The ABPC requires that its members: use pewter that conforms to the standards outlined below; and produce products that meet the required standard.
The most current legislation, regulations and advice affecting the standard of pewter within the UK are advised as follows:
Regulation on lead in consumer articles – The “Child’s Mouth” Rule and lead traces in pewter
The regulation on lead in articles, 2015/628, came into law within the European Union on 1st June 2016.
The concept for the regulation, aimed at protecting children from exposure to lead, was:
Due to their mouthing behaviour, children, especially those under 36 months, can be repeatedly exposed to lead released from consumer articles containing lead or lead compounds. Lead and lead compounds are present in consumer articles (this includes pewter ware), whether as intentionally added metallic lead, as an impurity or as an additive of metal alloys.
The lead limit is 0.05%.
An article supplied to the general public may be included within the scope of this restriction, if: (a) It does not exceed a size of 5 cm in any of its three dimensions, so that it can be placed in the mouth; (b) It has accessible parts, detachable or protruding parts with at least one dimension smaller than 5 cm, that can be placed in the mouth.”
Items exempted from the restriction
Religious articles for consumer use
Article types which are exempted as covered by other legislation
Articles intended to come into contact with food – Regulation (EC) No 1935/2004
Toys – Directive 2009/48/EC
Jewellery items – Paragraphs 1 and 2 of Entry 63 of Annex XVII to REACH
Advice for ABPC members concerning the regulation on lead in consumer articles
The existing (EN611) standards for the maximum lead content in pewter and pewter articles as set out in the regulations allow a maximum of 0.25% lead – and therefore are clearly above the new limit.
The standard for solders (EN 29453:1994) also allows for a higher lead content.
Therefore those standards are no longer valid for pewter products that can be mouthed by children as described above.
However testing carried out by the ABPC has indicated that pewter articles can meet the required standard.
Therefore if members are producing products that fit into the areas outlined above then they are advised to ensure that the pewter and solder used meets the required lead limit and that they commission testing of the articles if they are in any doubt.
European Directorate for the Quality of Medicines & Healthcare (EDQM) – Metals and alloys used in food contact materials and articles.
The 1st Edition of this document of new guidelines was issued in 2013, and concerned the Specific Release Limit (SRL) of metallic elements into food and drink contained within them. These guidelines do not represent Law, which is enacted by individual nation states, but they are followed by customers and the public when seeking reassurance that products are safe.
The regulations are organised by metallic element; and those of relevance to Pewter are as follows:
“the SRL for tin is set, in approximation with Regulation (EC) No. 1881/2006, at 100mg/kg”
“the SRL for antimony is set at 0.04mg/kg”
“the SRL for copper is set at 4mg/kg”
Within the text of the guidelines Pewter is only referenced once:
“Pewter may contain lead as a contaminant, which can also be released. Antique pewter may have been manufactured using lead-containing alloys, but this is not the case with modern pewter. Today, maximum levels of lead are specified for lead-containing pewter.”
Given the statement quoted above associating pewter with lead, there may be a need to test for SRL of lead.
“the P-SC-EMB decided to set the SRL at 0.01mg/kg”
Advice for ABPC members on Metals and alloys used in food contact materials and articles.
Testing of ABPC producer products has taken place using the testing procedures outlined in the guidelines. These tests took place over a 10 day period, at a temperature of 40° Celsius, using an acidic food simulant.
The results of these tests were immediately safe for all products tested with the exception of pewter drinks’ flasks which failed the initial test for the release of tin.
Therefore further tests were carried out on a flask that had been treated as recommended in the advice reproduced below: This text was previously issued to ABPC members as recommended instructions to be issued with pewter flasks.
The results of the 24 hour test were safe with the release of tin comfortably within the required limit. A further test, over 72 hours, also passed within the required level.
Our conclusion remains that advice along the above lines should be issued with any products where liquid might be sealed inside for any length of time.
Please note that all products tested have returned different results as a result of the numerous variations in factors involved such as: alloy composition; method of manufacture and finish surface treatment. Therefore we recommend that any members concerned to ensure that particular products meet the requirements should get those products tested. We suggest that wherever possible the test should be carried out using conditions applicable to the intended and likely use – for example use the intended food or drink and apply appropriate temperatures and time periods. This will allow appropriate consumer advice to be issued with the product if required, as with the flask above, for example.
Guidance to ABPC members selling products into other territories
The ABPC has carried out research and testing with regard to selling pewter products in jurisdictions outside the UK. As these territories are numerous, and the local regulations change from time to time, we do not list guidance in this document.
However, any member who requires guidance for any particular territory, product or regulation, should please feel free to contact the ABPC and we will share whatever knowledge is available to us.
Existing and previously regulations
For reference we outline below the regulations that existing prior to the regulations listed above. The standards outlined in these are still valid and applicable to all pewter manufacture other than where superseded by later requirements (as outlined above).
Pewter is defined as a malleable metal alloy mainly consisting of tin with the addition of other metals which can include antimony, bismuth, cadmium, copper, lead and silver.
The current standard for pewter starts with the standard for tin, the European Standard EN 610:1995. This requires that the chemical composition and grade designation of ingot tin must be as per the table shown below:
Pewter itself is a material defined by standard EN 611-1:1995 this allows for the chemical composition of pewter alloys to be as per the table below:
The same standard requires that solders should comply with standard EN 29453:1994 shown below:
The standard EN 611-2:1996 further defines pewterware:
In that “the pewter part(s) of the pewterware can be fabricated from one or more pieces of pewter, each of which shall be an alloy conforming to EN 611-1.”
It further sets out methods of sampling and analysis; and specifies that “as a minimum requirement, each article of pewterware shall be permanently marked with: the name or mark of the producer and / or distributor and the word PEWTER or a corresponding translation”
Should members require any further information, clarification or full copies of any regulations or guidelines please do not hesitate to contact the ABPC and we will provide whatever we can by way of assistance