GPSR risk assessment example: Hand-thrown ceramic mug

⚠ Red flags found for this product

• FOOD-CONTACT LEGISLATION APPLIES: this mug is a food-contact material. - Regulation (EC) 1935/2004 and Good Manufacturing Practice Regulation (EC) 2023/2006 apply. - Ceramics Directive 84/500/EEC (as amended by 2005/31/EC) also applies, as implemented in DE, FR and IE. - The Ceramics Directive sets lead and cadmium migration limits. - It also requires a written Declaration of Compliance (DoC) backed by test results. The DoC must accompany the product up to and including the retail stage, and the supporting documentation must be available to authorities. - The EU has been revising the lead/cadmium limits, so check for any updated, stricter limits applicable at the time of sale. - GPSR applies alongside this legislation only for aspects not covered by it, such as mechanical and thermal risks.
• The glaze supplier's 'food safe' label is NOT sufficient evidence on its own. Lead and cadmium release depend on your clay body, glaze thickness, firing temperature/schedule and kiln atmosphere. Without a lead/cadmium migration test on your own finished mugs (EN 1388-1 / ISO 6486), you cannot issue the required Declaration of Compliance. Until you have it, the mugs should not be sold into the EU as food-contact items.
• Manufacturer is in the United Kingdom (outside the EU). Under GPSR Art. 16, a responsible economic operator established in the EU must be appointed before selling to DE, FR and IE. Its name, postal address and electronic address must appear on the product, packaging, parcel or accompanying document, and in the Etsy listing. Northern Ireland follows EU rules on goods; check if relevant.
• Do not advertise the mug as 'food safe', 'microwave safe', 'dishwasher safe' or 'oven safe' unless you hold test evidence on your own finished mugs. Misleading claims create both safety and consumer-law liability.
• If any decoration uses metallic lustres (gold, platinum, copper), coloured oxides or underglazes, or third-party decals on the rim or inside, test them specifically. Metallic decoration also makes the mug unsuitable for microwaves.