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California companies required to disclose heavy metal content in baby food

As of January 2025, baby food manufacturers selling in California must disclose test results for four heavy metals – arsenic, lead, cadmium, and mercury – via an on-pack QR code.

The law, Assembly Bill 899 (AB 899), was signed by Governor Gavin Newsom in October 2023 and requires monthly testing of baby food for the specified contaminants.

Manufacturers must now provide a QR code on product packaging that links to publicly available test results, including batch numbers and links to the US Food and Drug Administration's (FDA) information on toxic heavy metals.

Response to heavy metal contamination findings

California’s decision to implement AB 899 follows a 2021 US Congressional report that found significantly high levels of heavy metals in major baby food brands, including arsenic levels up to 91 times the legal limit for drinking water and lead levels up to 177 times higher.

Commenting on the likely impact of the new measure, Sarah Sorscher, director of regulatory affairs at the Center for Science in the Public Interest (CSPI), told Ingredients Network: “Some consumers likely will visit a manufacturer’s websites to research baby food brands, and the information will also be used by reporters and consumer advocates. But it should not be up to consumers to shop around for baby food that is not high in lead: this is the manufacturer’s responsibility.”

She added, “The most important impact these bills will have is on corporate behaviour. Manufacturers know how sensitive consumers are to toxic contaminants in food, particularly food served to very young children. You can be sure they are doing everything in their power right now to ratchet up controls so that when testing rolls out, none of their products have to be reported as containing high levels of lead and other toxic heavy metals.”

Sorscher also highlighted ongoing regulatory gaps, stating: “This move is a step forward, but it’s not adequate to protect consumers. Unfortunately, the United States has very few real standards for heavy metal contamination in foods. [The Food and Drug Administration] only this week finalised voluntary action levels for lead in children’s food, a process that has dragged on for years. Without such limits, it is up to each manufacturer to determine what level of toxic metals it will allow in foods.”

QR code transparency

To meet the requirements, brands must now conduct monthly testing for the specified heavy metals and make the results accessible to consumers through the QR codes. However, the law does not define the presentation format for test results, raising concerns about the clarity of the information provided.

Rick Andrew, a consultant specialising in product certification strategies, commented on LinkedIn: “A challenge here will be context in interpretation of the results. What is the baseline level of heavy metals occurring naturally in foods? How does one product compare to another? What are the expected health impacts at the levels being reported? Data is great, but data without context can lead to worse decisions than would have been made with no data at all.”

Other industry experts are more positive. Sieh Ng, a research microbiologist at the Australian Commonwealth Scientific and Industrial Research Organisation (CSIRO) also commented on LinkedIn: “This is a huge milestone for baby food safety! The new law in California requiring mandatory testing and public disclosure of heavy metal levels in baby food will be a game-changer!

“... [T]he ripple effect across the industry will likely lead to more widespread testing, with major manufacturers incorporating QR codes for nationwide access to test results. It will be interesting to see how smart organic brands go above and beyond these requirements, setting themselves apart by demonstrating commitment to safety and quality.”

California setting the standard

While AB 899 currently applies only to baby food sold in California, other states have begun to adopt similar measures. Maryland will require baby food testing disclosures from January 2026, with manufacturers already required to start testing from January 1 of this year.

And on January 6, Virginia state delegate Michelle Lopes Maldonado introduced House Bill 1844, which would also mandate heavy metal transparency starting in January 2026. In addition to testing requirements and a prohibition on the sale of baby food that exceeds a level of heavy metals stipulated by the FDA, the bill also “requires a consumer to report a baby food product to the Commissioner of Agriculture and Consumer Services if the consumer reasonably believes that the baby food is being sold in the Commonwealth with toxic heavy metals that exceed the limits established by the FDA.”

Regulations set in California often influence national practices, and this is expected to happen with the new legislation, potentially driving brands to standardise QR code labelling for product transparency across all markets.