The European container glass industry expresses deep concern about the notified Danish legislation introducing national limits for lead (Pb) and cadmium (Cd) migration from food contact materials, including glass.
While we fully support the objective of ensuring a high level of human health protection, we regret that this measure introduces unilateral migration limits for glass. This national initiative risks creating fragmentation of the Single Market, with negative implications for the free movement of goods and significant compliance burdens for manufacturers. Companies placing glass packaging on the EU market may now face multiple and potentially conflicting national rules, undermining legal certainty and increasing testing and documentation requirements. This runs counter to the European Commission's commitment to 'better regulation' and reducing administrative burdens, instead creating new red tape that hinders economic activity across the Single Market.
Importantly, the European Commission has also committed to reviewing the EU FCM legislation and has recognised the need for harmonisation of materials such as glass. This means that a harmonised EU legislation for glass as a food contact material is currently under discussion at EU level. The container glass industry has long called for the development of harmonized EU-wide rules for glass to ensure free movement of goods, reduce administrative and testing costs and give certainty in the value chain.
In this context, Denmark’s decision to pre-empt this process and impose national limits is premature and risks undermining ongoing EU efforts to establish a coherent regulatory framework. We therefore urge:
- The European Commission to assess the Danish measure in the context of the EU’s Single Market rules and consider appropriate action under the TRIS procedure
- The Danish government to reconsider the adoption of national migration limits for glass and to work constructively within the EU framework towards a harmonised solution that preserves the internal market.
- EU Member States to refrain from adopting diverging national rules while harmonised EU measures for glass are under development
We remain committed to engaging constructively in the development of EU-wide rules for glass and reiterate our call for a harmonised framework based on scientific evidence, legal consistency, and market unity.
