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European "Food safe" regulation

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I never made objects that are intended to contact with food, like tableware. But since I'm planning both to expand  my production range than upscaling a little bit my tiny buisiness, I've been hitted by some posts that rightly mention "food safe regulation"... 


Since I live in Europe and regulations could differ a lot from US and EU I only hope that some Europeans that read could help me, because I don't know who knows anything about this matter and, being a non-professional, I can't ask for informations to craftsmen associations... On-line material is unuseful.


 My understanding is that is not not enough to use materials (clays, glazes) that are stated to be "food safe" or lead free glazes and so on... In addition my understanding is that the (tableware) producer must draw up and keep some documentation that demonstrates how he has made sure that his products are food safe. Also some "releasing tests" appears to be involved...


Really to make and sell a couple mugs (maybe an hoobyist like me that sells sometime is some small country fair) does is needed all this procedure?

 

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Damn, what a mess! :wacko: Thank you al lot @Sputty... it will take a lot of time to find the courage to face all this legislation!! Probably in a few weeks I'll ask you for more clarifications ... but not before!:D  

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I'm convinced of the fact that all Americans who read these things will find all very odd... Because all this stuff is very very European!! So bizarre, convoluted and complicated ...

I've just taken a look at the huge maount of directives and decrees (3 EU regulations, 2 EU directives and 2 Italian Ministerial Decrees!!)...

In Italy the situation seems to be the same as France. Unlike UK I have found no trace of any guidance, memorandum, and something else that mentions "craft potters and one-man operations"... Incredibly I can't found any comment or post in any forum or other... this is very strange because in Italy is full of craft potters (not in my city!) and I can't believe that nobody is concerned about all this mess...


The absurd thing is that everything appear to have been thought only for industries, because it's true that is told that everything must be scaled in order to avoid  excessive burden for small companies, but at the same time the directives appears to require some "management system" in order to ensure traceability of materials... So, should craft potters be certified ISO 9001?!?!?? Probably not, but...


The most absurd thing anyway for me is the fact that everywhere is mentioned the "company". It is given for granted that the pottery "producer" is a "company". Also a one-man operation is a company and this is ok... but what about people like me that are allowed to partecipate to some country fair and sell something on occasional basis without having a VAT number? For my little and negligible business I don't need to be enrolled in the "chamber of commerce" and  I don't need to have a "company"... Does all this regulations and decrees apply also to me ot not? If yes (and I think it is) how it applies to me?(I don't expect that somebody answers to those questions...)  As always, when it comes to dealing with the EU\Italian law, the mystery deepens ...!!!

Two things for @Sputty... First: I find that clarification in English by far more understandable  that italian political jargon!! :lol: Second: I think that UK potters will comment "let's go with Brexit!!"

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11 minutes ago, Sputty said:

There's a moratorium on political conversation on this forum

I'm sorry, my comment were intended only as a joke. I would never want to go into this speech first. This in general, much less here...

Anyway I  admit that my post was very (maybe to much) controversial with the law, but only with the fact that it looks to be very disheartening for small craft potters. Nothing to complain with the right necessity to protect people from poisoning (and in this way I also appreciate the intent of the law) but personally I'm only discouraged of  not being able to understand how I could be compliant with the law in my case (and I think in the case of many craft potters) or at least by the fact that it appears so complicated,  and I'm afraid I cannot have the resources to be compliant. This not exactly because of the law itself, but (mostly) because are missing easily available clarifications and clear explanations about the real practical impact.

Anyway once uderstood what I have to do, and how, and once understood that it's not so complicated as it appears at first glance, I wuold very happy to be compliant... and yes, I would feel even better too, because I would be 100% sure to offer a safe product, given that I give it especially to my friends...

37 minutes ago, Sputty said:

That is painfully clear when trying to unravel the mess that member states have made of implementing what should be a straight-forward Directive such as the one we're discussing here.

For once, Italy has adopted the directive without distorting it!  :PThe Italian decrees are a copy and paste of the directives ...

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31 minutes ago, Sputty said:

The one French language pottery forum I sometimes look at has the occasional post asking about the issue, where everyone piles in with different opinions, and then it all goes quiet as people drift away, none the wiser. Probably just like this thread, come to think of it!

 

That's something! The only Italian Language pottery forum  I know is technically dead... it's not a case that I'm writing in a forum that is intended to be international but is basically US born...

 

31 minutes ago, Sputty said:

The situation in France, as far as I can judge without interrogating others too deeply, is that generally craftspeople have ignored the legislation

This is also my impression (only an impression, I admit) for Italy...

31 minutes ago, Sputty said:

Anyway, I'm going to get a pot tested in the New Year! We'll see how the process works...

This is very interesting! It would be a very precious thing to have a firsthand witness about how it does actually works! I don't think that in this case there will be deep differences between Italy and France ... Let me know, please!

 

Edited by andros

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I think there is no legal term for food safe just lead and cadmium legislation possibly barium too. The rest is a very grey area and the metal oxides are probably much more dangerous to the potter than the end user. I can easier imagine a law suit over something breaking than leaching metals.

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Doing a bit of searching I came across this from 2016 http://publications.jrc.ec.europa.eu/repository/bitstream/JRC102075/report ceramic_rev04_2016_12_22-cs_ reg.pdf

Not made it all the way through but seems useful, they still mention there is yet to be any limits put on anything other than lead and cadmium but there could be at some point.

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One thing is not so crear to me... maybe because I'm little dummy or I paid insufficient attention, but...(I'm referring to the test report found by @High Bridge Pottery Pottery) Hollow articles appeared to be tested in the interior, i.e. they are filled with acetic acid or another test liquid ("The articles were filled with the test liquid to a level no more than 1 mm from the overflow point").  But at p19 also the external surface appears bitten... This is something that is not so clear (to me) also in the EU directives. Do only the internal parts that are destined to contact food need to be tested? Could I (for example) make a mug externaly lead plated but with a safe glaze inside?

Another thing... should I test every single shape I'm going to make? Does is not sufficient to test the couple clay-glaze fired at a given temperature? I don't think that there is significant difference between a mug or a bowl if produced with the same clay and same glaze...

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Just above the picture they say it is calcium carbonate, not sure why it looks like that but they are only filling the inside. 

Quote

several samples showed cracks on the surface and presence of calcium carbonate, as is shown in figure 3

I think you are right that you only need to test the glaze and not every shape of pot. Can't hurt to test a few different shapes. You only have to test if you use lead or cadmium. Looking at the results the only other thing to worry about is cobalt. Need to find some time sit and read it all.

It is interesting to note how much the values drop by the 3x running the test.

Edited by High Bridge Pottery

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@High Bridge Pottery, I skimmed through the link you posted and couldn't see any information on the firing variables of the ceramics that were tested. There is nothing other than colour, overglaze, and size information given.  No info on whether the ware is low fire earthenware or mid or high fire and if all glazes are gloss, they appear to be but could be camera flash on some. Dr Carty states firing temperature plays a role in how much a glaze leaches as does matte versus gloss. The decrease in leachable materials with subsequent tests also corroborates what Dr Carty found with copper glazes. Vapour condensing from the glaze depositing on the ware that can be washed off with hot soapy water, if this is done prior to testing the leaching figures he published are significantly lower. pages 35-36 of this. Perhaps that is happening with the other metals.

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4 hours ago, Min said:

couldn't see any information on the firing variables of the ceramics that were tested.

I think  that this due to the fact that the aim of the EU document was primarily to "develop adequate methodologies for testing these articles"  insted of make a methodic study about how metal leach s changes as the boundary conditions change... this is something that can be interesting for us (and in this way I will find much more time to study the interesting material posted by @Min. It's the potter that should be interested on how to avoid excessive metals leach. It is sufficient for the legislator to set thresholds that make sense ... isn't it?

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Is anyone here aware of the recent EU consultation on whether or not to require the use of an indelible mark (e.g. stamped symbol) on ALL ceramics that might be used for food to permanently identify whether it complies with the safety standards?

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1 hour ago, Sputty said:

The intention is that a detailed technical consultation will happen in 2018, followed by a regulatory package.

I read online also some rumors (also from Higher Institute of Health  members! This in some presentation made for ceramic industry) obut a revision of the directive itself... At least here the result of such a things is that nobody does nothing waiting futher developments... Anyway if something of more detailed for artisanal pottery will follow, for me is well accepted!

Anyway a lot of very interesting and useful stuff from all of you! ;)

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