Legislation

What a potter making ceramics intended for contact with food needs to know.

A good and trustworthy potter is familiar with the legislative requirements and introduces them meaningfully and successfully in their work.

Ceramic products intended to come into contact with food

Ceramic products made of clay can be intended for decoration or for use. If a ceramic product is used in the food sector, it must be produced in accordance with the provisions of the applicable legislation for the food contact. It sets out traceability and labelling requirements and provides the basis for the declaration of compliance. Operators who place products on the market must first comply with the provisions of the legislation regarding good manufacturing practice.

Compulsory registration of operators

All companies/operators who manufacture, import, process or who are first to put products intended to come into contact with food on the market must register with the Health Inspectorate of the Republic of Slovenia.

Good manufacturing practice

The operator must establish a documented quality system that includes monitoring of the implementation and achievement of good manufacturing practice, and remedial actions. The operator must ensure that the production processes are carried out in accordance with the legislative rules.

Traceability

The traceability of products must ensure effective control, easier withdrawal of non-compliant products, consumer information and transparent attribution of liability. It is important to establish the following:

traceability to the supplier/producer of raw materials
traceability in the process of storage and production
product traceability to a business partner

Product labelling

Products must be labelled with the product name or a brand name of the product, name, address or registered office of the manufacturer or seller, the text “food safe” or the food contact symbol, the identification number for material traceability (e.g. LOT/series) and, if necessary, also with the instructions for safe use. At a retail sale, the data must be presented on:

the products or their packaging, or
labels applied to products or their packaging, or
a notice in the immediate vicinity of the products that can be clearly seen by customers (this option is only applicable in cases where this information cannot be provided on products for technical reasons).

Declaration of compliance for ceramic products

In the marketing stages, ceramic products intended to come into contact with food must be accompanied by a written statement prepared by the product manufacturer. It must contain:

the identity (name) and the address of the company that manufactures the final ceramic product,
the identity of the ceramic product,
the date of declaration,
the declaration of the ceramic product’s compliance with the requirements of the Rules on ceramic materials intended to come into contact with foodstuffs (OG RS 38/06) and EC Regulation No 1935/2004.

Product withdrawal/recall from the market

The company/operator must develop a process of product withdrawal/recall from the market, including the manner of informing suppliers, purchasers and competent inspectors in order to immediately establish an effective withdrawal/recall of the non-compliant product from the market. If the operator/company that manufactured, imported, processed or first placed the product intended to come into contact with food has reason to suspect that the product does not comply with the legislation, it shall immediately initiate the withdrawal procedures.

Consideration

Legislation in the field of materials intended to come into contact with food covers a wide range of different categories of food contact materials but does not distinguish between large (industrial) productions from small traditional or unique productions. However, regardless of the size or mode of production (perhaps also because of a potter’s goodwill), legislative requirements can always be reasonably introduced into the production process. Therefore, Eva states: “A good and trustworthy potter is familiar with the legislative requirements and introduces them meaningfully and successfully in their work.”

Literature

Regulation (EC) No 1935/2004 of the European Parliament and of the Council of 27 October 2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC.
Commission Regulation (EC) No 2023/2006 of 22 December 2006 on good manufacturing practice for materials and articles intended to come into contact with food.
Rok Fink, Eva Bičič, ‘Materiali in izdelki namenjeni za stik z živili’, in Higiena objektov in procesov, ed. by Mojca Jevšnik (Univerza v Ljubljani: Zdravstvena fakulteta, 2017), pp. 183–195.
Decree on obligatory registration and treatment of companies who produce, process and first place materials and articles intended to come into contact with food into traffic (OG RS, No 57/08).
Rules on ceramic materials intended to come into contact with foodstuffs (OG RS, No 38/06).

Eva Bičič