EC 2019 — Cadmium in Chocolate (consumer information leaflet)

This is a two-page consumer information leaflet issued by the European Commission around the 1 January 2019 cocoa-products enforcement deadline of Commission Regulation (EU) No 488/2014. The leaflet’s purpose is to communicate, in plain language, the four cadmium maximum levels that the 2014 amendment of 1881/2006 set for chocolate and drinking-chocolate cocoa powder, and to explain why the levels apply to the finished product rather than to the cocoa beans. It is not a legal instrument; it is a public-facing Commission communication that summarises the binding text already in force.

Source role

For Heavy Metal Index, the leaflet’s value is as a primary-source quotation of the 488/2014 cadmium ceilings as they were communicated to the EU public in 2019, and as the Commission’s own framing of why those ceilings sit on processed product rather than on raw cocoa beans (the impact-alleviation rationale for cocoa-bean producers). The 488/2014 cadmium ceilings were subsequently re-issued and re-numbered through Commission Regulation (EU) 2021/1323 (see eu-2021-1323-cadmium-foodstuffs-amendment) and then consolidated into Commission Regulation (EU) 2023/915 (see eu-2023-915-cadmium). The four cadmium values for chocolate and drinking-chocolate cocoa powder were carried forward unchanged through all three texts; the leaflet is the cleanest period-appropriate citation for the 2014–2021 enforcement window.

The leaflet also documents the Commission’s policy framing around cadmium in cocoa: that the levels were set with reference to the EFSA risk analysis and Codex Alimentarius standards, that the four-year transitional window (1 January 2015 → 1 January 2019) was a deliberate accommodation for cocoa producers and processors, and that the EU was, as of 2019, financing capacity-building, research, and a DeSIRA-Initiative intervention in Colombia, Ecuador and Peru aimed at low-cadmium cocoa production.

Legal character

The leaflet itself is non-binding. The numerical ceilings it cites were binding under Commission Regulation (EU) No 488/2014 of 12 May 2014 (OJ L 138, 13.5.2014, p. 75), an amendment of Annex Section 3.2 of Regulation (EC) No 1881/2006 (see eu-1881-2006-contaminants-superseded). The cocoa/chocolate rows entered force for new products placed on the EU market from 1 January 2019; rows for “other food products” had entered force on 1 January 2015. The four-year transitional window was negotiated specifically for cocoa producers and processors.

The ceilings apply to the finished product (chocolate or drinking-chocolate cocoa powder placed on the market), not to the raw cocoa beans. The Commission’s framing in the leaflet is that this choice alleviates the compliance burden on bean producers, who can blend lots of differing cadmium content to meet the finished-product specification.

HMTc interpretation

The four 488/2014 cocoa-product cadmium ceilings (0,10 / 0,30 / 0,80 mg/kg by total dry cocoa solids percentage; 0,60 mg/kg for drinking-chocolate cocoa powder) are external legal floors, not HMTc certification thresholds. They are the binding EU comparator values for any chocolate or cocoa-powder product placed on the EU market between 1 January 2019 and the entry into force of 2021/1323 on 31 August 2021. HMTc workups on the chocolate product category should preserve the legal-status label (“binding EU maximum level — 2019 communication of 488/2014”) when displaying these numbers alongside Codex maximum levels, FDA action levels, or HMTc candidate thresholds.

The four-row split by total dry cocoa solids percentage is the row pattern that downstream chocolate product-category work should preserve: it is the binding regulatory recognition that cadmium burden in a finished chocolate is a function of the cocoa-mass fraction, and any HMTc within-row clean/dirty subcategory work for chocolate should sit inside that four-row ladder rather than across it.

Cadmium maximum levels communicated by the leaflet

Values are mg/kg, finished product, wet weight, as displayed on page 2 of the leaflet. Decimal points are preserved verbatim from the leaflet text.

The leaflet’s accompanying caption is “The darker the chocolate, the higher the maximum levels,” which is the Commission’s own one-line synthesis of the ladder.

Methods (brief)

This is a Commission communication, not an empirical study. No analytical method, sampling regime, or LOD/LOQ is specified in the leaflet itself. The leaflet’s framing of the regulatory basis is brief: it states that the EU “undertook a risk analysis” and that the levels are in line with Codex Alimentarius standards, without citing specific EFSA opinions, TWI values, or occurrence-monitoring datasets by name. The cited maximum levels were administratively set in 488/2014 on the basis of the EFSA CONTAM 2009 cadmium opinion (tolerable weekly intake 2,5 µg/kg body weight), Member-State occurrence-monitoring data, and alignment with Codex Alimentarius — these specific underlying references come from the regulatory-historical record for 488/2014 and EFSA, not from the leaflet itself. The official-control sampling and analysis rules sit in separate Commission implementing regulations, not in the leaflet or in 488/2014.

Key numbers

• Cadmium ceiling, chocolate < 30 % total dry cocoa solids: 0.10 mg/kg (page 2).
• Cadmium ceiling, chocolate ≥ 30 % and < 50 % total dry cocoa solids: 0.30 mg/kg (page 2).
• Cadmium ceiling, chocolate ≥ 50 % total dry cocoa solids: 0.80 mg/kg (page 2).
• Cadmium ceiling, drinking-chocolate cocoa powder sold to the final consumer: 0.60 mg/kg (page 2).
• Effective date for the cocoa-product rows: 1 January 2019 (page 2).
• Effective date for “other food products” already under 488/2014: 1 January 2015 (page 2).
• Transitional implementation window for cocoa producers and processors: four years from 1 January 2015 to 1 January 2019 (page 2).
• Stated EU share of world population referenced in the leaflet’s framing: 6 % (page 1).
• Stated EU share of world chocolate consumption referenced in the leaflet’s framing: 50 % (page 1, “of the world COCOA” pull-quote with “half of the world’s chocolate” in body text).
• Stated EU domestic cocoa production: zero — the EU imports all cocoa or cocoa beans it uses (page 1).
• DeSIRA (Development-Smart Innovation through Research in Agriculture) intervention referenced in the leaflet: a 6 million Euros programme on low-cadmium and climate-relevant cocoa innovation in Colombia, Ecuador and Peru (page 2).

The leaflet also restates the EFSA / IARC characterisation of cadmium as a toxic heavy metal with effects on kidneys, lungs and bones, classified as a human carcinogen, and notes natural cadmium sources (volcanic activity, forest fires, rock weathering) and the influence of geographic location, soil acidity, and cocoa variety on cocoa-bean cadmium burden.

Implications

For the chocolate product-category page, this leaflet supplies the 2019 binding-regulatory-context column: the four maximum levels that were in force from 1 January 2019 onward under 488/2014, before the 2021/1323 amendment and the 2023/915 consolidation. HMTc workups for chocolate should treat these values as the period-appropriate EU regulatory floor for chocolate placed on the market between 1 January 2019 and 31 August 2021.

For the cocoa ingredient page, the leaflet supplies the Commission’s own articulation of why ceilings sit on the finished chocolate rather than on cocoa beans, and the Commission’s framing of cocoa-bean cadmium burden as soil-and-variety-driven rather than processing-driven. The 488/2014 ceilings do not constrain cocoa-bean inputs directly; they constrain the finished product’s compliance posture, which propagates back to the supply chain through blending and lot selection. This is relevant for any HMTc workup that has to draw a line between “raw cocoa beans” and “chocolate as placed on the market.”

The DeSIRA reference is a small but useful data point for the regulation/policy timeline: it establishes that as of 2019 the EU was financing low-cadmium-cocoa agronomic research in the three Latin American countries that produce the highest-cadmium cocoa beans (Colombia, Ecuador, Peru). Source pages reporting cadmium in cocoa beans from these origins after 2019 should be read against the backdrop of an active, EU-funded mitigation programme rather than a no-intervention baseline.

For the EU regulatory-framework timeline page (see eu-regulatory-framework-timeline), the leaflet is the Commission’s own dated communication that the 488/2014 cocoa-product ceilings entered into force on 1 January 2019 and are the values then in effect.

Verification notes

• Ingested 2026-06-02 from the Kimi-agent download-corruption manual-fetch batch (04_Chocolate_Seasonings_Salt). PDF is a two-page Commission consumer information leaflet, dated by context to 2019 (filename year and content focus on the 1 January 2019 enforcement deadline).
• The leaflet uses decimal points (e.g., “0.10 mg/kg”) in the as-displayed graphic. The numbers are preserved verbatim from the leaflet rather than converted to the decimal-comma convention used in the Official Journal text of 488/2014 and 2021/1323; readers comparing the two should not infer numerical disagreement from the punctuation difference. The four cadmium ceilings for cocoa products in the leaflet match the four cadmium ceilings in eu-2021-1323-cadmium-foodstuffs-amendment sections 3.2.13.1 through 3.2.13.4 exactly.
• The leaflet refers to “milk chocolate” only in the < 30 % bin. The legal text in 488/2014 (and 2021/1323) carves out milk chocolate explicitly in two of the four rows; the leaflet’s simplified four-bin display does not reproduce that carve-out distinction. The maximum-levels table above reproduces the leaflet’s simplified display verbatim; for the legally precise milk-chocolate carve-out, cite eu-2021-1323-cadmium-foodstuffs-amendment or the underlying 488/2014 text.
• No brand names appear in the leaflet; no Part 12 redaction was required.
• No HMTc threshold inference or synthesis claim added. The ## Implications section describes regulatory-context routing for chocolate and cocoa pages, not HMTc threshold proposals.
• No DOI assigned to the leaflet (Commission consumer-information document, not a peer-reviewed publication). no_doi_assigned: true is recorded in frontmatter.
• The leaflet was likely also issued in other EU languages; only the English version is ingested here.
• Audit subagent (2026-06-02, fresh-context general-purpose) verdict PROMOTE. Two ⚠️ housekeeping concerns raised: (1) ## Methods (brief) should more explicitly flag that the EFSA CONTAM 2009 TWI (2,5 µg/kg bw) and Codex-alignment details come from the regulatory-historical record for 488/2014 rather than from the leaflet’s own text — applied: a one-clause aside was added clarifying that the leaflet’s own framing is the brief “EU undertook a risk analysis / in line with Codex” wording and the specific underlying references are from the regulatory-historical record; (2) [[synthesis/eu-regulatory-framework-timeline]] wikilink was flagged as a possible orphan reference because the auditor could not verify it against the closed taxonomy snapshot (which lists only ingredients/products/metals/regulations, not synthesis pages) — verified false positive against wiki/synthesis/eu-regulatory-framework-timeline.md (page exists on disk); the synthesis namespace is intentionally out of the taxonomy snapshot’s scope and the wikilink is retained.

Sources

• European Commission. 2019. Cadmium in Chocolate (consumer information leaflet). Directorate-General for Health and Food Safety.
• Commission Regulation (EU) No 488/2014 of 12 May 2014 amending Regulation (EC) No 1881/2006 as regards maximum levels of cadmium in foodstuffs. OJ L 138, 13.5.2014, p. 75.
• Commission Regulation (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs. OJ L 364, 20.12.2006, p. 5.
• EFSA Panel on Contaminants in the Food Chain (CONTAM). 2009. Scientific opinion on cadmium in food. EFSA Journal 980, 1–139.
• Codex Alimentarius Commission. General Standard for Contaminants and Toxins in Food and Feed (CXS 193-1995, as amended).

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.