What counts as tabletop

Tabletop products are food contact articles used for serving and consuming food and beverages, including ceramic and glass tableware and metal cutlery. They are regulated under the general FCM framework (such as assimilated Regulation (EC) 1935/2004) and national measures for ceramics and glass, with a particular focus on limiting metal release. Decorative items without realistic food contact generally fall only under general product‑safety law, while items used to hold or serve food, or whose rims/lip areas contact beverages, are treated as food contact materials.

Core obligations include:

• Determining whether the product & its components are tabletop food‑contact articles, and identifying all substances and materials that may migrate into food from these parts.

• Tabletop products must also be mechanically robust, with resistance to chipping, breakage, sharp edges, and thermal shock in foreseeable use, in line with relevant product‑safety expectations and buyer or standard requirements.

• Designing tabletop FCMs so that, under normal or foreseeable use, they do not transfer constituents to food in quantities that could endanger health, alter food composition or negatively affect taste, smell or appearance.

• Maintain a technical file, including risk assessments, material and glaze specifications, supply‑chain declarations, migration test reports for lead, cadmium and other metals, physical test reports any screening for NIAS, mechanical‑performance results, and overall compliance evaluations.

• Providing clear instructions and limitations of use for tableware, such as maximum temperatures, suitability for hot or acidic foods, microwave and dishwasher use, contact time restrictions, and any conditions needed to ensure safe performance and durability.

• Applying an appropriate conformity‑assessment strategy for tabletop items, suitable material and coating selection with migration and/or laboratory testing against relevant EU or UK regulations, metal‑release guidance and general FCM measures and standards.

• Drawing up, issuing and retaining Declarations of Compliance (or equivalent documentation) for the relevant stages in the supply chain for tableware and cutlery, citing applicable legislation, limits and specifications, and supporting them with traceable evidence that can be provided to customers and authorities on request.

Markings and information

Where food‑contact use is not obvious, tableware and cutlery must be marked “for food contact” or with the glass‑and‑fork symbol, together with any use restrictions (for example, microwave or dishwasher suitability, limits for hot or acidic foods). Labels should identify the manufacturer or importer and provide clear care instructions so consumers and food‑service operators can handle products safely and preserve their integrity. Manufacturers, importers, and brand owners are expected to hold test reports for metal release and other relevant migration checks, specifications and supplier declarations for glazes, coatings, decorations, and metals, and risk assessments linking test conditions to realistic worst‑case use scenarios.

How we can help

We help map applicable EU and UK food contact and product‑safety requirements for ceramic, glass, and metal tableware, including national ceramic‑articles regulations and current guidance on metal release. Our team supports selection and interpretation of metal‑migration and mechanical‑performance tests, validates supplier documentation, and advises on materials, glazes, decorations, and finishes in line with regulatory and retailer expectations. We can also help refine labelling and care instructions, perform gap analyses on existing ranges, and train product, quality, and buying teams on tabletop compliance and documentation best practice.
With tailored, end‑to‑end support, CERT helps you place food contact material articles on the EU and UK markets that are safe, compliant and fully supported by robust documentation and expert guidance.