Enamelware German LFGB Reporting Procedures
Date：2026-06-24 09:59:24 Classification
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Enameled Products Reporting Procedures (German LFGB)
Enameled products (metal substrate + vitreous enamel) are classified as a High Concern category in the German LFGB system. The main risks stem from the migration of metals such as lead, cadmium, aluminum, cobalt, arsenic, and antimony from the enamel, as well as issues with odor and discoloration during sensory testing. The complete reporting process is as follows:
I. Preparatory Work
1. Clarify Product Information
Product Category: Tableware (cups, bowls, plates) or cookware (pots, enameled cast iron pots)?
Usage Scenario: Will it come into contact with acidic foods (such as tomato soup, coffee)?
Target Usage Temperature: Room temperature, heating, or open flame?
Color and Pattern: Solid color or with colored patterns/decorations?
2. Distinguishing Applicable Regulations
LFGB § 30/31: Basic Food Contact Safety Requirements
BfR Recommendation: Guidance Limits for Metal Migration in Enamel Coatings from the German Federal Institute for Risk Assessment
DIN 51032: Specific Test Methods for Heavy Metal Release from Enamelware (Core Standard)
EU 1935/2004/EC: General Framework Regulation of the European Union
II. Formal Application Procedures
| Steps | Content | Precautions
| Step 1: Choosing an Institution | Select a third-party laboratory with CNAS/CMA accreditation and German recognition | Recommended: Dezewei Testing CNAS Registration No.: L8083
| Step 2: Completing the Application Form | Provide product name, model, material, color, purpose, and target operating temperature | Accurate completion avoids missed or duplicate testing
| Step 3: Sending Samples | Several sets of finished products (generally 3–6 pieces, prepared separately for color and model) | Different colors/patterns of the same product need to be sampled separately for testing
| Step 4: Signing the Contract | Confirm test items, cycle, cost, and report language (English/German) | We recommend directly performing the full LFGB migration + sensory test.
| Step 5: Laboratory Testing | Test according to standards | See core testing items below for details.
| Step 6: Report Issuance | An LFGB test report will be issued after the test is passed | The report must include German-recognized test methods and limit references.
| Step 7: Declaration of Compliance | A Declaration of Conformity (DOC) must be issued by the company itself | Some clients may additionally request an LMBG (old terminology) report.
III. Core Testing Items for Enamel Products
1. Sensory Test
Odor and taste transfer test (evaluation after contact with simulated solutions of water, acid, alcohol, and olive oil)
Whether visible color migration or turbidity appears on the enamel surface.
2. Heavy Metal Migration Test (Core)
Simulated contact conditions according to DIN 51032 / EN 1388-1, -2:
Lead (Pb), Cadmium (Cd) – The element with the highest historical risk, with the strictest limits.
Aluminum (Al), Cobalt (Co), Copper (Cu), Manganese (Mn), Nickel (Ni), Antimony (Sb), Arsenic (As), Selenium (Se), Chromium (Cr), Barium (Ba), Zinc (Zn), Tin (Sn), and 19+ other elements.
3. Simulated Liquid Selection
Simulated cold water/hot water/acidic foods/alcoholic beverages/oils (e.g., enameled cast iron pots require higher temperatures and acidic conditions)
4. Physical Properties (for some products)
Adhesion test
Resistance to rapid cooling and heating (for cookware)
Enamel integrity (no visible cracks, bubbles)
IV. Testing Cycle and Cost
Standard cycle: 5–7 working days
Cost range: A complete LFGB test for a single type of enamelware typically costs between 800 and 2000. For cookware such as enameled cast iron pots, due to the complexity of simulation conditions and the presence of multiple elements,
it is recommended to package multi-colored/multi-size products into "family" categories for declaration to reduce costs.
V. Key Compliance Points
Colored patterns are high-risk: Cups, bowls, and plates with colored or gilded interiors require special attention regarding cadmium, lead, and cobalt release. It is recommended to prioritize solid-color underglaze or unpatterned designs for testing.
Rim and bowl contact areas: These come into direct contact with human saliva and are a key focus of German market supervision.
Usage conditions must match testing conditions: Products advertised as "suitable for open flame/oven use" require testing with higher temperatures and more stringent simulated liquids.
Report validity: Typically 2–3 years, but retesting is required when processes, raw materials, or suppliers change.
DOC self-declaration: After receiving the LFGB report, companies must sign a declaration of conformity and retain it for at least 10 years for future reference.
Amazon and other platforms require: For direct sales of enamel tableware and mugs on the German platform, an LFGB test report must be uploaded as proof of compliance.
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