The Danish Veterinary and Food Administration has told trade bodies that it expects the new order to enter into force on 1 January 2027, with a six month transition for the new lead and cadmium limits in ceramics, glass and enameled articles. It has also said it intends to add a general exemption so that food contact materials produced, marketed or used as packaging before 1 July 2027 can keep being sold until stocks run out. The final draft has not been published, so none of those dates is fixed yet.

The revised draft splits the dates by article rather than describing a general transition period. The general provisions, including the declaration of compliance and the ban on PFAS in paper and board, apply from 1 January 2027. The lead and cadmium limits in Annex 5 and the rule on lidded containers apply from 1 July 2027. Food contact materials lawfully placed on the market or used as packaging before that date may keep being sold until stocks run out.

That leaves a gap worth using. The old order applies now, but the direction is set and the revision will not be withdrawn. A specification or a decoration choice changed in 2026 costs a fraction of the same change made in a hurry during a transition window.

The limits in force today

Under Order No. 681, ceramic, enameled and glass articles are tested against three categories, and the figures are expressed in milligrams. Glassware is pulled into the same table as ceramics, which surprises buyers who assume the order is about pottery.

The mouth rim requirement already exists in the current order: release from a 2 cm band along the upper edge is tested inside and outside. The draft replacement keeps that idea and restates it in different units, which is why a rim test cannot be treated as optional either before or after the change.

The unit changes from milligrams to micrograms

This is the change most likely to produce a wrong conclusion. The draft sets its limits in micrograms per square decimeter and micrograms per liter, while the order in force uses milligrams. The numbers therefore look about a thousand times smaller before any tightening is considered, and a report that is not read against the right unit will either alarm you or reassure you for the wrong reason.

Converted for comparison, the current Category I figure of 0.8 mg/dm² is 800 µg/dm², against a draft figure of 0.3 µg/dm² for the equivalent Category A article. The current 4.0 mg/l is 4,000 µg/l, against a draft figure of 2.0 µg/l for other fillable articles. Both readings say the same thing: this is a large tightening, not a rounding change.

The draft limit table

These are the values in the notified draft. The April 2026 consultation and the revised draft that follows it may still move them, so treat the table as the direction of travel and re-check against the published order before a purchase order depends on it.

The rim band and the lid split survive into the new text

Two measurement rules carry over and become harder to satisfy at lower limits. Migration from the mouth rim is measured on a 20 mm band from the top edge of an article intended for drinking, and a drinking article has to satisfy both the rim requirement and the body requirement. Separately, where a container is fitted with a lid, the limits apply to the container alone, and the container and the inner surface of the lid must be tested separately under the same conditions and then added together.

Both rules point at the same part of a glass program. Gold banding, colored enamel and decal decoration sit on or near the rim, which is exactly the surface the rim test isolates. A piece that clears the stricter limit on the body can still fail on the rim, and a jar that clears it on the body can still fail once the lid inner surface is added in.

The declaration of compliance becomes a shipping document

The draft keeps the requirement that food contact materials marketed before the retail stage carry a written declaration of compliance. The draft annex lists what it has to contain: the issuing business name and address, the identity of the article, the declaration date, confirmation of compliance with the order and with Regulation (EC) No 1935/2004, and, where relevant, the intended food types and the time and temperature of contact. A declaration missing those fields is not a valid one, whatever letterhead it carries.

The quotation price does not move under this order. The document set and the test report do. That is where a Danish program either clears or stalls.

Our glass drinkware and tableware and kitchen ranges are already tested against the migration limits our European buyers specify. Where the certificate set is the deciding factor on a program, the MOQ and document set guide sets out what a factory issues and when.

The analytical method the draft keeps

Annex 6 of the draft keeps the method the current order already uses. The extraction is 4% (v/v) acetic acid, freshly prepared, at 22 ± 2 °C for 24 ± 0.5 hours. Fillable articles are filled to within 1 mm of the overflow point, or within 6 mm along a flat or sloping rim. Mouth rim release is tested by immersing a 2 cm band along the top edge. Because the method is unchanged, an existing report can be set against a new one, which makes a re-test a controllable step rather than a leap.

Two further provisions in the draft sit beside the glass rules rather than inside them, and both reach the same purchase order through retail packaging. PFAS are banned in paper and cardboard food contact materials, with two exits: the material is already regulated under Regulation (EU) 2025/40, or a functional barrier prevents migration into food. Vinyl chloride must not be released at detectable quantities, with a detection limit of 0.01 mg/kg determined by headspace gas chromatography. If your retail carton, label adhesive or insert uses coated paper, that part needs its own answer from the packaging supplier.

Where a program involves rim decoration or a lid component, the custom decoration and OEM program is where the specification is agreed, and it is the right point to decide that the rim area is tested as its own surface rather than after a failed report.