The Long Cycle Notes
What are the lead and cadmium limits for ceramic tableware sold in the U.S.?
Federal limits come from two FDA Compliance Policy Guides: leachable lead from 3.0 µg/mL for flatware down to 0.5 µg/mL for cups, mugs and pitchers, and leachable cadmium from 0.5 down to 0.25 µg/mL. California writes the same FDA limits into state law, requires a permanent maker or importer mark on tableware made with lead or cadmium, and adds Proposition 65 warning rules. Test every glaze and decoration before production.
Why buyers are asking this now
Glaze is doing more of the selling in tabletop than it used to: reactive glazes, speckled finishes, two-tone dips and bright color programs. Each new color is a new mix of minerals, and each one has to pass the same lead and cadmium limits as a plain white plate. At the same time, many programs are qualifying a second origin, which means the same item is being made with new clay, new glaze suppliers and a new kiln. A test report from the old factory does not carry over.
The rules themselves are not new. What trips buyers up is that three layers apply at once in the U.S.: FDA's federal limits, California's state law, and California's Proposition 65 warning rules.
The FDA limits, by type of piece
FDA sets action levels for leachable lead and cadmium in two Compliance Policy Guides. Pieces are tested with a leaching method such as ASTM C738, and the limit depends on the shape of the piece and how many of six test units must pass.
| Category | How it is judged | Leachable lead (µg/mL) | Leachable cadmium (µg/mL) |
|---|---|---|---|
| Flatware (internal depth 25 mm or less: plates, saucers, shallow dishes) | Average of 6 units | 3.0 | 0.5 |
| Small hollowware under 1.1 L (bowls, small serving dishes), other than cups and mugs | Any 1 of 6 units | 2.0 | 0.5 |
| Cups and mugs | Any 1 of 6 units | 0.5 | 0.5 (small hollowware) |
| Large hollowware 1.1 L or more, other than pitchers (large bowls, casseroles) | Any 1 of 6 units | 1.0 | 0.25 |
| Pitchers | Any 1 of 6 units | 0.5 | 0.5 under 1.1 L; 0.25 at 1.1 L or more |
Two details matter in practice. First, flatware is judged on an average, but every hollowware category fails on a single bad unit, so one under-fired mug can fail a lot. Second, pieces that are clearly not for food, for example with a hole drilled through the food-contact surface or a permanent "not for food use" label, fall outside these limits. Most retail tabletop is meant for food, so plan to test.
How California adds to the federal rules
| Rule | What it requires | What it means for the buyer |
|---|---|---|
| California Health and Safety Code §108860 | Makes it unlawful to make, import or sell tableware in California that releases lead or cadmium above the FDA Compliance Policy Guide standards, or any stricter standard FDA adopts later | The FDA limits above become state law, enforceable in California even if FDA never inspects your shipment |
| California Health and Safety Code §108870 | Each piece must be permanently marked, fired or manufactured into the glaze, with the name of the maker or importer responsible for California sales; tableware made without lead or cadmium is exempt | Decide the backstamp before tooling and decoration are approved, not after the goods are packed |
| Proposition 65 | A clear warning is required when a product exposes consumers to listed chemicals above safe harbor levels: for lead, 0.5 µg/day for reproductive toxicity and 15 µg/day (oral) for cancer; for cadmium, 4.1 µg/day (oral) for reproductive toxicity | For ceramic tableware, warning standards have been set in court settlements based on leaching from food-contact surfaces. Ask your lab which standard applies, and decide on warnings before packaging is printed |
What we see on the factory floor
Every tabletop program we run is tested for lead and cadmium against U.S. FDA and California requirements by independent laboratories such as Eurofins and SGS. The reports are tied to the item, the factory and the buyer that ordered them. We share the relevant report under NDA, and we arrange new testing for a new item rather than stretching an old report to cover it. Test fees appear as their own line in the quote, so nobody is tempted to skip them.
The risk is rarely the plain white plate. It is the new color. Reactive glazes vary from piece to piece by design, so we agree an approved range with reference samples before production and inspect glaze color against that range at the final inspection. When a program adds a colorway, changes a glaze supplier or moves to a second factory, we treat it as a new test, not a variation of the old one. That discipline mattered when we built our Vietnam ceramic supply chain in 2024: new clay, new glazes and new kilns meant new reports for every item, and every shipment from Vietnam travels with a Certificate of Origin.
What to check before you place the order
- Test each glaze and decoration, not just the shape. Every colorway, rim glaze and decal needs its own result against the FDA category for that piece.
- Test production pieces. Pull test units from the production run, not hand-finished samples, and keep the six-unit rule in mind for hollowware.
- Know the category. Measure internal depth (25 mm) and capacity (1.1 L) so the lab tests to the right limit. A deep plate can be hollowware.
- Retest on any change. New factory, new glaze supplier, new kiln or new decoration means a new report.
- Plan the California backstamp. Confirm the maker or importer name that will be fired into each piece, or document that the tableware is made without lead or cadmium.
- Decide on Prop 65 early. Ask your lab which settlement standard applies and decide on warning labels before artwork is final.
- Keep reports by item. File each report with the item number, factory and production date, so you can answer a retailer or a notice quickly.
Sources (accessed 2026-10-17): U.S. FDA, CPG Sec. 545.450 Pottery (Ceramics); Import and Domestic — Lead Contamination; U.S. FDA, CPG Sec. 545.400 Pottery (Ceramics); Import and Domestic — Cadmium Contamination; California Legislative Information, Health and Safety Code §108860 and §108870; California OEHHA, Proposition 65 safe harbor levels for lead and lead compounds and cadmium.
Developing a ceramic tabletop program? See ceramic dinnerware, how we handle testing and audits and Vietnam vs China for ceramic dinnerware, or start a conversation.
Frequently asked questions
Do cups and mugs have stricter lead limits than plates?
Yes. Under FDA guidance, flatware is judged on the average of six units at 3.0 µg/mL of leachable lead, while cups, mugs and pitchers fail if any one of six units exceeds 0.5 µg/mL. FDA defines cups and mugs as vessels commonly used for hot drinks such as coffee or tea, and their lead limit is six times tighter than flatware.
If my ceramics pass FDA limits, do I still need to think about Prop 65?
Yes. Proposition 65 is a separate California warning law. A warning is needed when a product can expose consumers to lead or cadmium above California's safe harbor levels, and for ceramic tableware the warning standards have been set in court settlements based on how much lead leaches from food-contact surfaces. Ask your lab to test against the standard that applies to your product and channel.
Does tableware sold in California need a backstamp?
Usually. California Health and Safety Code section 108870 requires each piece to be permanently marked, fired or manufactured into the glaze, with the name of the maker or importer responsible for California sales. Tableware made without lead or cadmium as an added ingredient or contaminant is exempt, and small pieces in a marked set can rely on the set.
Do I need new tests if production moves to Vietnam?
Yes. Test reports belong to a specific item, glaze and factory. A new factory, a new glaze batch or a new decoration means a new report. Every shipment from Vietnam should also travel with a Certificate of Origin, because origin and safety testing are checked separately.
Jeffrey Chen is the second-generation CEO of Jason Craft Corporation, a Taipei-based sourcing and product development company founded in 1981. More about Jeffrey · About Jason Craft.