Fourteen years is a long time to wait for a number. In January 2025, the FDA finally published one: the maximum amount of lead it considers achievable in a jar of baby food. Cadmium and arsenic don't have that number yet. The agency says it's writing it this year.
Start with what actually happened, in order. On January 7, 2025, the FDA published final guidance setting action levels for lead in processed food intended for babies and young children, with a correction issued that April. The levels are not uniform: 10 parts per billion for fruits, vegetables other than root vegetables, fruit-and-vegetable mixtures, yogurts, custards and puddings, and single-ingredient meats; 20 parts per billion for single-ingredient root vegetables and dry infant cereal. These are action levels, not legal tolerances set through formal rulemaking — a distinction that matters. An action level tells FDA when a product's contamination is high enough to warrant enforcement scrutiny; it does not automatically make a product illegal to sell, and it is not the same kind of binding limit as, say, a pesticide tolerance under 40 CFR Part 180.
Lead in solid food was the piece that got finished first. Lead and arsenic in juice have their own, separate history: FDA finalized a 10 ppb action level for inorganic arsenic in apple juice back in June 2023, but a parallel draft guidance proposing lead limits for juice — 10 ppb for apple juice, 20 ppb for other single-strength juices — has sat in draft form since April 2022 and still hasn't been finalized as of this writing. And per FDA's own 2026 Human Foods Program priority list, the agency plans to "advance work" this year to establish its first action levels for cadmium and inorganic arsenic in baby and toddler food generally. Right now, the only inorganic-arsenic action level that exists for a baby-food category is the 100 ppb level for infant rice cereal, set in August 2020 — narrower than most people assume.
The reason any of this exists traces back to Congress, not FDA's own initiative. In February 2021, a staff report from the House Oversight Committee's Subcommittee on Economic and Consumer Policy examined internal manufacturer testing data and reported finding arsenic, lead, cadmium, and mercury in baby food products, along with a more specific and pointed claim: that manufacturers had set their own internal contamination ceilings, sometimes exceeded even those self-imposed limits, and tested raw ingredients rather than the finished product on the shelf. A second report that September named additional brands. Two months after the first report, in April 2021, FDA launched Closer to Zero, its structured plan to evaluate, propose, consult on, and finalize action levels for all four metals in foods young children eat most. Four years later, one of those four numbers — lead in solid food — is done.
Where this gets genuinely interesting is the comparison across the Atlantic, and it cuts against the usual assumption. The EU's baby-food contaminant rule, Commission Regulation (EU) 2023/915, in force since May 2023, set a single blanket maximum for the whole "baby food and processed cereal-based food" category: 20 ppb for lead and 40 ppb for cadmium, no matter what the food is. The US finalized its lead levels almost two years later, but for most categories — fruit purees, vegetable blends, yogurts, meats — the new American number is 10 ppb, half the EU's blanket standard. Only for root vegetables and dry cereal does the US level match the EU's exactly, at 20 ppb. So on lead, in the categories where most jarred baby food actually falls, the US just became the stricter regulator, not the looser one. On cadmium, it's the reverse: the EU has had an enforceable number since 2023, and the US doesn't have one yet at all. Neither side is uniformly stricter; the record is genuinely split, category by category, metal by metal — which is closer to the truth of most food-safety divergence than either "Europe is safer" or "the US is safer" ever is. A much older Codex Alimentarius standard, adopted by the UN's FAO/WHO food-standards body in 2014, set infant formula's lead ceiling at 10 ppb — the same number the US only applied to solid baby food more than a decade later.
None of this shows up on a package. There's no federal requirement that a jar of baby food disclose its lead, cadmium, or arsenic test results, and an FDA action level isn't a label claim — it's a number FDA uses internally to decide when to look closer at a product. The one place this is starting to change is Maryland, where a 2024 law nicknamed Rudy's Law now requires baby food manufacturers selling in the state to test monthly for all four metals; starting in 2026, they also have to publish the results and put a QR code on the label linking to them. It's the first attempt anywhere to put this specific record in front of a parent at the point of purchase, rather than in a federal guidance document nobody outside the industry reads.
That's the gap PurityIQ exists to close without another layer of interpretation stacked on top of the FDA's or the EU's. Where the two disagree, the app shows both numbers and the regulation each rests on, so the divergence stays visible instead of getting flattened into a single score. No verdict, no grade — the public record, at the shelf, cited to its source. You still decide what to buy. You just get to see what regulators actually did, and didn't yet do, before you decide.
Sources:
-
FDA: Closer to Zero: Reducing Childhood Exposure to Contaminants from Foods — https://www.fda.gov/food/environmental-contaminants-food/closer-zero-reducing-childhood-exposure-contaminants-foods
-
House Oversight Committee, Subcommittee on Economic and Consumer Policy Staff Report (Feb. 4, 2021) — https://oversightdemocrats.house.gov/news/press-releases/oversight-subcommittee-staff-report-reveals-top-baby-foods-contain-dangerous
-
House Oversight Committee, Subcommittee on Economic and Consumer Policy Staff Report (Sept. 29, 2021) — https://oversightdemocrats.house.gov/news/press-releases/oversight-subcommittee-staff-report-reveals-alarming-levels-of-toxic-heavy
-
Federal Register: Action Levels for Lead in Processed Food Intended for Babies and Young Children; Guidance for Industry (Jan. 7, 2025) — https://www.federalregister.gov/documents/2025/01/07/2024-31534/action-levels-for-lead-in-processed-food-intended-for-babies-and-young-children-guidance-for
-
Federal Register: Correction (Apr. 21, 2025) — https://www.federalregister.gov/documents/2025/04/21/2025-06786/action-levels-for-lead-in-processed-food-intended-for-babies-and-young-children-guidance-for
-
FDA: Inorganic Arsenic in Rice Cereals for Infants: Action Level — https://www.fda.gov/media/97234/download
-
Federal Register: Inorganic Arsenic in Rice Cereals for Infants: Action Level; Guidance for Industry (Aug. 6, 2020) — https://www.federalregister.gov/documents/2020/08/06/2020-17169/inorganic-arsenic-in-rice-cereals-for-infants-action-level-guidance-for-industry-availability
-
Federal Register: Action Level for Inorganic Arsenic in Apple Juice; Guidance for Industry (June 2, 2023) — https://www.federalregister.gov/documents/2023/06/02/2023-11769/action-level-for-inorganic-arsenic-in-apple-juice-guidance-for-industry-availability
-
FDA: Draft Guidance for Industry, Action Levels for Lead in Juice (Apr. 2022) — https://www.fda.gov/media/157949/download
-
FDA: Human Foods Program 2026 Priority Deliverables — https://www.fda.gov/about-fda/human-foods-program/human-foods-program-2026-priority-deliverables
-
Commission Regulation (EU) 2023/915 of 25 April 2023 (Annex I, categories 3.1.26 and 3.2.20) — https://eur-lex.europa.eu/eli/reg/2023/915/oj/eng
-
Codex Alimentarius Commission maximum level for lead in infant formula, per FAO/WHO newsroom — https://www.fao.org/newsroom/detail/UN-strengthens-regulations-on-lead-in-infant-formula-and-arsenic-in-rice/en
-
Maryland House Bill 97 / Chapter 953 (2024 Session), "Rudy's Law" — https://mgaleg.maryland.gov/2024RS/chapters_noln/Ch_953_hb0097E.pdf