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FDA's Draft Cadmium Limits for Baby Food (2026): What the Numbers Mean for Parents

On October 22, 2026, the U.S. Food and Drug Administration published draft guidance proposing the first action levels for cadmium in processed foods made for babies and young children under two. It is the second metal to get numbers under the agency's Closer to Zero program, after lead in January 2025, and it lands in the same season that Consumer Reports published its most reassuring baby-food heavy-metal tests to date.

This explainer walks through what the proposal covers, where the numbers came from, what it does not cover, and how parents can use California's AB 899 lot-testing disclosures to see how a product compares. Every figure below comes straight from the cited source; we have not estimated or extrapolated any lab values.

The proposed numbers

FDA's draft guidance would set these cadmium action levels for packaged foods (jars, pouches, tubs, boxes) intended for children under two (FDA draft guidance; Federal Register notice):

Food category Proposed cadmium action level
Fruits, vegetables (excluding single-ingredient carrots) and mixtures, including grain- and meat-based mixtures 10 ppb
Single-ingredient carrots 25 ppb
Dry infant cereals 45 ppb
Yogurts, puddings and custards 20 ppb
Single-ingredient meats 25 ppb

An action level is the concentration at which FDA may regard a food as adulterated and consider enforcement. FDA is explicit that guidance documents "do not establish legally enforceable responsibilities," and that it expects industry "will strive for continual reductions over time" rather than treating the number as a target (FDA draft guidance).

The proposal is a draft. FDA asks for comments by December 22, 2026 under docket FDA-2025-D-4023, and it will host a free public webinar on November 16, 2026 (FDA constituent update).

Why cadmium, and why babies

Cadmium occurs naturally in the earth's crust and is also spread by pollution, so crops can take it up from soil, water and air (FDA constituent update). FDA's background section notes that cadmium has a long half-life in the human body, approximately 10 to 33 years, which is why even low-level chronic dietary exposure can lead to adverse effects on the bones and kidneys. It adds that early-life exposure has been associated in available data with impaired neurodevelopment and altered growth in children (FDA draft guidance).

Root vegetables are a recurring theme. FDA writes that carrots "can absorb cadmium more readily from the soil than other crops," and that is the reason carrots get their own, higher category.

Where the numbers came from

FDA built the levels from 1,430 samples drawn from its Toxic Elements Program and targeted surveys of domestic and imported baby foods. The mean cadmium concentrations it reports are useful context for any label or lot result you look up (FDA draft guidance):

  • Fruits: mean 1.0 ppb
  • Mixtures: mean 4.2 ppb
  • Vegetables excluding single-ingredient carrots: mean 4.4 ppb
  • Single-ingredient carrots: mean 12.7 ppb (90th–95th percentile 30.5–37.7 ppb)
  • Dry infant cereals: mean 15.0 ppb (90th–95th percentile 29.8–39.9 ppb)
  • Yogurts/puddings/custards and single-ingredient meats: means of 0.9 ppb and 0.5 ppb

FDA then tested each candidate level for two things: how much it would cut exposure for heavy eaters (children at the 90th percentile of consumption), and what share of products already meet it ("achievability").

Category Exposure reduction at 90th percentile Share of samples already at or below level
Fruits, vegetables (ex. carrots), mixtures — 10 ppb 28% 93%
Single-ingredient carrots — 25 ppb 32% 84%
Dry infant cereals — 45 ppb 5% 98%
Yogurts, puddings, custards — 20 ppb 0% 100%
Single-ingredient meats — 25 ppb 0% 100%

Two details stand out. First, FDA notes that if carrots were held to the same 10 ppb as other vegetables, only 55% of carrot samples would pass, which is why it proposed 25 ppb. Second, the dry-infant-cereal level only reduces exposure by an estimated 5%. In other words, it mostly removes the outliers. FDA says that with the levels in place, the 90th-percentile exposures fall below the lower end of its cadmium toxicological reference value range, 0.21 µg/kg body weight per day (FDA draft guidance).

What the draft does not cover

The scope section is worth reading closely, because some of the foods parents buy most are outside it (FDA draft guidance):

  • Snack foods, including grain-based or freeze-dried snacks, are excluded. FDA says it is still collecting data on grain-based snacks.
  • Infant formula and all beverages, including toddler drinks, are excluded.
  • Homemade foods and raw agricultural commodities are excluded.

The snack gap matters. In its September 2026 tests of 48 baby foods, Consumer Reports found that "in general, higher levels of inorganic arsenic, cadmium, and lead were found in baby food snacks, such as puffs, melties, biscuits, rice rusks, and bars, than they were in purées of any type." CR detected cadmium in 38 of the 48 products, though 96% of products stayed below CR's level of concern for heavy metals overall (Consumer Reports, 2026).

If you want our breakdown of formula specifically, see Infant Formula and Heavy Metals in 2026.

How cadmium fits with lead and arsenic

Closer to Zero is moving one metal at a time. FDA's current status table (Closer to Zero):

  • Lead in baby food: final guidance January 2025 — 10 ppb for fruits, most vegetables, mixtures, yogurts, custards/puddings and single-ingredient meats; 20 ppb for single-ingredient root vegetables and dry infant cereals (FDA lead guidance).
  • Cadmium in baby food: draft guidance October 2026.
  • Inorganic arsenic in baby food: FDA is targeting 2027 for draft guidance.

Not everyone thinks the approach goes far enough. Unleaded Kids argues that action levels focus on removing only the most contaminated 5–10% of products and consider each metal in isolation (Unleaded Kids). FDA, for its part, told Consumer Reports it estimates its lead action levels will reduce lead exposure by 19–29% depending on food category (Consumer Reports, 2026).

Using AB 899 disclosures to check a product yourself

Here is where the draft becomes practical. Under California's AB 899, baby food manufacturers selling in the state must test their products for lead, arsenic, cadmium and mercury at least once a month, and since the start of 2025 they must publish those results on their websites and through QR codes on labels. The law covers baby food, snacks and supplements for children under two but not infant formula (Consumer Reports AB 899 review).

Unleaded Kids, which tracks 39 brands selling baby food in California, reports 22 making results publicly available and 17 requiring a lot code to view them. Maryland, Virginia and Illinois have adopted similar laws (Unleaded Kids).

To compare a product against the draft:

  1. Find the lot results. Brands with full public pages, such as Once Upon a Farm and Cerebelly, let you check before you buy. Lot-code brands, such as Beech-Nut, need the package in hand.
  2. Match the category. A single-ingredient carrot purée is judged against 25 ppb; a carrot-apple blend is a mixture, judged against 10 ppb; a dry cereal against 45 ppb.
  3. Look at the units and detection limit. Results are usually in ppb. A "non-detect" only means the amount was below that lab's reporting limit, so check what the limit was.
  4. Remember it is one lot. Levels vary between ingredient lots and production runs, which is why our ranking method rewards brands that publish every lot rather than a single representative result.

Our baby food rankings score brands first on how completely they disclose, then on independent lab flags, never on numbers we cannot cite.

What parents can do now

Consumer Reports' experts point to habits that limit exposure to any single contaminant: rotate a wide variety of foods rather than relying on a few, consider skipping or limiting rice-based cereals and snacks, and include iron-rich foods such as lentils, chickpeas, peas, meats and fatty fish, since iron has been shown to help limit lead absorption. CR also notes that homemade baby food is not automatically free of heavy metals, because lead, arsenic and cadmium occur in fresh produce too (Consumer Reports, 2026).

FDA itself stresses that the action levels "are not intended to direct consumers into making food choices" and recommends a varied, nutrient-dense diet across the main food groups (FDA draft guidance). If you have concerns about a specific product or your child's exposure, your pediatrician is the right first call. Common questions are answered in our FAQ.

Sources