Regulatory Information for Heavy
Metal Glass & Ceramic Decorating

Ceramic and glassware are often decorated with permanent, kiln-fired colors that have traditionally contained heavy metals. The use of these metals, primarily lead and cadmium, has come under examination in relation to
negative health and environmental impacts.

When in contact with foods and beverages, the metals can leach out of the decorations. Prolonged
or repeated food contact can result in chronic poisoning. Ceramic or glass packaging that enters the waste stream also leaches the poisons, which can have severe consequences on the environment and our water supply.

In response to these concerns, there are a number
of regulations limiting the amount of heavy metals in food-bearing vessels and disposable packaging. The FDA and EPA have established national guidelines, in addition to which there are individual state laws and voluntary industry standards. The summaries and links below are provided to help you understand the regulations and potential consequences of heavy metal use in glass and ceramic decoration, and to offer you safe and effective decorating options.

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Federal Food & Drug Administration

A. Ceramic Food Bearing Surfaces
The FDA's Compliance Guide sets forth the standards for the leaching of lead
(CPG 7117.07) and cadmium (CPG 7117.06) from the food contact surface of ceramic tableware.

Lead Rules (measurements in ppm):

• Flatware - 3.0
• Small Hollowware - 2.0
• Large Hollowware - 1.0
• Cups/Mugs - 0.5
• Pitchers - 0.5

Cadmium Rules (measurements in ppm):

• Flatware - 0.5
• Small Hollowware - 0.5
• Large Hollowware - 0.25

B. Lip and Rim Area
A voluntary industry standard limits the amount of lead and cadmium leaching from the top 20 mm of the outside of a ceramic cup, mug, or drinking glass. The limits are not more than 4ppm of lead and not more than .4ppm for cadmium. The standard does not apply to ceramic or glass ware that have less than 60 mm of decorating area below the rim and which is not intended for usage by children.

C. Decorative Ware
In addition to tableware, the FDA has a regulation (21CFR109.16) for the proper labeling and representation of decorative ceramic and glass ware containing heavy metals. These requirements include a clearly visible sticker warning of the poisoning potential on the top of the piece, a similar, permanent label on the bottom, and may sometimes include altering the piece to ensure it cannot be used to prepare, hold, or serve food.

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Consumer Product Safety Commission

Before 2008, the CPSC had little interaction in the limiting of harmful materials within cermic and glass products. However, with the enactment of the Consumer Product Safety Improvement Act of 2008, new restrictions were placed on products that were marketed for young children. It stipulates that after August 14, 2009, manufactured products for children cannot contain more than 300 ppm of lead. After August 14, 2011, if the methods exist to make it feasible, the most amount of lead able to be contained in these products will be 100 ppm. Under this law, manufacturers, retailers, and importers can all be held liable.

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California Regulations

California has led the charge in more specific regulation to protect the safety of their residents; some other states have followed with similar laws of their own. It is important that manufacturers and distributors be familiar with all applicable laws in all states in which their product(s) will be sold.

A. Tableware Safety Law
This law prohibits the sale of tableware that leaches lead and/or cadmium in excess of the levels noted in the FDA guidelines.

B. Proposition 65
The Safe Drinking Water and Toxic Enforcement Act requires that tableware leaching lead in excess of the standard set forth by the regulation have proper warnings when they are sold or displayed. The manufacturer must inform retailers when warnings are required and provide the appropriate signs. Warning notices are required of lead leaching in excess of 0.226 parts per million for flatware and 0.100 parts per million for hollowware, cups, mugs, and pitchers. All products that may contain harmful substances under these definitions are required to have a warning placed on them, using the language specified in the details of the act itself. Any private citizen of California or the State of California herself can enforce this law.

Related links:
California Childhood Lead Poisoning Prevention Branch: Lead in Tableware
Business & Legal Reports: Proposition 65

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Regulations and safety concerns have initiated the research and development of safer decorating methods with inks free of lead and other heavy metals. Heinrich Ceramic Decal is proud to be a leader in this technology and offers completely heavy metal free color palettes for both ceramic and glass decoration.

As always, our decals are screen printed with ceramic oxides, which you or your decorator apply to the piece and fire in a kiln. The result is a high quality, permanent decoration. Heinrich is committed to following all regulations for environmental concerns and legal compliance.

We are prepared to work with you to develop the best possible decoration for your project. Heinrich is happy to share our knowledge with our customers; please remember that specific regulatory requirements are dependent on a number of factors and the responsibility of meeting them is with the manufacturer of the final product.

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Media Coverage of Lead Safety Concerns

Below are links to news stories, articles, and other media coverage of lead safety concerns. Please let us know if you have additional links that may be of interest.

May It Please the Court Legal WebLog, Newport Beach, CA:
Deal to Pay Defense Firm Out of Plaintiff's Prop 65 Settlement Pending Before AG