1One element per product

A heavy-metals panel reports four elements: lead, cadmium, mercury and arsenic. A brand with twelve products does not have forty-eight questions. For each product one of the four is the one that fails, it comes from one identifiable place, and Regulation (EU) 2023/915 gives it one number or, where it gives none, one rule for deriving it.

The figure below puts six measured products against the row that applies to each of them, expressed as a multiple of that row so that different elements and different limits can share one axis. Everything to the right of the gold line is above its limit.

2What the four numbers protect against

The limits are not arbitrary and they are not all of one kind. Each element has a different target organ, a different reference value behind its row, and a different relation between what the panel measures and what the toxicologist means.

3What an exceedance costs the producer

Three sentences of the regulation set the cost.

Article 2(1). Food listed in Annex I "shall not be placed on the market and shall not be used as a raw material in food or as an ingredient in food where it contains a contaminant at a level which exceeds the maximum level".

Article 2(2). Food complying with the maximum levels "shall not be mixed with food which exceeds these maximum levels".

Article 4. Food containing the listed contaminants "shall not be deliberately detoxified by chemical treatments".

In plain words: a batch above its number cannot be sold, cannot be used as an ingredient, cannot be blended with a clean batch to bring the average under the line, and cannot be treated to remove the metal. If it has already been sold it is withdrawn or recalled and reported through the Rapid Alert System for Food and Feed, whose portal is public and is read by buyers as well as by authorities. The finding is per batch: one high lot does not condemn the product line, and the next lot is judged on its own result.

4Plant protein powders: pea, soy, rice

The metal

Cadmium. Arsenic as well when the base is rice.

Where it comes from

The plant takes the metal from the soil, and isolating the protein concentrates part of it with the protein. Rice is the exception among the three: it takes up arsenic from flooded paddies and stores most of it in the bran. Rice-bran powders and tablets have been measured at 284 to 767 µg/kg of inorganic arsenic, 1.4 to 3.3 times the limit for white rice, and the bran of a grain holds more arsenic than the kernel. Whey is not a plant and does not take metal from soil, which is why it is the comparator for this category rather than a member of it.

The number

No row exists for a protein isolate. Sold as a food supplement, the product takes the supplement rows: lead 3.0 mg/kg, cadmium 1.0 mg/kg, mercury 0.10 mg/kg, and no arsenic row. Sold as a food, Article 3 applies; for rice protein the reference is the rice-flour row of 0.25 mg/kg inorganic arsenic together with the concentration factor from grain to isolate, which the operator must be able to justify.

When to test

Per supplier lot of isolate. The certificate for the grain does not cover the isolate, because the concentration step is where the number changes.

5Chocolate-flavoured proteins and mass gainers

The metal

Cadmium, from the cocoa powder in the flavour system, not from the protein.

Where it comes from

The cacao tree takes cadmium from the soil, and beans from Latin American origins are the highest. In a 2026 survey of 103 commercial cocoa powders from twelve countries, cadmium ranged from below detection to 1.30 mg/kg and 15.5 % of samples were above the EU cocoa-powder limit. One unit of soil pH changes bean cadmium by a factor of 1.6, and about 30 % of Ecuador's cocoa area produces beans above 0.6 mg/kg. The number changes with origin and with lot.

The number

The cocoa rows are set by cocoa content, and the one that matters to a blender is the last.

Under Article 2(1) a cocoa lot above 0.60 mg/kg cannot be used as an ingredient at all, whatever the finished product's status. The finished product then takes the supplement row of 1.0 mg/kg if it is sold as a supplement, or Article 3 if it is sold as a food.

When to test

The cocoa lot, before it goes into the blend. A new origin is a new lot.

6Greens and superfood powders: spirulina, chlorella, wheatgrass, barley grass

The metal

Lead, and arsenic for algae grown in open ponds.

Where it comes from

The water and the dust at the growing site. Spirulina is grown in open ponds, chlorella usually in closed systems, and the grasses in fields; the site changes with every supplier. A survey of thirteen spirulina and four chlorella products on the Polish market found lead from below 0.02 to 0.38 mg/kg, cadmium up to 0.078 mg/kg and mercury up to 0.017 mg/kg, all below the supplement rows. The spread between products was a factor of twenty for lead, which is the point: the category is safe on average and variable by supplier.

The number

The supplement rows: lead 3.0 mg/kg, cadmium 1.0 mg/kg, mercury 0.10 mg/kg. The 3.0 mg/kg cadmium row for seaweed-based supplements does not apply to spirulina or chlorella, which are not seaweed. There is no arsenic row; the panel's total-arsenic result is the figure to keep on file.

When to test

Per algae lot. A blend of several greens is tested as the blend, and the result is read against the supplement rows.

7Bee products: honey, pollen, propolis, royal jelly

The metal

Lead.

Where it comes from

The surroundings of the apiary. Bees forage up to 10 km from the hive and bring back what settles on flowers: lead from road traffic and from industrial dust. Honey from urban apiaries is higher than from rural ones; in one Italian survey the two elevated samples came from hives next to a busy road and an industrial site; honey from industrial areas of Romania has measured 0.19 to 0.20 mg/kg. Pollen and propolis concentrate more than honey: 0.27 mg/kg of lead in pollen from an urban Italian apiary, and 0.046 to 0.96 mg/kg in propolis from Turkey.

The number

Honey has its own row, and it is one of the strictest in the regulation: 0.10 mg/kg of lead. Pollen, propolis and royal jelly have no rows of their own; sold as supplements they take the supplement rows, lead 3.0 mg/kg, cadmium 1.0 mg/kg, mercury 0.10 mg/kg. The same hive can therefore produce a honey that fails and a pollen that passes with a wide margin, because the two are judged thirty-fold apart.

When to test

Per apiary site and per season for honey; per supplier for pollen and propolis, because a brand rarely knows where its supplier's hives stand.

8One table to keep

The four sections reduce to one table and one diagram. The table gives the element, the source, the row and the sampling point; the diagram shows where in each product's route the sample is drawn.