DTU 2024 - lead and cadmium food-contact-material migration limits

The DTU National Food Institute prepared this memo for the Danish Veterinary and Food Administration as a working document proposing national maximum limits for migration of lead and cadmium from ceramic, glass, and enamelled food-contact materials. The memo is a regulatory source, not a peer-reviewed primary occurrence paper; it combines proposed limits, analytical LOQ reasoning, and secondary summaries of migration studies. The routeable HMI signal is food-contact-material leachate and food-simulant context for ceramic and glass tableware, decorated rims/coatings, ceramic-coated/enamelled cookware, bakeware, and infant feeding bottles.

Key numbers

• Request and scope: DVFA asked DTU on 12/8 - 2024 to suggest new national maximum limits for migration of lead and cadmium from ceramic, glass, and enamelled food-contact materials. The memo is dated 12th of December 2024 and carries DTU DOCX no. 24/1014518.
• Table 1 suggested lead limits: Category I non-fillable/shallow articles and rims of drinking vessels, soup plates, and dinner bowls 0.30 µg/dm2; Category II fillable materials, including cups, glasses, mugs, infant feeding bottles, and other fillable articles 1.5 µg/l.
• Table 1 suggested cadmium limits: Category I non-fillable/shallow articles and rims 0.40 µg/dm2; infant feeding bottles 0.35 µg/l; drinking vessels such as cups, glasses, and mugs 0.70 µg/l; other fillable articles including bowls, cookware, and containers 2.0 µg/l.
• Table 2 current Danish/EU-aligned limits copied in the memo: Pb 800 µg/dm2 for category I, 4000 µg/L for category II, and 1500 µg/L for category III; Cd 70 µg/dm2 for category I, 300 µg/L for category II, and 100 µg/L for category III.
• Prior EU working-group starting values cited by DTU: Pb 3 µg/kg food and Cd 2 µg/kg food, both with an allocation factor of 10 %.
• BfR 2020 analytical-position values cited by DTU: no detectable release with detection limits of 10 μg lead/kg foodstuff (simulant) or 5 μg cadmium/kg foodstuff (simulant), equivalent in the memo’s category-I conversion to 2 μg lead/dm2 and 1 μg cadmium/dm2 assuming 5 square decimetres (dm2)/kg foodstuff.
• Table 3 DVFA method LOQs: Cd 0.062 µg/L, 0.062 µg/kg, and 0.012 µg/dm2; Pb 0.133 µg/L, 0.133 µg/kg, and 0.027 µg/dm2.
• Table 4 analytical limit-value floor: five times LOQ for cadmium gives 0.310 µg/L, 0.310 µg/kg, and 0.062 µg/dm2; ten times LOQ for lead gives 1.328 µg/L, 1.328 µg/kg, and 0.266 µg/dm2.
• DTU lead HBGV used in the memo: 0.05 µg/kg bodyweight pr. day; DTU cadmium reference value: 2.5 μg/kg body weight per week.
• Intake assumptions for limit derivation: 20 g food and beverage/kg bodyweight for storage, cookware, tableware except drinking vessels, and upper rims; 50 g beverage/kg bodyweight per day for drinking vessels; 150 g beverage/kg body weight per day for baby feeding bottles. DTU equates 1 kg food and/or beverage to 1 L food simulant.
• Exposure comparison for lead at 1.5 µg/kg into 20 g food and beverage/kg bodyweight: 5.1 % of EFSA lower-bound mean lifetime dietary exposure for lead; for cups/glasses/mugs under the higher beverage-intake scenario, 12.9 %.
• BfR 2020 heavily decorated ceramic plates from Germany (n = 42, standard 84/500/EEC migration test), Table 5: Pb minimum <1, median 10.0, mean 54.7, 90th percentile 129, 95th percentile 152, maximum 500 μg/dm2; Cd minimum <0.2, median 1.1, mean 24.0, 90th percentile 105, 95th percentile 142, maximum 170 μg/dm2.
• Bulut et al. 2021 Turkish brown ceramic cookware summary: cookware sampled from 13 sales points; n = 96 tests; Pb migration ranged from < 0.10 µg/L to 4.49 µg/L; 2 of 13 products had migration levels > 1.5 µg/L; in around 40 % of duplicate tests, migration increased in the second test.
• Rebeniak et al. 2014 Polish decorated ceramic summary: 187 flat dishes with 174 (93 %) below 10 µg/dm2 Cd and 153 (82 %) below 100 µg/dm2 Pb; 233 deep dishes with 202 (87 %) below 10 µg/L Cd and 153 (66 %) below 100 µg/L Pb; 331 mugs with 325 (98 %) below 10 µg/L Cd and 323 (98 %) below 100 µg/L Pb.
• Mania et al. 2018 Polish decorated ceramic summary: 62 flat ceramic dishes with 60 (97 %) below 10 µg/dm2 Cd and 47 (76 %) below 100 µg/dm2 Pb; 69 deep ceramic dishes with 65 (94 %) below 10 µg/L Cd and 55 (80 %) below 100 µg/L Pb.
• DVFA 2023 Danish ceramic testing summary: 47 ceramic cups, bowls, plates, and ovenproof dishes were tested under standard 84/500/EEC conditions. Four products had Pb migration at or above the LOQ (1.0 µg/l / 0.2 µg/dm2); one cup and one plate were relatively high at 124 µg/l and 14.2 µg/dm2. Three products had Cd migration above the LOQ (0.1 µg/l / 0.02 µg/dm2), and only one product exceeded the memo’s suggested maximum limits.
• Soda-lime glass summary from Rebeniak et al. 2014: 393 beverage-glass samples; Pb migration was not detected in 95 % of samples and Cd migration was not detected in 98 %. Mania et al. 2018 tested nine deep glass dishes and detected neither Pb (LOQ: 100 µg/L) nor Cd (LOQ: 10 µg/L).
• Braikova et al. 2023 crystal-glass summary: traditional crystal glasses containing 24% lead oxide reached lead migration just above 100 µg/L; Cd migration was approximately 90 µg/L in water and 66 µg/L in vodka.
• Haldimann and Zimmerli 1991 crystal-glass summary: four brands exposed to 4 % acetic acid for 24 hours migrated Pb at 71 µg/L to 145 µg/L; 14 brands tested with white wine for 180 min ranged from 14 to 93 µg/L; two products tested with cola gave 115 and 145 µg/L.
• Hight 1996 crystal-glass summary: 24 hours with 4 % acetic acid produced 467 µg/L Pb in solvent, and white wine produced 358 µg/kg. DTU’s consumer-use scenario using Hight’s 6 minutes white-wine value of 154 µg/L estimates 38.5 µg Pb from a 250 ml glass and 0.55 µg/kg bodyweight for a 70 kg adult.
• Rebeniak et al. 2014 Polish crystal-glass summary: 129 crystal-glass samples; one sample had Cd migration 447 µg/L; no Pb sample exceeded the current 4000 µg/L maximum limit; 45 % were within 500 to 2000 µg/L for Pb; 18.6 % were below the detection limit.
• Decorated rims summary: Rebeniak et al. 2014 reported 303 rim samples with 46 (15 %) above 100 µg/product for Pb and 18 (6 %) above 10 µg/product for Cd. Mania et al. 2018 found Pb above 100 µg/product in 2 of 30 ceramic drinking vessels and 2 of 14 glass drinking vessels; Cd above 10 µg/product in 1 of 30 ceramic and 2 of 14 glass vessels.
• Turner 2018 decorated drinking-glass summary: among 72 externally decorated glasses, 52 contained Pb in at least one colour and 51 contained Cd in at least one colour. Maximum enamel levels were almost 400 mg/g Pb and 71 mg/g Cd. In 14 products decorated at or near the rim, Pb migration ranged from 0.03 mg to 33.8 mg, with 11 of 14 exceeding 3 mg; Cd migration ranged from 0.04 mg to 5.4 mg, with 9 of 14 exceeding 0.1 mg.
• Enamelled metal products: the memo states that no data were found on migration levels from enamelled cast iron cookware or ceramic non-stick cookware.

Methods (brief)

The memo is a DTU regulatory working document rather than a laboratory paper. DTU used health-based guidance values, default food/beverage intake scenarios, and DVFA analytical LOQ constraints to propose migration limits. For market-impact context, the memo summarizes available migration studies using the established Council Directive 84/500/EEC ceramic food-contact-material test approach, usually 4 % acetic acid food simulant with 24-hour contact, and includes a short DVFA 2023 internal testing summary for 47 Danish-market ceramic products. The memo keeps migration units on the regulatory basis: µg/dm2, µg/L, µg/kg, µg/product, mg, or mg/g, depending on article type and cited study.

Implications

Certification (HMTc): This source is regulatory context for food-contact-material migration rows, not a proposed HMTc threshold. Its values should remain separated from food-as-consumed occurrence data because they describe migration into food simulant or per-product rim release.

Courses: The memo is a compact example of how a regulator can combine toxicological reference points, allocation factors, LOQs, and market-impact data when revisiting old food-contact-material limits.

App: If surfaced, this source can support a food-contact-material warning that Pb/Cd migration basis matters: a ceramic plate result in µg/dm2, a glass result in µg/L, and a rim result in µg/product are not interchangeable.

Wiki pages this source may touch

• tableware-ceramicware
• tableware-glassware
• tableware-decorative-decals-coatings
• cookware-ceramic-coated
• bakeware
• infant-bottles
• lead
• cadmium
• efsa-lead-contam-2010
• efsa-cadmium-twi

Verification notes

• PDF text was extracted with pdftotext -layout to /tmp/ingest.txt; the title page, Danish and English memo openings, Tables 1-5, the health-based limit calculations, the data-on-migration section, and the references were checked against this page.
• Identity checks before creation: title, DTU DOCX no. 24/1014518, raw handle MFK_0-5-micrograms-ml, raw SHA-256 8cd6d7dccf96c916b4c1be581517d40be993ad14aa72f814a8a17121a5dda29a, and cite key dtu2024-food-contact-pb-cd-limits were searched in wiki/sources/ and evidence files; no existing source page was found.
• DOI status: no DOI is printed in the PDF or the DTU Orbit cover page. The page uses doi: null and no_doi_assigned: true.
• Units are copied as printed in the memo. No conversion was performed between µg/dm2, µg/L, µg/kg, µg/product, mg, or mg/g.
• Speciation: the memo reports lead and cadmium migration as total Pb and total Cd regulatory endpoints. There is no arsenic, mercury, chromium, tin, or organotin speciation issue.
• The sample_n: 47 field refers only to the DVFA 2023 Danish ceramic testing summary. The BfR, Bulut, Rebeniak, Mania, Braikova, Haldimann/Zimmerli, Hight, and Turner numbers are secondary summaries copied from this memo, not fresh primary extraction from those original papers.
• Brand firewall: no brand names are attached to contamination values. The memo reports categories and cited-study summaries, not brand-by-brand product results.
• HMTc firewall: the suggested maximum limits are DTU/DVFA source-side regulatory proposals, not HMTc thresholds. The Implications section does not propose HMTc values or compare against certification thresholds.
• Closed-vocabulary check: product slugs appear in the current taxonomy snapshot. food-contact-material-leachate and food-simulant follow established food-contact-material matrix terms already used in sibling source pages. Exact enamelled-cast-iron and lead-crystal-glass sub-slugs are not available; they are retained in prose rather than invented in frontmatter.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.