The Benelux Committee of Ministers Decision M (2024) 5 has driven updated regulations across Belgium, the Netherlands, and Luxembourg to significantly tighten the specific migration limits for lead and cadmium in ceramic food contact materials (FCM).
These synchronized national updates replace older, less restrictive limits under EU Directive 84/500/EEC and officially took effect on May 29, 2026.
Who is impacted?
The amendment affects stakeholders across the food contact ceramic materials and articles supply chain, including manufacturers, importers, retailers and other intermediaries operating in Belgium.
New Specific Migration Limits (SML)
The Benelux countries have categorized maximum allowable lead and cadmium migration by article type and depth stated in the following table
| Category | Product Type | Cadmium (Cd) | Lead (Pb) |
| Category 1 | Flatware and shallow articles (depth ≤ 25 mm) | ≤ 4 μg/dm² | ≤ 6 μg/dm² |
| Category 2 | Other fillable ceramic articles | ≤ 20 μg/L | ≤ 30 μg/L |
| Category 3 | Cooking ware, storage vessels and packaging containers (>3 L) | ≤ 7 μg/L | ≤ 10 μg/L |
Status for implementation
| Country | Implementation Measure | Effective Date |
| Belgium | Royal Decree of 19 July 2026 | 29 May 2026 |
| Netherlands | Ministerial Regulation of 23 April 2026 | 29 May 2026 |
| Luxembourg | Grand-Ducal Regulation of 19 May 2026 | 29 May 2026 |
CMA Testing offers a comprehensive range of services to help manufacturers, importers, and retailers comply with the latest Benelux requirements for ceramic food contact materials:
- Lead and cadmium migration testing for ceramic food contact materials
- Compliance assessment against the latest Benelux regulatory requirements
- Regulatory consulting for food contact materials (FCMs)
- Technical documentation and Declaration of Compliance (DoC) review
- Product inspection and factory assessment services
Useful link for this regulation: https://legilux.public.lu/eli/etat/leg/rgd/2026/05/19/a252/jo
