Bill 899 and the Future of Baby Food Safety Standards
Concerns about heavy metals in food have been growing for years, as research continues to show how harmful contaminants like arsenic, lead, cadmium and mercury can be, especially for infants. In response, California passed Assembly Bill 899, a law aimed at holding baby food manufacturers to a higher standard and mandating monthly testing of finished baby food products.
Why California Bill 899 Matters
Exposure to heavy metal contaminants can come from numerous sources—the environment, food and ecosystems—and it ultimately ends up in humans. The concern over toxicity of heavy metals is greater for infants because it can have a greater impact due to their lower body weight.
A few years ago, Congress introduced the Baby Food Safety Act, which proposed limits for heavy metals in baby food. Those limits are:
- Cadmium - 5 ppb (parts per billion)
- Lead - 5 ppb
- Mercury - 2 ppb
- Arsenic - 10 ppb
The FDA’s “Closer to Zero” initiative aims to reduce exposure to toxic heavy metals in foods consumed by infants and young children. Grounded in scientific research and data evaluation, the program establishes proposed action levels for contaminants such as lead, arsenic, cadmium, and mercury. The first phase, focused on lead, concluded with final guidance issued in January 2025. Final recommendations for the remaining metals are anticipated in 2026. A full timeline and additional details can be found on the FDA’s website.
What is California Bill 899?
Effective January 1, 2024, California Assembly Bill 899 mandates that baby food manufacturers selling products in the state conduct monthly testing on representative samples from each production lot or batch. These tests must be carried out by qualified laboratories that meet specific proficiency standards and must screen for toxic elements as outlined in the legislation. The bill also outlines the following definitions:
- “Baby food” - products packaged in jars, pouches, tubs or boxes for children under 2 years old. It explicitly excludes infant formula. Infant formula is regulated separately and already has stringent requirements under other federal programs.
- “Final baby food product” - finished products identified by a unique UPC (this differs from prior practices focused on testing ingredients rather than finished goods).
- “Product label” - what’s displayed on packaging.
- “Product shelf life” - the time between manufacturing and expiration.
- “Production aggregate” - a batch or lot intended to be uniform in composition and quality.
- “Representative sample” - product units selected via rational methods like random or systematic sampling to represent the lot.
- “Toxic elements” - arsenic, cadmium, lead and mercury.
Testing must be performed by a qualified laboratory holding ISO 17025 accreditation, ensuring compliance with industry-recognized standards. To meet regulatory expectations, the lab must adhere to the FDA’s limit of quantitation (LOQ) thresholds, follow methodologies outlined in the FDA Elemental Analysis Manual, and successfully participate in proficiency testing with a z-score within ±2.
The LOQ thresholds established by the bill are as follows: 11.6 ppb for arsenic, 3.71 ppb for cadmium, 10.9 ppb for lead, and 7.82 ppb for mercury—values derived from multi-laboratory validation studies.
Compliance and the Testing Timeline
As of January 2024, manufacturers must test for arsenic, cadmium, lead and mercury monthly for each unique UPC and make the results available to government agencies upon request. Beginning January 2025, testing results also must be published on the manufacturer’s website, and include information on the product name, UPC, size and batch or lot numbers. The expectation is that consumers can look up lot numbers or UPC codes to find testing results on the baby food they bought.
Products subject to FDA action levels or tolerance levels must include a QR code or other machine-readable code that links to a manufacturer’s website on the product’s label. That code must link to: (1) test results for the element, (2) the FDA webpage with health information and current guidance, and (3) a statement encouraging consumers to scan the code for more information. This QR code requirement only applies when such action levels exist.
From Legislation to Action: A Safer Future for Baby Food
California Assembly Bill 899 sets a clear and comprehensive framework for ensuring the safety of baby food products sold within the state. By requiring monthly testing of finished products for heavy metals—including arsenic, cadmium, lead, and mercury—the legislation reinforces a commitment to transparency, consumer protection, and public health. Laboratories conducting this testing must meet stringent proficiency standards and apply approved analytical methods to ensure accuracy and consistency in results.
Importantly, once action levels are established, manufacturers must make test results accessible not only to regulators but also to the public, incorporating tools like QR codes to support informed decision-making by consumers. Although the bill centers on finished product testing, proactive ingredient monitoring remains a critical part of a robust quality control program, helping manufacturers maintain compliance and uphold the highest safety standards throughout the supply chain.
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About the Author
Grace Bandong
Business Unit Manager
Eurofins Food Chemistry Madison, Inc- Contaminants & Inorganics
Grace has spent over 35 years in the food and supplement industry specializing in contaminants analysis including elemental analysis, pesticide residue analysis, and risk assessments. In her tenured career, Grace has developed contaminant-testing programs that support supplier verification for food manufacturers and dietary supplement companies. She is an expert in chemical risk assessment for dietary supplements and food.
Additional Resources:
Guide to California Bill 899 and Baby Food Standards Infographic
How to Ensure the Chemical Safety of Infant Formula and Baby Foods
