The maximum levels for heavy metals in food have been tightened. The question for most producers is no longer whether they test, but whether they test against the limit that actually applies to their product, with a method that holds up when an authority asks.
If you want to know which limits apply to your product and how to demonstrate compliance in a way that holds up, contact us to discuss what your situation requires.
Lead, cadmium, mercury, arsenic and nickel occur naturally in soil and water, and they can accumulate in food through the environment and through anything added during production You cannot reformulate them away, and a clean supplier statement does not tell you what ended up in the finished product. Their presence depends on crop, origin, processing and the category the food falls into, which is exactly why the law treats categories differently.
Maximum levels for contaminants in food are set in Commission Regulation (EU) 2023/915, which replaced the older Regulation 1881/2006 and consolidated the limits for a.o. lead, cadmium, mercury, inorganic arsenic and inorganic tin into a single text. On top of that, Commission Regulation (EU) 2024/1987 introduces maximum levels for nickel for the first time, applicable from 1 July 2025, with a later date of 1 July 2026 for cereals because of their more complex supply chains.
The principle behind the rules is strict. Food that exceeds a maximum level may not be placed on the market, and it may not be used as an ingredient or mixed with compliant food to dilute the result. The limits themselves are risk management values, and they continue to be revised as new assessments appear.
It rarely starts with a routine test. It starts with an imported product you did not produce yourself, a private label product where you carry the responsibility for someone else’s process, a new product category whose limit you have not checked, or an auditor asking how you know your product complies.
The most common trigger now is a category where the limit has simply moved. A producer who was comfortably within the norm last year can find that the norm changed underneath them, with nickel being the clearest recent case.
The value is not in producing a number. It is in deciding which number you need before anything is measured. We help establish which limit applies to your specific product and category, what the right analytical scope is, and whether the method can measure low enough to make the result defensible. That judgement at the start prevents testing for the wrong thing, retesting later, and discussions about whether the chosen approach was sufficient. We combine the analysis with the regulatory interpretation, so the result arrives as a position you can stand behind rather than a value you still must explain.
Heavy metal analysis is typically performed by ICP-MS, quantifying each element against the maximum level for the relevant food category. What matters as much as the instrument is the limit of quantification.
It is a starting point, not evidence. The responsibility for the product placed on the market rests with you, and that responsibility is supported by data, not by a statement.
Because the limits change. Nickel is the most recent example, and the category dates differ, so a product can fall out of compliance without anything in the product itself having changed.
No. Which elements are relevant, and at what level, depends on the food category and its origin. The scope should follow the product, not a default list.
Maximum levels for heavy metals in food are set in Commission Regulation (EU) 2023/915, which repealed Regulation (EC) No 1881/2006. Nickel was added separately by Regulation (EU) 2024/1987, which amends 2023/915. The applicable text is the consolidated version, because the limits are revised through amendments rather than reissued, and an outdated copy is one of the easier ways to test against the wrong number.
The regulation covers lead, cadmium, mercury, inorganic tin and arsenic, with nickel added for the first time in 2024. Which of these is relevant for your product depends on the food category and its origin, so the right scope follows the product rather than a fixed panel.
The nickel limits apply from 1 July 2025, with cereals given an additional year, until 1 July 2026, because of their more complex supply chains. The levels vary by category, for example a general limit of 3.5 mg/kg for most tree nuts and 0.5 mg/kg for baby food. Because these limits are new, a product that was never assessed for nickel before may now fall in or out of compliance without anything in the product having changed.
Lead limits for food intended for infants and young children are among the lowest in the regulation, in the order of 0.01 mg/kg depending on the exact category. At that level the detection limit of the method matters as much as the result, because a method that cannot measure well below the threshold cannot demonstrate compliance with it.
Heavy metals are typically quantified by ICP-MS or an equivalent validated technique, measured against the maximum level for the specific food category. For arsenic the relevant figure is usually inorganic arsenic rather than total arsenic, since the inorganic form is the one the limit addresses, and confusing the two is a common reason a result looks compliant when it is not.
Not by itself. A measurement only proves compliance if it is taken against the correct category limit, with a method whose detection limit sits below that limit, and interpreted in light of the current regulation. The number is the easy part. Deciding which number you need, and whether it holds up, is where compliance is actually won or lost.
If you want to know which limits apply to your product and how to demonstrate compliance in a way that holds up, contact us to discuss what your situation requires.
