Does GPSR Apply to Mugs, Cutting Boards and Other Food-Contact Items?

Short answer: if you sell mugs, cutting boards, resin coasters or bowls to EU buyers, your main rulebook is not the GPSR — it is the EU food contact framework, Regulation (EC) No 1935/2004, plus material-specific measures: the Plastics Regulation (EU) No 10/2011 and the Ceramics Directive 84/500/EEC with its lead and cadmium limits. The GPSR (Regulation (EU) 2023/988) applies only residually, to the aspects food contact law does not cover — and for ceramics and plastics you need a written declaration of compliance backed by test documentation. EUSellKit's checker does not cover food-contact requirements; this guide explains why, and what you need instead.

Is a mug or cutting board covered by the GPSR?

Only for the risks that food contact law does not already regulate — Article 2(1) GPSR makes the regulation residual. Where products are subject to specific safety requirements imposed by Union law, the GPSR "applies only to those aspects and risks or categories of risks which are not covered by those requirements" (Art. 2(1)).

For food-contact articles, those specific provisions exist. Regulation 1935/2004 applies to any article that, in its finished state, is intended to come into contact with food or "can reasonably be expected to be brought into contact with food" under normal or foreseeable use (Art. 1(2)). That scope catches the classic Etsy cases:

Product	An FCM?	Main rules
Ceramic mug	Yes — clearly intended for food contact	Reg. 1935/2004 + Directive 84/500/EEC (Pb/Cd limits, declaration of compliance)
Wooden cutting board	Yes	Reg. 1935/2004 Art. 3, 15, 17; no EU-harmonised specific measure for wood
Resin coaster sold as decor	Usually no — a cup sits on it, not food	GPSR (chemical and mechanical safety as a normal consumer product)
Resin serving board marketed "food safe"	Yes — you made it food contact by marketing it	Reg. 1935/2004; plastics/epoxy rules incl. Reg. (EC) 1895/2005

The practical takeaway: for chemical migration into food, look to food contact law; for everything else — including marketplace listing fields — the GPSR still matters (more below).

What does Regulation (EC) 1935/2004 require for every food-contact item?

Four things: safe manufacture, honest presentation, labelling, and traceability. These apply to all food-contact materials, whatever they are made of:

• Article 3 — general requirements. The article must not transfer constituents to food in quantities that could endanger health, unacceptably change the food's composition, or spoil its taste or smell. Article 3(2) adds that labelling, advertising and presentation must not mislead consumers — the provision an unsubstantiated "food safe" claim breaks.
• Article 15 — labelling. Articles sold empty must carry the words "for food contact", a use indication (e.g. "soup spoon"), or the glass-and-fork symbol (Annex II), plus any safe-use instructions and the name and EU address of the manufacturer or responsible seller. The wording is not obligatory for articles clearly intended for food contact (Art. 15(2)) — a mug speaks for itself.
• Article 16 — declaration of compliance. Where a specific measure covers your material (plastics, ceramics, epoxy coatings…), the article must be accompanied by a written declaration of compliance, with supporting documentation available to authorities on demand.
• Article 17 — traceability. You must be able to identify the businesses you sourced from and supplied to.

What are the lead and cadmium limits for ceramic mugs?

Directive 84/500/EEC sets binding migration limits, and Article 2a requires a written declaration of compliance up to and including the retail stage. The limits (Art. 2(4)) are tested with 4 % acetic acid over 24 hours (Annex I):

Category	Definition	Lead (Pb)	Cadmium (Cd)
1	Articles that cannot be filled, or fillable with internal depth ≤ 25 mm (plates, flat boards)	0.8 mg/dm²	0.07 mg/dm²
2	All other fillable articles — this is your mug	4.0 mg/l	0.3 mg/l
3	Cooking ware; packaging and storage vessels over 3 litres	1.5 mg/l	0.1 mg/l

The declaration must identify the manufacturer/importer and the article, be dated, and confirm compliance with the Directive and Regulation 1935/2004 (Annex III). Behind it you must hold the analysis results, test conditions, and the name and address of the testing laboratory (Art. 2a(2)). If you glaze and fire your own mugs, that means an actual lab test of your glaze/firing combination — a supplier's "lead-free" note on a bag of glaze is not a migration test of your finished mug.

Can you call a resin coaster or cutting board "food safe"?

Only if you can document it — otherwise the claim itself violates Article 3(2) of Regulation 1935/2004. For plastic articles, Regulation (EU) 10/2011 sets an overall migration limit of 10 mg of constituents per dm² of food contact surface (Art. 12) and requires a declaration of compliance through the supply chain (Art. 15, Annex IV) plus supporting documents for authorities (Art. 16). Epoxy resins face an extra layer: Regulation (EC) No 1895/2005 restricts BADGE and no longer permits BFDGE and NOGE in food-contact materials.

The honest options for a resin seller: either sell it as decor and say so ("decorative — not intended for food contact" — then it is not an FCM and no migration testing is needed), or sell it for food use only with a resin system whose manufacturer provides food-contact documentation for your actual use (cured ratio, food types, temperature). What you cannot do is write "food safe epoxy!" because the craft-store label said so — that phrase on the raw resin rarely covers your cured, home-mixed article.

Do wooden cutting boards need an EU declaration of compliance?

No — there is no EU-harmonised specific measure for wood, so the Article 16 declaration duty is not triggered at EU level. Wood still falls under Regulation 1935/2004's general requirements, labelling and traceability rules (Arts. 3, 15, 17), and Member States may keep national provisions where no EU specific measure exists (Art. 6) — so an authority can still ask about the oils, glues and finishes you used. Document them and use food-grade materials — but no EU rule requires a formal DoC for a plain wooden board.

What do you still owe under GPSR and on Etsy?

The non-chemical risks — and your marketplace's safety fields. Because the GPSR covers aspects other rules don't, breakage, sharp edges and thermal shock sit in GPSR territory, and a proportionate risk assessment should cover them. And regardless of the fine legal boundaries, Etsy applies its GPSR-driven requirements to EEA-bound listings: an economic operator on the account and completed Manufacturer / Product safety information fields — see our full Etsy GPSR guide. Leaving those empty gets listings deactivated even when your migration paperwork is perfect.

Does EUSellKit check food-contact compliance?

No — food-contact requirements are explicitly outside EUSellKit's scope. Migration limits, declarations of compliance and lab testing under Regulation 1935/2004 cannot be verified from a listing, and we won't pretend otherwise. What our checker does cover is the GPSR and marketplace side of the same product: missing safety information fields, economic operator, labelling and documentation gaps that get listings taken down. Sort your food-contact documentation with your supplier or a lab — and let us handle the listing compliance layer: Check your listing's GPSR gaps — €14.

This guide is general information, not legal advice.