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When looking for safe cookware products it is good to be aware of all safety regulations that certain utensil complies with. In this post, I would like to present you safety regulations in different countries and tell you more about how they can help us find safer cookware products.
One of the important points that I want to highlight through this text is a huge gap that exists in the US regulations related to the safety of everyday items, including cookware. Additionally, this post will compare EU end US regulations so you will be able to see some important differences.
Regulations in the US
Since 1976 Federal law called the Toxic Substances Control Act of 1976 (TSCA) governs toxic substances used in everyday products.
TSCA only excludes foods, food additives, cosmetics, drugs, pesticides, tobacco, radioactive materials, and wastes. These products are regulated under specific acts such as the Federal Food act, Drug act, etc.
The safety of products apart from these specific categories is evaluated by Environmental Protection Agency(EPA) by following TSCA rules. This also applies to cookware safety. However, there is one important thing to mention here.
While different substances used in specific products such as drugs need to be tested by companies through standardized procedures, before applying for their authorization, testing off all of the other non-specific products all rely on the limited resources of EPA.
Let’s take an example and look at how this process of EPA authorization works. Additionally, let’s see what are some of the important omissions that are happening in this procedure.
If e.g. a cookware company wants to introduce a new substance for an application in non-stick coatings for cookware there is only one thing that it needs to do according to TSCA. It should submit the paper called Pre-Manufacturing Notice(PMN) to the EPA before starting the manufacturing process. According to Section 5 of the TSCA regulation, the company is not obliged to provide safety information for the new substance before and provide it in PMN. Finally, EPA is the one that needs to do all of the tests.
But why that is a problem?
Well, EPA has only 90 days from receipt of pre-manufacturing notice to test new chemicals before it can be legally marketed and included in products.
During this period only a small part of acute toxicity and mutagenicity testing can be completed. Additionally, when it comes to testing of long-term effects (e.g. neurotoxicological, developmental, reproductive, and chronic) no relevant data could be generated for such a short period.
Because of the number of applications and time-limiting conditions, EPA could not generate solid experimental conclusions and it mainly rely on computer modeling of substance toxicity to make some conclusions.
From 1979 to 1994 the EPA OPPT’s new chemical program received over 24000 PMNs. From that number, they force the postponing of the manufacturing process and require additional data for only 5000 of those submissions. Today thousands of chemicals used within the USA manufacturing system don’t have any experimental data about their health effects!
This kind of regulation triggers the question of potential negative effects caused by all of the everyday items around as, as well as cookware.
Regulations In the EU and their impact on cookware safety
Now, let present more information about EU safety standards and what sets them apart from the US laws.
Within the European Union, there are some important regulations related to Food Contact Materials(FCMs) that refer to all member countries. Additionally, there are country-specific rules that additionally secure the safety of cookware produced and sold there.
Unlike the US where all of the testings of new chemicals really on government bodies, in the EU companies are the ones who need to do detailed safety experiments before submitting any application to the authorities.
Furthermore, when some cookware production company from countries like Germany or France wants to bring a new product to a market, it needs to submit a specific paper called Declaration of compliance (DoC) to government bodies. In this document, the enterprise is obliged to clearly show cookware safety according to not just general EU regulations, but also strict national laws. The same rule applies to all other items in everyday use.
Now let find out more about some important standards in the EU and how they protect customer safety.
EU regulative 1935/2004- General safety requirements for all Food Contact Materials(FCMs)
This is the regulative common for all EU member countries. Within its lines, it gives universal rules that need to be followed for all Food Contact Materials and items ( cookware, packaging, storage containers..) that are sold on the EU market.
The core of EC 1935/2004 can be explained through the following lines:
,,Materials and articles, including active and intelligent materials and articles, shall be manufactured in compliance with good manufacturing practice so that, under normal or foreseeable conditions of use, they do not transfer their constituents to food in quantities which could” :
(a) endanger human health; or
(b) bring about an unacceptable change in the composition of the food; or
(c) bring about a deterioration in the organoleptic characteristics thereof.
The labeling, advertising and presentation of a material or article shall not mislead the consumers.
But wait, what does it mean to endanger human health? Is there any rule that specifies this better? Where is the list of forbidden substances or maximal leaking limits for some molecules present in cookware-specific materials?
These details are revealed in separate EC1935/2004 amendments. For most of Food Contact Material, there is a specific amendment, including ceramics, silicones, plastics, ion-exchange resins, paper and board, printing inks, regenerated cellulose(cellophane) and a few others.
These documents define precise rules about which substances are forbidden or limited for mentioned material types. For instance, the amendment regarding ceramics gives clear directions about heavy metals and their maximal leaking amounts. The amendment for plastics states a list of allowed and forbidden plastic additives etc.
Finally, all of the amendments have the reference list of scientific studies which are used to define all of the limits. This can be very useful for additionally checking all of the information.
But who is evaluating the existing scientific studies and providing the opinion that is used to form regulations? Additionally, how relevant that opinion is?
One of the main stakeholders in providing the scientific data and expert opinion, about what is harmful to health is the European Food Safety Authority(EFSA). Such a system provides great relevance to all of the regulations.
EFSA is an EU agency that provides independent scientific advice and communicates on existing and emerging risks associated with the food chain, including cookware safety.
The agency consists of more than 500 world-leading experts in the food sector including scientists and experts dedicated to law regulations. Such an organization secures that there is solid scientific data behind all of the existing regulations in the food safety domain.
EC 1935/2004 Vs US regulation, what are the important differences?
After defining what EC 1935/2004 is and which authorities stand behind it let’s compare it more closely to the US system.
Unlike the regulations in the US, the regulative EC 1935/2004 differs in a few important aspects, which significantly contribute to cookware safety standards in the EU.
In it articles 19. And 20. of EC 1935/2004 issue that companies are the ones who need to rigorously test the new substances before they can enter the market of Food Contact Materials (FCM).
This procedure can last up to one year for each chemical and the company needs to submit detailed results of toxicological studies to the European Safety Authority. Based on that EFSA gives its opinion, after which the EU commission decides should the substance enter the market or not.
The procedure is the same for all of the FCM producers including cookware manufacturing companies. This helps to ensure high cookware safety standards.
So, in comparison to the US, in the EU, companies are the ones that are making the documentation behind substance safety which requires time, money, and effort. This pushes every enterprise to think twice before they start the process of material validation.
Finally, all of the information about substance safety facts and EFSA’s opinion about it become publicly available. You can perform short research on Google for this information by using the name of a substance you are interested in(or the family of substances to which it belongs) and the keyword “EFSA opinion”.
The story about introducing new chemicals is especially important for the industry of plastics, silicones and resins used as Food Contact Materials. Such industries introduce new additives and materials quite often.
*It is good to notice that these regulations don’t affect just cookware safety, but also protect customer’s health in the case of all the items that are intended to come in contact with food. This includes cutlery, cutting boards, food processing machines(e.g. mixers), packaging, storage containers, etc.
EU regulation EC 2023/2006- How manufacturing standards ensure cookware safety and quality
This EU regulative, just like the previous one, applies to all EU countries and Food Contact Materials sold on the EU market. It pushes all of the companies to use Good Manufacturing Practices(GMP) in the production process to ensure the high quality and safety of the final products.
Let’s give a quick example of how this works. Additionally, let’s explain what are the GMPs and how they contribute to the cookware safety and protection of consumers.
We can take an example of iron-based Food Contact Materials(FCMs). This includes e.g. using the iron for cast iron cookware or food cans. In this and many other industries, you will find different professional associations and institutes that publish the latest standards and practices that should be applied to the manufacturing process.
In the iron FCM industry such standards can include limitations for impurities in iron alloys, the proper melting and molding process that will ensure the best longevity of products, etc.
Additionally, such guidelines define methods that should be used for monitoring the final quality of products. This could include procedures for measuring the cookware wall uniformity or pressure that cookware can withstand. Also, such guidelines define how often the production line should be controlled.(e.g. checking the quality of every tenth piece of cookware that is produced)
All these rules within GMP guidelines help to ensure the cookware’s safety and quality at the end of the production process. Finally, EC 2023/2006 pushes the products to stay along the most updated GMPs and thus follow the best advice from international experts.
How EC2023/2006 and EC1935/2004 regulations act together
Mentioned two directives are the foundation of EU cookware safety regulations. So, to fulfill the picture about laws in Europe it is good to see how they function together in practice.
As already mention EC1935/2004 amendments regulate the properties of cookware products in a way that doesn’t affect health, food composition, or organoleptic properties. These amendments exist for materials such as ceramics or plastic, ceramic or silicone-like already mentioned. In addition, some EU countries have to supplement laws that regulate materials not covered by EC1935/2004 amendments.
However, there are materials for which safety is not specifically regulated by EC 1935/2004 amendments nor the particular country regulations. Metal alloys can be one of the examples.
This is where EC 2023/2006 comes on to a scene. This regulation issues the good manufacturing for all Food Contact Materials including the ones that are not covered in the mentioned regulations (EC1935/2004 and national ones).
So, if the cookware is sold on the EU market it guarantee that it is produced under high safety? In the end, it needs to comply with strict directives such as EC1935/2004 and EC2023/2006?
Unfortunately, this is true only on paper for some EU countries.
Even it is expected from all of the companies to comply with EC2023/2006 and Good Manufacturing Practices to ensure product safety, in some EU countries the government bodies do not evaluate this.
The same conclusion was made by a detailed EU study that aims to evaluate the current status of Food Contact Materials regulations in Europe.
So, when you are looking for safe products, it is not just important that they are produced/sealed in the EU, but also in which counties exactly.
Some countries like Germany and France strictly evaluate the compliance with EC1935/2004 and EC2023/2006 which additionally ensure the safety of cookware products that appear on the market of these countries. Furthermore, they own specific regulations that add up on EU general ones.
Country specific regulations
Germany-Cookware safety regulations
One of the states that not just expect good manufacturing practices compliance from companies but also evaluate this in practice is Germany. On the German market, every cookware producer needs to specify the GMP that it uses in the document called Declaration of Compliance(DoC) before it establishes a new product to the market.
Each DoC needs to pass the evaluation of the federal state commission before it is taken under consideration for entering the market. This is one of the reasons why I usually take the products that are sold/produced in Germany as a good reference system for cookware safety and quality.
However, when it comes to this country and good safety standards this is not the end of the story. Good Manufacturing Practices applied to products that exist on the German market are one of the best in the EU and further. But, let’s explain this in more detail.
Good manufacturing practices(GMPs) in Germany
In different EU countries, GMPs that refer to the same material can differ one from another. During my research about safe cookware, I wanted to specify which countries require the compliance with most strict GMPs.
To get more information about German GMPs I was directly contacting BfR agency and BVL office. The first one(BfR) is the German Federal Institute for Risk Assessment while the second one presents the federal office of consumer protection and food safety. Additionally, I was using information available on web pages of different government offices.
Through this research, I have found that Germany requires the application of very comprehensive GMPs issued by well known international authorities such as the Council of Europe(CoE) or mentioned German Federal Institute for Risk Assessment(BfR)
For instance, in the case of metal cookware Germany require that enterprises comply with CoE resolution CM/Res (2013)9 as a GMP reference. This resolution issues the limits for leaking of 15 different metal ions to secure the cookware’s safety, which presents a comprehensive measure for preventing any negative health effects.
Additionally, mentioned limitations are based on studies and data that fully comply with the scientific information that I have.
The regulation about methal cookware is just one example. But, it generally reflects the good standards that I have found throughout German regulation of different cookware materials.
France- Cookware safety regulations( DGCCRF declaration)
Just like in Germany, France requires cookware companies to submit their Declaration of Compliance(DoC). Within these documents, companies need to show which GMP they have used in the production process, together with product composition data and existing migration levels of different components.
As it is already mentioned, some of the countries have supplementation of EU general rules regarding Food Contact Materials. In France, there is one comprehensive document that unifies the regulations on different FCMs in one place. ( DGCCRF regulation)
This law covers some supplementary precautions that don’t exist In the EC1935/2004 amendments. It covers materials like glass, ceramic, plastic, and especially metal alloys.
One of the examples of high safety requirements issued by this law can be stainless steel(SS). All food contact SS in France is made from several methal alloys specifically de find for such purposes.
Furthermore, the list with allowed alloys doesn’t just include their compositions but also the levels of potentially trace elements. Such rules prevent the presence of harmful contaminants such as lead or cadmium, which can be harmful even in small quantities.
Additionally, this document clearly specifies the testing methods and metal migration limits for cookware sold on the French market. This very comprehensive regulatory approach is also present in the case of other mentioned FCMs(ceramics, plastics, silicone..)
Finally, provisions presented in DGCCRF don’t just broadly apply to specific FCMs, but they clearly target the application of materials and adjust the specific limitations for each of them.
For instance, steel can be used in the production of cookware, cans, storage containers… For each application, GGCCRF adapts the composition/production rules in order to ensure full product safety.
Such comprehensiveness of national regulations and application of general EU rules in practice ensures the high safety of cookware produced and sold in France.
Cookware recommendation page- safety marks
As a part of Safetouseit, you will find the product recommendation page. There I will provide you with some useful directions on how to search for safe cookware alternatives that best fit your needs.
This page also includes cookware brands and models that can help you with finding what you are searching for. However, before presenting you any of the utensils on the website I took several comprehensive steps in analyzing their safety. (Find all of the steps on the Cookware recommendation page)
One of the important aspects includes considering the safety certification and standards that cookware brands possess.
In the following text, you will find cookware safety marks that I have used to present the safety regulations that each cookware model fulfills. All of the safety marks are based on the info regulations in this post.
Marking the cookware that complies with EU standards
On Safetouseit cookware recommendation page, you will be able to find companies that comply with general EU cookware safety standards and thus have the approval to sell their cookware on the EU market. Such products are marked with the following sign:
This sign indicates compliance with general EU directives like EC2023/2006 and EC1935/2004 explained earlier in the post.
Apart from the general EU compliance mark, you will find safety marks based on rules in specific EU countries (France and Germany). These countries push the cookware producers to strictly comply with existing EU marks. Additionally, they have their own additional cookware safety requirements which help with protecting customers health on a high level.
For indicating country-specific regulation compliance I have used the marks presented below.
Marking the utensils that comply with German cookware safety standards
Within the product recommendation page, you will be able to find producers and utensils that have passed German cookware safety standards. Such products are marked with the following sign:
Marking the utensils that comply with French cookware safety standards
A similar style sign you will find for producers and utensils that have passed French cookware safety standards. Such products are marked with the following sign:
California Proposition 65 compliance
In addition to the EU-based marks. Some of the companies pass other certification procedures.
One of the important ones is compliance with California proposition 65. This regulation was developed by the Office of Environmental Health Hazard Assessment(OEHHA) in California. California 65 proposition targets use limitations for around 900 chemicals scientifically proven as bad for human health.
The proposition issues the leaking limits of certain chemicals and prohibits the use of others. All of the data rules presented by Proposition 65 are supported by the number of research studies that are clearly listed.
I found the information provided by OEHHA very comprehensive and in accordance with the scientific publication that I have.
Because of this, I take compliance with California Proposition 65 as an important criterion for evaluating cookware safety. Every product that passes such a standard is marked with the following sign:
FDA rules compliance
In certain cases, Food and Drug Agency provides some safety certificates that can be applied to Food Contact Materials. One of such certifications covers the limitation for the leaking of heavy metals from the cookware.
Certain Cookware manufacturers like Ceramic cookware producer Ceramcor applied for such approval from FDA. Because of that, you will find the following sign next to Xtrema cookware models.
Independent lab testing certificate
Some of the brands on the market take one step further and undergo testing even if the national regulations don’t require that(THe case in the US).
The aim here is to provide some relevant proof and guarantee additional safety precautions for customers.
An example of that can be testing of the ceramic-derived utensils to show their mineral composition and absence of heavy metals such as lead or cadmium.
The brands that clearly present the results of such testing on their website and indicate the reference laboratory have the mark:
