Australia New Zealand: Food Standards Code – Maximum Level of Cadmium in Cocoa and Cocoa Products

Full summary

Under the FSANZ framework, cocoa and cocoa products are currently subject to a single maximum level of 0.5 mg/kg cadmium, applied uniformly across the category. This limit functions as a blanket cap for cadmium in cocoa powders, cocoa mass, chocolate, and other cocoa‑based foods, irrespective of specific product type or cocoa content. It is an existing element of the standards code rather than a newly adopted measure and therefore represents an ongoing compliance expectation for exporters and domestic manufacturers supplying the Australian and New Zealand markets.

The reason this measure is now being surfaced on the CAA dashboard is not due to a recent regulatory change, but to inform CAA members about CAA’s advocacy activities. CAA will initiate an appeal to the relevant FSANZ decision‑makers to review whether a single maximum level is appropriate for all cocoa and cocoa products, and to consider more risk‑proportionate or differentiated limits (for example, by cocoa content or product category). The dashboard entry therefore acts as an update on CAA’s action and engagement, rather than as a notification of a new regulatory obligation.

Scope & Applicability

• Applies to cocoa and cocoa products marketed in Australia and New Zealand, whether produced domestically or imported.

• Covers a wide range of cocoa‑based foods (such as cocoa powder, cocoa liquor/mass, chocolate, and chocolate products) which fall under the cocoa category referenced in the maximum level schedule.

• Applies at the point where the food is offered for sale to consumers or for food‑service use.

Key Requirement

• A single maximum level of 0.5 mg/kg cadmium applies to all cocoa and cocoa products within the scope of the FSANZ standard.

• Products exceeding 0.5 mg/kg cadmium are non‑compliant and may be subject to enforcement measures, including rejection, recall, or other regulatory intervention.

• Food business operators are expected to maintain appropriate specifications, supplier controls, and testing programs to demonstrate that cadmium concentrations in cocoa and cocoa products are consistently at or below the limit.

Compliance deadlines

• No new or staged compliance dates are associated with this limit; it is already in force and applies to current and future supplies.

• CAA’s planned appeal or dialogue with FSANZ does not suspend or defer compliance duties; operators must fully comply with the existing limit unless and until the code is formally amended.

Potential impact on cocoa sector

• The uniform ML of 0.5 mg/kg can restrict sourcing from origins with naturally higher cadmium in cocoa beans, potentially requiring origin diversification, blending, or exclusion of certain sources.

• High‑cocoa products (cocoa powder, cocoa liquor, and high‑percentage dark chocolate) are more exposed, because cadmium is associated with cocoa solids, while lower‑cocoa products face relatively less technical pressure.

• Exporters targeting Australia and New Zealand may face increased testing costs, more complex supply‑chain qualification, and tighter product‑specification management to ensure all lines comply with the same limit.

• The absence of differentiated limits across cocoa product types can create commercial and technical challenges that motivate sector‑wide advocacy for a more nuanced system.

  
  

CAA Notes & interpretations

• This FSANZ requirement is not new; the single 0.5 mg/kg cadmium ML has been in place and remains enforceable. It is being flagged on the CAA dashboard to provide transparency on CAA’s decision to formally approach the relevant authority to re‑evaluate the single‑limit approach for cocoa and cocoa products.

• CAA’s position is that differentiated limits aligned with cocoa content or product subcategories would better reflect exposure realities and international regulatory developments, and would reduce disproportionate impacts on certain high‑cocoa products and origins.

• Until there is any formal amendment, CAA advises members to operate on the basis that the 0.5 mg/kg limit applies to all cocoa and cocoa products destined for Australia and New Zealand and to ensure that cadmium‑control strategies (testing, origin management, blending, and specifications) are robust.

• Members are encouraged to channel data on cadmium levels, trade impacts, and compliance difficulties to CAA to strengthen the evidence base supporting the ongoing appeal.

  
  

Downloadable source

• Australia New Zealand Food Standards Code – Australia New Zealand Food Standards Code – Schedule 19 – Maximum levels of contaminants and natural toxicants - Federal Register of Legislation