FDA proposes cadmium action levels for baby food under Closer to Zero

Pediatricians fielding parent questions about heavy metals in baby food have a new benchmark. On October 22, 2026, the FDA proposed action levels for cadmium in processed foods intended for children younger than 2 years, with limits ranging from 10 to 45 parts per billion (ppb) depending on food category.¹˒² The draft guidance is the latest step in the agency's Closer to Zero initiative, which previously produced action levels for inorganic arsenic in infant rice cereal and for lead in processed baby foods.¹

In the draft guidance, the agency described the levels as achievable when manufacturers apply control measures, adding that "our expectation is that industry will strive for continual reductions over time."²

Proposed cadmium action levels for baby food categories

The draft guidance covers packaged foods sold in jars, pouches, tubs, or boxes for babies and young children, including ready-to-eat purees and dry infant cereals.² The proposed levels are 10 ppb for fruits, vegetables other than single-ingredient carrots, and mixtures, including grain- and meat-based products; 25 ppb for single-ingredient carrots; 45 ppb for dry infant cereals; 20 ppb for yogurts, puddings, and custards; and 25 ppb for single-ingredient meats.² The guidance does not apply to infant formula, toddler drinks, other beverages, homemade foods, or snack foods such as grain-based and freeze-dried snacks. The FDA said it is still collecting data on grain-based snacks.²

Why cadmium exposure matters in infants and young children

Cadmium enters crops such as root vegetables and cereal grains through contaminated soil, water, and air.² Because cadmium's half-life in humans is approximately 10 to 33 years, even low-level chronic dietary exposure can harm the kidneys and bones, and data also associate early-life exposure with impaired neurodevelopment and altered growth.² The FDA noted that babies and young children may be more susceptible because of differences in metabolism and their small body size.¹

How the FDA derived the cadmium limits for baby food

The agency anchored the levels to a toxicological reference value (TRV) of 0.21 to 0.36 μg/kg of body weight per day, based on kidney and bone effects.² The FDA analyzed 1430 samples collected from fiscal years 2009 to 2024, modeling exposure at the 90th percentile of consumption.² Dry infant cereals had the highest mean cadmium concentration (15.0 ppb), followed by single-ingredient carrots (12.7 ppb), while fruits averaged 1.0 ppb.²

The FDA estimates that 93% of fruit, vegetable, and mixture samples, 84% of single-ingredient carrot samples, 98% of dry infant cereals, and all yogurt and meat samples already fall at or below the proposed levels.² Projected reductions in 90th-percentile exposure are 28% for fruits, vegetables, and mixtures; 32% for carrots; and 5% for dry infant cereals, with no change for yogurts or meats.²

Preventive controls guidance on chemical hazards in food

The FDA also released a draft chapter of its preventive controls for human food guidance under the Food Safety Modernization Act addressing chemical hazards, which the agency said may help companies meet Closer to Zero action levels once finalized.¹˒³

Limitations of the cadmium proposal and counseling considerations

Action levels are nonbinding, although the FDA may regard foods that exceed them as adulterated when weighing enforcement.² In the agency's modeling, 90th-percentile exposure from each food category, assessed individually, was already below the lower bound of the TRV before the limits were applied, suggesting the limits function largely as a ceiling on outlier products.² The modest 5% projected reduction for infant cereal, the highest-cadmium category, and the separate, higher carrot threshold reflect the FDA's effort to balance exposure reduction against keeping nutritious products available.² Snacks, a common toddler food, remain outside the guidance.²

For family counseling, the FDA states the action levels are not intended to direct consumer food choices and recommends a varied, nutrient-dense diet across vegetables, fruits, grains, dairy, and protein foods.²

References

1. US Food and Drug Administration. FDA advances Closer to Zero initiative to safeguard food for children. Constituent update. October 22, 2026. Accessed October 22, 2026. https://www.fda.gov/food/hfp-constituent-updates/fda-advances-closer-zero-initiative-safeguard-food-children

2. US Food and Drug Administration. Action levels for cadmium in processed food intended for babies and young children: draft guidance for industry. October 2026. Accessed October 22, 2026. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/action-levels-cadmium-processed-food-intended-babies-and-young-children-draft-guidance-industry

3. US Food and Drug Administration. Draft guidance for industry: hazard analysis and risk-based preventive controls for human food. Updated October 2026. Accessed October 22, 2026. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/draft-guidance-industry-hazard-analysis-and-risk-based-preventive-controls-human-food