of food contact materials and articles, including cookware. It establishes Good Manufacturing Practice (GMP) rules for the groups of materials and articles listed in Annex I to the EU FCM Regulation, which includes:

  • Ceramics
  • Glass
  • Metals and alloys
  • Plastics
  • Silicones
  • Wood

Product examples

This regulation might cover cookware such as the following:

  • Metal frying pans
  • Ceramic bowls
  • Cast iron frying pans
  • Glass cooking pots

Requirements

Business operators are required to ensure that their manufacturing operations are executed per:

  • The GMP rules regarding their quality assurance system
  • The GMP rules regarding their quality control system
  • The GMP rules regarding documentation
  • The detailed GMP rules as established in the Annex

General Product Safety Directive

The General Product Safety Directive (GPSD) aims to ensure the safety of products placed on the market. It establishes general rules for importers, manufacturers, and distributors regarding safety aspects of consumer products that are not covered by other regulations. This could include, for example, measure that aim at preventing mechanical hazards, which are generally not covered by regulations specific for food contact materials.

Product examples

The GPSD covers a wide range of consumer products, for hazards that are not already covered by other regulations.

Thus, as an example, the GPSD could cover burning hazards caused by cookware products whose handle become too hot due to improper isolation and, as such, burn the users.

Here are some examples of products that might fall under the scope of the GPSD:

  • Cooking pots
  • Portable barbecues
  • Pans

Requirements

Products placed on the market should:

  • Be safe, for instance because they comply with relevant harmonised, national, or international standards
  • Bear a traceability label
  • Be marked with appropriate warnings (if relevant)
  • Be accompanied by instructions (if relevant)

REACH

The REACH Regulation aims to ensure the of protection for the environment and human health from dangerous chemicals, and the free circulation of substances and articles in the EU market.

Product examples

The regulation covers a broad range of substances, including cookware and other articles that contain these substances. Examples of cookware that is covered by REACH include:

  • Sauce pans
  • Frying pans
  • Whisks
  • Ladles

Requirements

The REACH regulation requires importers and manufacturers to:

a. Adhere to substance restriction requirements under Annex XVII.

b. Register their products in the SCIP database and notify the consumers upon request if their products contain over 0.1% of any substances of very high concern (SVHC).

Note that, in some cases, not all the product must comply with the relevant substance restrictions. For example, according to the “Guideline on the scope of restriction entry 50 of Annex XVII to REACH: Polycyclic aromatic hydrocarbons in articles supplied to the general public”, only the handle and holding area of the product must comply with the PAHs restrictions (0.0001% by weight) set in Annex XVII.

Ceramic cookware

Importers and manufacturers should comply with the Ceramics FCM Directive requirements, in addition to the requirements outlined in the previous sections, when manufacturing and placing on the market ceramic food contact articles.

Ceramics FCM Directive 84/500/EEC

This directive concerns the potential migration of cadmium and lead from finished ceramic products that are meant to come into contact with food.

Product examples

The directive covers ceramic products intended for contact with foodstuffs, such as:

  • Ceramic cooking ware
  • Ceramic articles that can’t be filled
  • Fillable ceramic articles with a maximum internal depth of 25 mm

Examples of ceramic cookware include, but are not restricted to:

  • Saucepans
  • Pots
  • Pans
  • Dutch ovens

Requirements

Article 2 of the directive specifies lead and cadmium limits for three categories of ceramic articles, when said substances are extracted during testing.

a. Category 1 – Ceramic articles, which include articles that cannot be filled as well as those that can be filled (the internal depth of which should not exceed 25 millimetres (mm)), should have a lead limit of 0.8 milligram per square decimetre (mg/dm2), and a cadmium limit of 0.07 mg/dm2.

b. Category 2 – “All” other fillable ceramic articles should have a lead limit of 4.0 milligrams per litre (mg/l) and a cadmium limit of 0.3 mg/l.

c. Category 3 – Ceramic cookware, as well as packaging and storage vessels that have capacities exceeding 3 litres, should have a lead limit of 1.5 mg/l and a cadmium limit of 0.1 mg/l.

The Directive also requires the issuance of a declaration of compliance

Wooden cookware

Before placing wooden cookware on the market, importers and manufacturers should ensure that their products adhere to relevant requirements and regulations.

Deforestation Regulation (EU) 2023/1115

The Deforestation Regulation aims to address the problem of deforestation due to agricultural expansion and commodity production. It requires operators and traders to prove that their products didn’t contribute to forest degradation.

Specifically, wooden products should be made of wood that has been harvested from forests without resulting in deforestation.

You can find examples of wooden kitchenware in

Product examples

Annex I of the regulation specifies that tableware and kitchenware made of wood are covered by the regulation. Here are some product examples:

  • Soup ladles
  • Cut boards
  • Serving spoons
  • Spatulas

Requirements

The regulation requires importers and manufacturers to exercise due diligence and providing:

a. A due diligence statement, containing items such as:

  • Product description
  • The product’s country of manufacture

b. Documentation regarding due diligence, such as:

  • Summary of information regarding the product
  • Conclusions of risk assessment
  • Consultations with indigenous peoples, where applicable

Stainless steel cookware

Importers and manufacturers of stainless steel cookware should ensure that their products are safe before placing them on the market. This means that the products must comply with relevant regulations. The EU also released a technical guide for metals and alloys used in food contact materials and articles. You can find the link below.

Product examples

Here are a few examples of stainless steel cookware:

  • Roasting trays
  • Frying pans
  • Griddles
  • Pots

Requirements

As far as we know, no specific measures for stainless steel cookware exist. However, general requirements (e.g., GMP requirements, requirements set by the EU FCM Framework Regulation) for food contact articles still apply.

Stainless steel cookware products might contain coatings and paints; as such, you should refer to requirements in Regulation EU 2018/213 or Regulation EC 1895/2005.

EU documents

It is also important to take into consideration guides, resolutions, and other EU documents that can help you to understand how to apply the requirements of the existing directives and regulations, or complement them, when no specific measure exist for a material.

Here we list some documents that are relevant for stainless steel cookware:

a. Metals and alloys used in food contact materials and articles – A practical guide for manufacturers and regulators (Link)

b. Resolution CM/Res(2020)9 on the safety and quality of materials and articles for contact with food (Link)

c. Guidelines on testing conditions for articles in contact with foodstuffs (Link)

Plastic cookware

Importers and manufacturers of plastic cookware should ensure that their products comply with the requirements of the regulations outlined in this section, besides ensuring that the products comply with regulations that cover cookware in general.

FCM Plastic Materials and Articles Regulation (EU) 10/2011

This regulation specifies requirements for plastic materials and articles meant for, or are reasonably expected to come into, contact with food.

Product examples

The regulation covers substances used in plastic food contact cookware, which might include:

  • Plastic steamer basket
  • Plastic cooking pot
  • Plastic microwavable cookware container
  • Plastic microwavable bowls

Requirements

Plastic cookware placed on the market must comply with the following requirements:

  • Specific migration limits (SML)
  • Overall migration limits
  • Declaration of compliance

Restriction of Use of Certain Epoxy Derivatives in FCM Regulation (EC) 1895/2005

This regulation restricts the usage of the epoxy derivatives BADGE, and bans the usage of BFDGE and NOGE, in plastic food contact materials.

Product examples

The regulation covers cookware that might contain epoxy derivatives, such as:

  • Plastic cookware (e.g., steamer basket)
  • Plastic cookware covered by surface coatings (e.g., cooking pots with non-stick coatings)
  • Plastic cookware with adhesives (e.g., plastic microwaveable containers)

Requirements

Covered cookware should:

  • Not release BADGE into food at amounts exceeding 9 mg/kg
  • Not contain BFDGE and NOGE
  • Be accompanied by a written declaration (for BADGE) per the EU FCM Regulation

Polyamide and Melamine Plastic Kitchenware from China or Hong Kong SAR (China) Regulation (EU) No 284/2011

This regulation sets conditions and comprehensive processes for the importation of polyamide and melamine plastic kitchenware from China or Hong Kong SAR (China).

Product examples

The regulation covers cookware that might contain melamine or polyamide, such as:

  • Sauce pots
  • Whisks
  • Ladles

Requirements

Importers of plastic kitchenware that contain polyamide and melamine should:

  • Comply with import conditions
  • Issue a declaration of compliance and a lab test report for each consignment
  • Comply with notification requirements

Recycled Plastic FCM Regulation (EU) 2022/1616

This regulation establishes rules for plastic products (containing recycled plastic) covered by the EU FCM Regulation.

Product examples

This regulation covers products containing recycled plastic, and might cover cookware such as:

  • Cooking whisks containing recycled plastic
  • Cooking pan handles made from recycled plastic
  • Cooking pot lid handles made from recycled plastic

Requirements

Cookware containing recycled plastic should adhere to requirements such as:

  • Being manufactured using an acceptable recycling technology
  • Adhering to relevant substance restrictions
  • Being accompanied by a declaration of compliance
  • Bearing adequate labelling (e.g., batch number)

Guidance and Guidelines

The following documents are relevant for plastic cookware:

a. EU Guidance on plastic materials (Regulation (EU) No 10/2011) (Link)

b. EU Guidance on information in the plastics supply chain (Link)

c. Guidance for the identification of polymers in multilayer films used in food contact materials (Link)

d. Guideline on testing migration of primary aromatic amines from polyamide utensils and for formaldehyde from melamine-based kitchenware in support of Regulation (EU) No 284/2011 on imports from China and Hong-Kong (Link)

e. Guidelines on testing conditions for articles in contact with foodstuffs (see link on the section dedicated to stainless steel cookware)

Silicone cookware

To the best of our knowledge, no specific regulation or directive for silicone cookware exist. However, this doesn’t mean that these products don’t have to adhere to any safety requirements.

General requirements for cookware still apply. Additionally, the EU published a resolution that solely focuses on silicone food contact products. We link to this document in the section below. We are also aware of testing companies using the resolution as the basis for lab testing.

Product examples

We list below a few examples of silicone cookware:

  • Silicone bakeware
  • Silicone spatulas
  • Silicone cooking tongs

Requirements

Silicone cookware is subject to the general requirements set by the following regulations:

a. EU Food Contact Materials Framework Regulation (EC) 1935/2004

b. Good Manufacturing Practice for FCM Regulation (EC) 2023/2006

c. General Product Safety Directive

d. REACH

Besides that, if your product contain coatings or paints, Regulation EU 2018/213 or Regulation EC 1895/2005 also apply.

Resolution on silicone food contact products

The EU published the “Resolution ResAP(2004)5 on silicones used for food contact applications”, which sets requirements concerning the migration of substances from silicone products to foodstuffs.

Importers and manufacturers can use this document to assess what kind of testing is necessary for their silicone cookware. Test labs are also likely to follow these requirements.

You find more information on this page.

Other relevant documents

The “Guidelines on testing conditions for articles in contact with foodstuffs” linked in the section concerning stainless steel cookware are also relevant for silicone cookware products.

Coatings and paints

Cookware and food contact materials might have varnishes and coatings, which in turn might contain Bisphenol A (BPA) and some epoxy derivatives. Importers and manufacturers of such cookware should ensure they adhere to the relevant requirements.

Use of Bisphenol A in Varnishes and Coatings Regulation (EU) 2018/213

This regulation applies to varnishes and coatings that were manufactured using BPA and meant to come into contact with food.

Product examples

You might find varnishes and coatings in cookware products such as:

  • Baking pans
  • Cooking pans
  • Frying pans

Requirements

Manufacturers should ensure that:

a. BPA should not migrate into food from coatings or varnishes applied to products in quantities exceeding a specific migration limit 0.05 mg/kg of food.

b. There is no BPA migration from varnishes and coating of articles intended young children which are meant to come into contact with infant formula and other products as outlined in Article 2 of the regulation.

c. They issue a written declaration of compliance.

Restriction of Use of Certain Epoxy Derivatives in FCM Regulation (EC) 1895/2005

This regulation bans the usage of BFDGE and NOGE, and restricts the usage of BADGE and its epoxy derivatives, in surface coatings of cookware and other products.

Product examples

The regulation covers products that use BADGE, BFDGE, or NOGE in its surface coating, and might include cookware such as:

  • Coated cooking pots
  • Coated woks
  • Coated frying pans

Requirements

Coatings of cookware should:

  • Not contain BFDGE and NOGE
  • Not release BADGE and its derivatives into food at amounts exceeding 9 mg/kg
  • Undergo migration testing for BADGE and its derivatives
  • Be accompanied by a written declaration (for BADGE) per the EU FCM Regulation

EN Standards

EN standards cover a broad range of products, and might include requirements such as test methods, test procedures, or labelling. These standards can generally be used to comply with the requirements of relevant regulations, and enhance product safety, even if they are generally voluntary.

Here, we list here a few standards relevant to cookware:

a. EN 1388-1 – Materials and articles in contact with foodstuffs – Silicate surfaces – Part 1: Determination of the release of lead and cadmium from ceramic ware

b. EN 12983-1 – Cookware – Domestic cookware for use on top of a stove, cooker or hob – Part 1: General requirements

c. EN 12983-2 – Cookware – Domestic cookware for use on top of a stove, cooker or hob – Part 2: General requirements for ceramic cookware and glass lid

d. EN 15284 – Materials and articles in contact with food stuffs – Test method for the resistance to microwave heating of ceramic, glass, glass-ceramic or plastics cookware

Lab testing

You generally need to have your cookware products tested to ensure that they don’t contain any substances that either exceed migration limits, or limits by weight. Other types of tests might also be necessary (e.g. to ensure the product’s mechanical safety).

After your product passes testing, you receive a test report that proves your product’s compliance with relevant requirements and regulations.

Test methods

Here, we list a few examples of test methods relevant to cookware:

a. ISO 7086-1 – Glass hollowware in contact with food – Release of lead and cadmium – Part 1: Test method

b. ISO 6486-1 – Ceramic ware, glass ceramic ware and glass dinnerware in contact with food – Release of lead and cadmium – Part 1: Test method

c. a. ISO 8391-1 – Ceramic cookware in contact with food – Release of lead and cadmium – Part 1: Method of test

d. EN 13248 – Cookware – Coffee makers for domestic use with an independent heat source – Definitions, requirements and test methods

e. EN 15284 – Materials and articles in contact with food stuffs – Test method for the resistance to microwave heating of ceramic, glass, glass-ceramic or plastics cookware

Testing companies

Here are a few companies that offer testing services against the EU FCM Framework Regulation, and related regulations:

  • (USA & EU)

    FREE CONSULTATION CALL (US, EU & UK)

    • Request a free 30-minute call with Ivan Malloci to learn how we can help you with:
    • Find product requirements
    • Certification and labeling
    • Lab testing

    REQUEST A CALL



    Disclaimer: The Site cannot and does not contain legal advice. The legal information is provided for general informational and educational purposes only and is not a substitute for professional advice. Accordingly, before taking any actions based upon such information, we encourage you to consult with the appropriate professionals. We do not provide any kind of legal advice. THE USE OR RELIANCE OF ANY INFORMATION CONTAINED ON THE SITE IS SOLELY AT YOUR OWN RISK.

    Full Disclaimer: Link

    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
  • Leave a Reply

    Your email address will not be published. Required fields are marked *

    Compliance Gate Platform: 30% OFF until Friday

    Free Training Session

    Product Compliance in 2024

    1. United States, EU, and UK

    2. Product examples & case studies

    3. Ask your questions via Live Chat!