Closer to Zero Roadmap 2026: What Parents Should Track

The short answer

Closer to Zero is FDA's program to cut childhood dietary exposure to arsenic, cadmium, lead, and mercury while keeping nutritious foods available [1]. Lead baby-food action levels are final (January 2025); cadmium is draft (October 2026; comments by December 22, 2026; webinar November 16, 2026); inorganic-arsenic draft guidance is targeted for 2027; lead-in-juices final is targeted for 2027 [1][2][3]. Snacks and infant formula remain outside those published scopes [4][5].

This post is a forward-looking status map — not a cadmium ppb rehash. For the side-by-side lead vs cadmium numbers, see FDA lead vs cadmium action levels. For cadmium-only detail, see draft cadmium explainer.

What is FDA's Closer to Zero program?

The program is FDA's initiative to progressively drive down heavy metals in foods commonly eaten by babies and young children through research, action levels, preventive-controls guidance, and enforcement when products are unsafe [1]. FDA describes a repeating cycle: evaluate the science and achievability, propose draft action levels, consult stakeholders, finalize, then reassess [1].

The program covers arsenic, cadmium, lead, and mercury as environmental contaminants that crops and animals can take up from soil, water, and air [1][2]. Mercury is in the initiative's scope, but FDA says its baby-food survey work has not prioritized mercury action levels for processed foods for babies and young children at this time because measured levels were not a concern in the samples assessed [1]. Separately, FDA is also working on contaminant issues in infant formula under Operation Stork Speed [1].

Which metals have final, draft, or upcoming guidance?

FDA publishes a status table on the FDA program page. Here is that roadmap in parent-readable form, using FDA's stated statuses and target years [1][2][3].

Heavy metal and commodity pair	Status (FDA)	What parents can do with it now
Lead in processed food intended for babies and young children	Final guidance issued January 2025 (after 2023 draft) [1][4]	Compare AB 899 lead lot results to the final ppb grid [4][6]
Cadmium in processed food intended for babies and young children	Draft guidance published October 2026; comments due December 22, 2026 (docket FDA-2025-D-4023) [1][2][3]	Compare lots carefully as draft; comment or attend the Nov 16 webinar [2][7]
Inorganic arsenic in processed food intended for babies and young children	FDA is targeting 2027 to release draft guidance [1]	No broad CTZ draft table yet; watch the CTZ page and Foods Program guidance agenda [1][8]
Lead in juices	Draft guidance issued April 2022; FDA is targeting 2027 to release final guidance [1]	Separate from jar/pouch baby-food lead finals; do not mix the grids [1][4]

FDA's October 22, 2026 constituent update also released draft Chapter 12 guidance on controlling chemical hazards under the Preventive Controls for Human Food rule, with comments requested by January 21, 2027 on docket FDA-2016-D-2343 [2]. That chapter is industry process guidance, not a second set of baby-food ppb numbers.

When is the inorganic arsenic draft expected?

FDA's status table states that the agency is targeting 2027 to release draft guidance on inorganic arsenic in processed food intended for babies and young children [1]. The Foods Program guidance-under-development list likewise includes "Action Levels for Inorganic Arsenic in Food Intended for Babies and Young Children; Draft Guidance for Industry" among topics under consideration [8]. Target years are planning signals, not guaranteed calendar dates — FDA notes priorities and resources can shift [8].

Parents sometimes confuse this upcoming broad baby-food arsenic draft with FDA's earlier work on inorganic arsenic in infant rice cereal. Those are related topics, but the CTZ table row above is the 2027-targeted draft for processed baby food generally [1]. For snack-format arsenic patterns from independent testing, see rice snacks arsenic CR 2026.

What is still excluded (snacks, formula, beverages)?

Published lead (final) and cadmium (draft) action levels for processed baby food both exclude:

Snack foods, including grain-based or freeze-dried snacks (puffs, rusks, teething biscuits, and similar) [4][5]
Infant formula [4][5]
Beverages, including toddler drinks [4][5]
Homemade foods and raw agricultural commodities [4][5]

FDA says it continues to collect grain-based snack data to decide whether snack action levels are appropriate [4][5]. Juice lead remains on its own draft→final track (final targeted 2027) [1]. Infant formula contaminant work is pointed to Operation Stork Speed on that FDA page rather than these baby-food action-level PDFs [1].

Exclusion from an action-level table is not the same as "FDA cannot act." FDA states it does not need an action level to take action when a food is unsafe [1]. Independent testing still matters for excluded formats — Consumer Reports' 2026 baby-food project is one place parents look for snack vs purée patterns (microplastics subset; rice snacks arsenic).

How does this relate to AB 899 and Consumer Reports tests?

These FDA action levels are federal FDA guidance tools. California AB 899 is a state disclosure law that requires testing and posting of lead, arsenic, cadmium, and mercury results for covered baby foods sold in California [6][9]. They complement each other:

Use AB 899 (or similar state) lot/public results to see what a brand measured on a given lot [6][9].
Use FDA action levels (final for lead; draft for cadmium) as the comparison grid for categories those guidances cover [4][5].
Use CR or other independent labs as a separate snapshot — useful for snacks or questions FDA has not numbered yet, but not a substitute for FDA's legal framework [10].

For lot-code vs public-page mechanics, see AB 899 public vs lot-code. How World of Baby Food weighs disclosure and independent flags is on methodology and the homepage rankings.

Where do I comment on cadmium before December 22?

FDA asks for comments on the draft cadmium guidance by December 22, 2026 via regulations.gov docket FDA-2025-D-4023 so comments can be considered before work on the final begins [2][3]. FDA is also holding a free webinar, "Closer to Zero Updates Including Cadmium Action Levels," on November 16, 2026, 1:00–2:00 p.m. ET (registration required) covering the cadmium draft, Chapter 12 chemical-hazards guidance, and the CTZ webpage refresh [2][7].

Step-by-step comment and webinar tips live in FDA cadmium comment + webinar guide. For the ppb categories themselves, use cadmium action levels explainer or the lead vs cadmium side-by-side.

This article is for information only and is not medical advice. If your child has specific feeding needs, talk with your pediatrician before changing their diet.

FAQ

Is this FDA program a law that bans baby food above a number?

No. Action levels in that guidance clarify concentrations at which FDA may regard a food as adulterated and consider enforcement; FDA says guidance documents are not themselves binding legislative rules in the same way statutes are, and parents should not treat them as a cue to discard all packaged baby food [1][4].

Which metal already has final baby-food action levels?

Lead in certain processed foods intended for babies and young children — final guidance January 2025 [1][4]. Cadmium is draft as of October 2026 [1][2].

When will juice lead limits be finalized?

FDA's CTZ status table says it is targeting 2027 to release final guidance for lead in juices (draft was issued April 2022) [1].

Do snacks get cadmium or lead action levels under these baby-food guidances?

Not in the published lead final or cadmium draft scopes; FDA is still collecting grain-based snack data [4][5].

Where should I watch for the arsenic draft?

FDA's status table and the Foods Program guidance-under-development list; both point to a 2027-targeted inorganic-arsenic draft for foods intended for babies and young children [1][8].

References

U.S. FDA, Closer to Zero: Reducing Childhood Exposure to Heavy Metals from Foods.
U.S. FDA, FDA Advances Closer to Zero Initiative to Safeguard Food for Children (October 22, 2026).
Federal Register, Action Levels for Cadmium in Processed Food Intended for Babies and Young Children; Draft Guidance for Industry; Availability (91 FR 66796, October 23, 2026).
U.S. FDA, Action Levels for Lead in Processed Food Intended for Babies and Young Children: Guidance for Industry (final guidance PDF).
U.S. FDA, Action Levels for Cadmium in Processed Food Intended for Babies and Young Children: Draft Guidance for Industry (draft PDF).
Consumer Reports, Best Baby Food Brands for Reporting Heavy Metals: California AB 899.
U.S. FDA, Webinar on Closer to Zero Updates Including Cadmium Action Levels — November 16, 2026.
U.S. FDA, Foods Program Guidance Under Development.
Unleaded Kids, Update on Baby Food disclosure tracker.
Consumer Reports, We Tested 48 Baby Foods for Heavy Metals and Microplastics (September 17, 2026).