On September 11, 2026, the Belgian Moniteur belge published the royal decree of July 19, 2026 of the FPS Public Health, Food Chain Safety and Environment amending the royal decree of May 1, 2006 on the declaration of conformity and performance criteria for the analysis method of ceramic articles intended to come into contact with foodstuffs (NUMAC 2026006323). The official gazette PDF (edition of September 11, 2026, p. 49662) is the binding Belgian text.
The decree replaces Article 3, paragraphs 2 and 4, of the 2006 instrument, inserts Chapter IV/1 on mutual recognition, and enters into force on May 29, 2026, the 18-month deadline of Benelux Committee of Ministers Decision M (2024) 5 of November 29, 2024. The Netherlands and Luxembourg already apply the same specific-release limits from that date. Belgium is the third Benelux state to put them into national law, and the gazette is retroactive: ceramic tableware, cookware and storage vessels placed on the Belgian market since May 29, 2026 already had to meet the new envelope.
What did the royal decree of July 19, 2026 actually change?
It rewrites how an operator placing ceramic articles on the Belgian market proves that lead and cadmium release stays within the specific limits, and it writes those limits at the Benelux safeguard levels rather than the Directive 84/500/EEC ceilings the 2006 decree had carried.
New Article 3 § 2.1 lets that operator calculate or estimate migration from composition and supplier files, from whether lead- or cadmium-bearing substances are used (food-contact, mouth-contact, interior, underglaze or exterior), from similar-article or batch tests, and from process control of glazing, decoration, firing, lot variation and cross-contamination. New § 2.2 is the fallback: if that file does not give sufficient assurance, release must be determined by the Annex 1 test conditions and the Annex 2 method of the 2006 decree.
Article 2 inserts Article 4/1: ceramic articles legally manufactured or placed on the market in an EU Member State, or in a non-EU state party to a customs-union treaty, or legally manufactured in a state party to a free-trade-area treaty binding the Benelux countries, are assimilated if they meet requirements offering at least equivalent protection. The recitals cite Article 18 of Regulation (EC) No 1935/2004, the FCM safeguard clause.
Who must apply the new limits, and from which date?
Every operator who places ceramic food-contact articles on the Belgian market: Belgian manufacturers, extra-EU importers, and retailers putting own-brand or imported tableware, cookware or storage vessels on Belgian shelves.
Article 3 of the 2026 decree sets entry into force on May 29, 2026. Publication on September 11, 2026 does not postpone it. Goods already in Belgian distribution since May 29, 2026 sit inside the new limits. Operators already shipping to the Netherlands or Luxembourg under those states' May 2026 measures can rely on Article 4/1 if the articles meet equivalent requirements; operators who still treated Belgium as on the 2006 (Directive 84/500/EEC) numbers need an immediate gap analysis. Execution sits with ministers David Clarinval (Agriculture) and Frank Vandenbroucke (Public Health); market surveillance is with the federal food-chain authorities (AFSCA/FAVV).
How do the new specific-release limits compare with Directive 84/500/EEC?
New Article 3 § 4 treats an article as compliant only if lead and/or cadmium release does not exceed the Benelux M (2024) 5 limits below, which sit far below the directive's still-applicable EU-wide ceilings.
| Category | Articles covered | Directive 84/500/EEC Pb / Cd | Belgian AR of July 19, 2026 Pb / Cd |
|---|---|---|---|
| 1 | Non-fillable articles, and fillable articles with internal depth of 25 mm or less | 0.8 mg/dm² / 0.07 mg/dm² | 6 µg/dm² / 4 µg/dm² |
| 2 | All other fillable articles | 4.0 mg/l / 0.3 mg/l | 30 µg/l / 20 µg/l |
| 3 | Cookware; packaging and storage vessels above 3 litres | 1.5 mg/l / 0.1 mg/l | 10 µg/l / 7 µg/l |
Category 1 lead therefore moves from 0.8 mg/dm² (800 µg/dm²) to 6 µg/dm², and cadmium from 0.07 mg/dm² (70 µg/dm²) to 4 µg/dm². Decorative glazes, rims and exterior surfaces that can contact the mouth sit inside § 2.1; a declaration of conformity that only covered the food-contact face under the old numbers is not enough.
What should FCM teams do this week for stock and inbound shipments?
Map every ceramic SKU placed on the Belgian market since May 29, 2026 against the three categories, then decide whether composition files, supplier attestations and similar-article tests under § 2.1 give sufficient assurance, or whether Annex 1 / Annex 2 testing is required under § 2.2. Update the declaration of conformity to the new § 2 and § 4 wording. For inbound lots already cleared in the Netherlands or Luxembourg under equivalent Benelux rules, document the Article 4/1 assimilation rather than re-testing blindly. Brief contract labs that Belgian work now uses the Benelux microgram limits, not the milligram directive ceilings.
Continuous, per-jurisdiction real-time monitoring surfaces a Moniteur belge drop like this the moment it publishes.
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Confirm which of your ceramic food-contact SKUs are on the Belgian market, check each against the category limits in the table, refresh the DoC under the new estimation-or-test protocol, and brief quality, import and retail teams that May 29, 2026 is the operative date. Obsidian tracks these gazette publications per jurisdiction so the next national FCM amendment is visible when it lands, not weeks later.
