1The same number, two answers

A wine from the 2023 harvest is tested for lead and comes back at 0.13 mg/kg.

In Great Britain it complies. In the European Union it does not. And in Northern Ireland — the same country as Great Britain — it does not either.

Nothing about the wine changed. The number did not change. What changed is the rulebook the bottle is being judged against, and there are more rulebooks in play than most producers expect.

Part 1 of this series set out the European rows: lead in wine at 0.20 mg/kg for the 2001–2015 harvests, 0.15 for 2016–2021 and 0.10 from 2022 onwards, with grape liqueur wine at 0.15 from 2022, and no level at all for beer or spirits. This article is about what happens to that result once the bottle leaves the European Union.

2Where the vintage rule travels

The harvest-year principle is not a European invention, and it did not stay in Europe.

Switzerland reproduces the European structure exactly: the same three bands with the same years, and the same 0.15 mg/kg for grape liqueur wine. It is not an EU member and aligned autonomously, in force since February 2024.

The Codex Alimentarius uses the principle but anchors it to an event rather than a year. Grapes harvested after its 2019 adoption decision carry 0.1 mg/kg; those harvested before carry 0.2 mg/kg, kept expressly so that trade in older wine retains an international reference. Fortified and liqueur wine sit at 0.15 mg/kg. Codex texts are voluntary, but they matter: the WTO Agreement on Sanitary and Phytosanitary Measures treats them as the reference standard.

The OIV recommends 0.10 mg/L from the 2019 harvest, with a derogation that deserves copying: a long-aged liqueur wine is judged by the limit in force when it was made. The OIV has fifty member states and the European Union sits as an observer. Its resolutions are recommendations, not law — though for lead in wine the European regulation on the common organisation of markets refers the analytical method to OIV methods, so the two are not as separate as they look.

Great Britain kept the principle and froze the text. Its assimilated version of the old European regulation stands as it was on 31 December 2020, which means two bands rather than three: 0.20 mg/kg up to the 2015 harvest and 0.15 mg/kg for 2016 onwards, with no upper step. That is why a 2023 wine at 0.13 mg/kg passes there and fails in the EU.

Northern Ireland applies the European regulation directly. Same state, different answer.

There is a second British divergence worth knowing. Liqueur wine is expressly excluded from the British wine row and has no row of its own, so it carries no lead limit at all in Great Britain, while carrying 0.15 mg/kg in the European Union.

3The rest of the world

Outside Europe the vintage almost never matters. What varies instead is whether a limit exists at all.

One wine, thirteen rulebooks. The gold line is the result; the navy mark on each row is the maximum level that market applies to it. Where the mark falls to the left of the line, the wine exceeds the level. Units are not identical — Brazil and the OIV work in mg/L and Canada in ppm by weight — and are placed on one axis for comparison only. California is absent because it sets no concentration limit at all.

Four things in that table are worth stopping on

Japan. A figure of 0.2 mg/kg circulates widely as the Japanese limit. It is not. Japan's own risk documentation attributes that number to the Codex. There is no national maximum level for lead in alcoholic drinks, and responsibility for food standards moved to the Consumer Affairs Agency in April 2024.

Beer. There is no European limit for lead in beer or spirits, but Canada, China, Brazil and India all set one. A European brewery has nothing to comply with at home and a number to meet in four export markets. That inversion catches people out, because the European Union is assumed to be the strict one.

Absence is usually deliberate. Where a market sets no lead limit for alcohol, it is rarely an oversight. The Australia–New Zealand code names alcoholic drinks precisely — red wine, white wine and fortified wine; whisky, rum, gin and vodka — but only in its methanol table. Its lead table lists eleven foods and none of them is a drink. Switzerland is the same: spirits appear once in the whole contaminants ordinance, under patulin, never under lead. These regulators know how to name a wine when they want to.

China tightened, in the direction people miss. Under the 2017 standard, all distilled spirits sat at 0.5 mg/kg. Since June 2023 only baijiu and huangjiu do; everything else moved to 0.2 mg/kg. Imported whisky, brandy, vodka, gin and rum became more tightly controlled, not less. The successor standard takes effect in September 2026 with the same figures. Separately, the Chinese product standard for fermented drinks deleted its own lead limit in 2012 and now defers to the general contaminants standard, so a specification citing the old beer standard is citing a rule that no longer contains a number.

4Four traps in reading any of these numbers

The limit may not be filed under your product

Canada has no row for wine, and none for beer or spirits. What it has is a generic entry covering beverages other than fruit juice and nectar, set at 0.2 ppm. The Canadian Food Inspection Agency applies that category to alcoholic drinks in practice: its 2022 survey tested 28 wines and 19 brandy, sherry and vermouth samples against the corresponding generic tolerance.

A producer searching for a Canadian wine limit finds nothing and concludes there is none. There is one. Older statements that Canada does not regulate metals in these products date from before the entry took effect and no longer describe the position.

Units are not interchangeable, and nobody converts for you

Most markets work in mg/kg. India and the OIV work in mg/L. Canada works in ppm by weight, referred to the food as consumed rather than to a volume, despite the product being a liquid. Brazil does two things at once: its contaminants rule expresses wine in mg/L and everything else in mg/kg, while a separate product standard for beer gives the figure in ppm. Three bases, one country, one sector.

Some limits are narrower than they look

South Korea's 0.2 mg/kg sits in a section covering all fermented drinks, but a parenthesis restricts it to grape wine within the fruit-wine category. Beer is in the same section and expressly outside the limit. The distilled section next door sets methanol and aldehydes, and no metals at all.

Brazil goes the other way: its alcohol-free beer is held to 0.05 ppm, four times stricter than the beer with alcohol in it.

Translation errors travel

The Chinese standard sets 0.5 mg/kg for 白酒 — baijiu, the domestic grain spirit — and 0.2 mg/kg for everything else. English versions circulating on official European portals render 白酒 as "distilled spirits", which puts every imported whisky, brandy and vodka in the wrong row.

A Scotch shipped to China is held to 0.2 mg/kg, not 0.5. Anyone planning against the higher figure has less margin than they think, and anyone writing it into a specification is writing the wrong number.

5Where you probably sit

Compliance discussions rarely mention what wine actually contains, which makes the limits sound tighter than they are.

Occurrence data compiled for the WHO puts the mean lead content of European wine at about 17 µg/kg for red and 15 µg/kg for white. Canadian wine averages around 10 µg/kg, American wine around 5. An international survey published in 2017 found means of 34 µg/L in reds and 36 µg/L in whites.

Against a limit of 0.10 mg/kg — that is, 100 µg/kg — typical wine sits three to ten times below it. Most producers testing for the first time find the answer reassuring. The value of the test is not an expectation of failure. It is the ability to state the number to whoever asks for it.

6California: no limit, and the burden is yours

California is the exception that matters most to a European exporter, and it works on a different principle entirely.

Proposition 65 sets no concentration limit for lead in anything. It is a warning law. What it sets is an exposure threshold: 0.5 µg per day for reproductive toxicity, and 15 µg per day for cancer. The lower one governs in practice. Above the threshold you must warn; below it you need not.

The catch is in who has to prove which. The statute places the burden on the defendant. If you wish to rely on being under the threshold, it is your task to demonstrate it, not the regulator's task to demonstrate you are over. Exposure is calculated as concentration multiplied by a reasonably foreseeable rate of intake, and the regulation defines no standard serving for wine.

The enforcement mechanism is what creates the commercial risk. Penalties run to 2,500 dollars per day per violation, and any private individual may bring the action sixty days after giving written notice. There is no regulator to persuade and no inspection to pass. There is a letter, and then a lawsuit.

So California produces a situation with no European equivalent: no number to comply with, and a strong practical reason to hold per-batch lead data anyway. No rule obliges you to test. The burden of proof makes it prudent.

Three further points

Alcoholic beverages are listed under Proposition 65 in their own right, so the warning obligation exists regardless of lead, and the standard warning text covers cancer and reproductive harm together.

The warning is delivered at the point of sale: a sign at eye level, a smaller one at the till, the drinks list for on-premise service, or the shipping package or electronic receipt for direct sales. There is no bottle-label option. The obligation therefore cannot be discharged by the producer alone, and it belongs in the contract with the importer. A 2018 Californian appeal decision confirmed that giving the standard warning constitutes full compliance, and that arguments about its adequacy are for the regulator rather than the courts.

There is an exemption for naturally occurring lead, but it is narrow. You must show that the lead does not come from any known human activity, and that quality controls have reduced it as far as is currently feasible. Given the history set out below, that is a difficult case to make for wine.

7Where the lead actually comes from

Lead in wine is mostly not a vineyard problem.

The best-documented source is winery hardware. A study measuring lead across roughly seven thousand wines concluded that atmospheric contamination did not explain the elevated results, that capsules contributed very little, and that brass fittings were the main cause; inspections of wineries with known problems found brass pipes and taps. Work following Douro wines through the whole process found lead rising from 4.7 µg/L in the must to 17.2 µg/L in the finished fortified wine, meaning only a quarter to a third of the final lead came from soil and air. The shift to stainless steel is the main reason contemporary numbers look the way they do.

Where atmospheric lead does contribute, it does not arrive by the route most people assume. Isotope work on wine from contaminated areas found the lead signature matching airborne particulate rather than the soil beneath the vines. The lead landed on the leaves and fruit; it was not taken up through the roots.

Lead capsules on bottle necks are a real source, and the mechanism is also counterintuitive. Isotope studies in the 1990s found no migration of corrosion products back into a sealed bottle. What happens is that corrosion products on the capsule dissolve as the wine is poured, particularly where the cork has seeped. The capsule matters in the glass, not in the tank. Lead capsules have been prohibited on European wine for decades and in the United States since 1996.

Two lesser sources are worth knowing. Lead arsenate was used as a vine spray, and lead was a contaminant of copper sulphate. And lead crystal is a container problem rather than a production one: wine stored in a lead crystal decanter has been measured at 116 to 2,576 ppb after sixty weeks.

The direction of travel

It is visible in the limits themselves. The OIV recommendation has come down in steps: 0.6 mg/L in 1953, 0.5 in 1975, 0.3 in 1987, 0.25 in 1993, 0.2 in 1996, 0.15 in 2006, and 0.10 from the 2019 harvest. A study tracking French wines across the twentieth century found lead falling from around 0.25 mg/L in the early 1950s to under 0.1 mg/L by 2000, in step with environmental lead.

8What makes a result usable

The vintage. Without it a European result cannot be matched to a row.

The destination market, named. A single number is not a verdict. It becomes one only against a stated rulebook, and this article is a demonstration of how far those rulebooks diverge.

The unit as measured. Not converted silently between a mass basis and a volume basis.

The measurement uncertainty. Every result carries one, and European practice subtracts it from the result before a breach is established. A wine at 0.11 mg/kg against a level of 0.10 mg/kg has not automatically failed. A report that says so is more useful than one that stamps a verdict.

And one sealed bottle describes that bottle. For a tank or a bottling run, it describes the batch only as well as it was drawn from it.