What Are Canada SOR/2016-175 Limits On Lead/Cadmium Leaching From Stainless Steel?

The regulation is named for ceramics - but its flatware definition captures stainless steel forks, spoons and knives.

The regulation sets limits through a schedule that categorises food contact products by type and internal depth. The key category for stainless steel tableware is "Flatware" - defined in the regulation as any product "that has an internal depth not exceeding 25 mm, measured vertically from the lowest interior point to a horizontal plane passing through the point of overflow".

For this category, SOR/2016-175 establishes the following migratable limits:

Lead (Pb): maximum 3.0 mg/L
Cadmium (Cd): maximum 0.50 mg/L

These limits appear in the regulation's schedule under "Migratable limits for lead and cadmium - general" and are consistently cited in Health Canada guidance and third-party compliance summaries. The values are expressed in milligrams per litre of the extraction solution - not per kilogram of product - which is a critical distinction for interpreting test reports correctly.

SOR/2016-175 does not leave the testing method to the discretion of the laboratory. The schedule mandates a specific procedure based on ISO 6486-1:2019, the international standard for determining lead and cadmium release from food contact ceramic and glassware.

The procedure is precise. The product is first handwashed with a non-acidic detergent solution, rinsed with distilled water and air dried. It is then filled to within 5 mm of the overflow level with an extraction solution of 4% (volume/volume) acetic acid in water. An inert opaque cover is placed over the product, and it is allowed to stand for 24 hours at 22 ± 2°C. After standing, the extraction solution is stirred to ensure homogeneity, and an aliquot is analysed within eight hours using a technique in accordance with good laboratory practices. The result is expressed as milligrams of lead or cadmium per litre of extraction solution.

This method is designed to simulate worst-case exposure to acidic foods. Acetic acid at 4% is roughly equivalent to the acidity of vinegar - a common condiment and ingredient that could come into prolonged contact with tableware. The 24-hour duration represents an exaggerated exposure scenario, ensuring that even products with marginally compliant surfaces are identified.

A common assumption among buyers is that stainless steel is inherently exempt from lead and cadmium concerns because the alloy is not "made with" these metals. This assumption is partially correct - high-quality food-grade 18/10 and 316L stainless steels do not intentionally contain lead or cadmium. The alloying elements are iron, chromium, nickel and molybdenum. Neither lead nor cadmium is a deliberate constituent.

However, the assumption breaks down in two important scenarios. First, trace impurities can be present in steel, particularly in recycled scrap or non-food-grade alloys. Lead and cadmium are common contaminants in lower-grade raw materials, and even parts-per-million levels can migrate into an acidic extraction solution. Second, decorative or functional coatings on stainless steel tableware - painted handles, coloured PVD finishes, plated rims - may contain lead or cadmium pigments or stabilisers. A regulation that applies to the finished product tests the finished product, regardless of what the substrate is made of.

In practice, a well-manufactured 18/10 stainless steel fork with no coating will pass SOR/2016-175 testing with a comfortable margin. The migration values for lead and cadmium from pure food-grade steel are typically well below the detection limit of standard analytical techniques, let alone the 3.0 mg/L and 0.50 mg/L thresholds. The compliance risk lies in coated products, recycled-content steel, and tableware with mixed-material construction.

Step 1 - Confirm product categorisation. Determine whether the product falls within the "flatware" definition (internal depth ≤ 25 mm) or another category. Forks, spoons and standard knives are flatware. A deep serving spoon or ladle may fall into "small hollowware" with different limits.

Step 2 - Commission testing to ISO 6486-1:2019. Use a laboratory familiar with the SOR/2016-175 schedule and the ISO 6486-1 method. The test report must clearly state the extraction conditions (4% acetic acid, 24 hours, 22°C) and the measured lead and cadmium concentrations in mg/L.

Step 3 - Verify results against limits. Confirm that lead is ≤ 3.0 mg/L and cadmium is ≤ 0.50 mg/L. If the product is coated, consider testing the coating separately to isolate any contribution.

Step 4 - Retain documentation. Health Canada and the Canada Border Services Agency can request compliance documentation. Keep test reports on file for the duration of the product's market life plus a reasonable retention period.

Step 5 - Monitor for updates. SOR/2016-175 was last amended in June 2026. The regulation is periodically reviewed, and limits or test methods may be updated. A compliance programme that was valid two years ago may need re-verification.

Does SOR/2016-175 apply to stainless steel tableware?

Yes. Although SOR/2016-175 is titled the Glazed Ceramics and Glassware Regulations, its scope extends to food contact materials that fall within its product category definitions. The regulation defines 'flatware' as any product with an internal depth not exceeding 25 mm, measured vertically from the lowest interior point to the overflow plane. Stainless steel forks, spoons and knives fall within this flatware category and are subject to the lead and cadmium migration limits.

What are the lead and cadmium migration limits for flatware under SOR/2016-175?

For flatware - the category that includes stainless steel forks, spoons and knives - SOR/2016-175 sets a migratable lead limit of 3.0 mg/L and a migratable cadmium limit of 0.50 mg/L. These limits apply to the extraction solution after the product has been tested using the specified method.

What test method does SOR/2016-175 require for lead and cadmium migration?

The regulation mandates a test method based on ISO 6486-1:2019, 'Ceramic ware, glass ceramic ware and glass dinnerware in contact with food - Release of lead and cadmium - Part 1: Test Method.' The procedure involves handwashing with non-acidic detergent, filling the product with 4% acetic acid solution, covering with an inert opaque cover, and allowing it to stand for 24 hours at 22 ± 2°C. The extraction solution is then analysed using a technique in accordance with good laboratory practices.

Is stainless steel inherently exempt from lead and cadmium concerns?

No. While high-quality food-grade 18/10 and 316L stainless steels do not intentionally contain lead or cadmium as alloying elements, trace impurities can be present, particularly in recycled or non-food-grade steel. Additionally, decorative coatings, painted handles or plated finishes on stainless steel tableware may contain these metals. Testing is therefore required to confirm compliance.

What documentation do I need for stainless steel tableware sold in Canada?

You need a test report from a qualified laboratory demonstrating compliance with SOR/2016-175 lead and cadmium migration limits, using the ISO 6486-1 method. The report should clearly identify the product, the test conditions, and the measured migration values. This documentation should be retained and made available to Health Canada or the Canada Border Services Agency upon request.