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FDA Lead vs Cadmium Baby-Food Action Levels: Side-by-Side

The short answer

FDA finalized lead action levels for certain processed baby foods in January 2025 and proposed draft cadmium levels for overlapping categories in October 2026 [1][2][3][4]. Lead guidance is final; cadmium is draft, with comments due December 22, 2026 [2][4]. Both exclude snacks, infant formula, and beverages, and both cover packaged foods for children under two [3][5]. Root vegetables differ most: lead sets 20 ppb for single-ingredient carrots or sweet potatoes; cadmium drafts 25 ppb for single-ingredient carrots only [3][5].

This is a comparison guide, not a reprint of the cadmium-only ppb explainer. For cadmium numbers in depth, see FDA draft cadmium action levels explained. For how to comment before the deadline, see cadmium comment + Nov 16 webinar.

What are FDA lead vs cadmium action levels for baby food?

An action level is the concentration at which FDA may regard a food as adulterated and consider enforcement under the Federal Food, Drug, and Cosmetic Act [3][5]. Neither document is a consumer shopping list: FDA says the levels are not intended to tell parents which foods to throw out [1][2].

Metal Status Issued Scope age
Lead in processed food intended for babies and young children Final guidance January 2025 (constituent update dated January 6, 2025) [1][3] Less than 2 years [1][3]
Cadmium in processed food intended for babies and young children Draft guidance October 2026 (FR notice October 23, 2026) [2][4] Less than 2 years [4][5]

Both sit under FDA's Closer to Zero initiative to reduce dietary exposure to arsenic, cadmium, lead, and mercury while keeping nutritious foods available [6]. For the full roadmap (arsenic draft targeted 2027, lead-in-juices final targeted 2027), see Closer to Zero roadmap 2026.

Which foods get which ppb?

FDA published different category grids for the two metals. The table below puts them next to each other using the category wording from each guidance [1][3][4][5].

Food category (as FDA defines it) Lead action level (FINAL) Cadmium action level (DRAFT)
Fruits; vegetables excluding the metal-specific root exception; mixtures (including grain- and meat-based mixtures) 10 ppb [1][3] 10 ppb [4][5]
Yogurts, custards/puddings 10 ppb (same 10 ppb bucket as fruits/mixtures/meats) [1][3] 20 ppb [4][5]
Single-ingredient meats 10 ppb [1][3] 25 ppb [4][5]
Single-ingredient root vegetables (carrots or sweet potatoes) 20 ppb [1][3] (no matching bucket — see next section)
Single-ingredient carrots only (covered by root-veg 20 ppb) 25 ppb [4][5]
Dry infant cereals 20 ppb [1][3] 45 ppb [4][5]

Read the footnotes in each PDF before you treat a label as "in" or "out." Lead defines "single-ingredient root vegetables" as a food that consists of either carrots or sweet potatoes (with or without water/preservatives); a carrot-apple or sweet-potato-apple puree is a mixture [3]. Cadmium's higher vegetable exception is single-ingredient carrots only, not sweet potatoes [5].

Where do root vegetables and carrots differ?

This is the comparison parents miss when they only read one metal's table.

  • Lead (final): single-ingredient root vegetables = carrots or sweet potatoes → 20 ppb. FDA notes these roots can absorb lead more readily from soil than other crops, and that a 10 ppb level would have left only about 79% of those samples achievable in its analysis [3].
  • Cadmium (draft): single-ingredient carrots → 25 ppb; other vegetables (including other roots that are not single-ingredient carrots) sit in the 10 ppb fruits/veg/mixtures bucket [4][5]. FDA's cadmium draft explains that carrots can absorb cadmium more readily from soil than other crops [5].

Practical read of an AB 899 lot:

  1. Single-ingredient sweet-potato puree → compare lead to 20 ppb; for cadmium use the general vegetable 10 ppb draft level (unless the brand's disclosure labels it as something else — match FDA's category language, not marketing copy) [3][5].
  2. Single-ingredient carrot puree → lead 20 ppb; cadmium draft 25 ppb [3][5].
  3. Carrot-apple blend → mixture for both metals → lead 10 ppb; cadmium draft 10 ppb [3][5].

Are snacks and formula covered?

No for both metals, in parallel language.

Lead final guidance does not cover snack foods (including grain-based or freeze-dried snacks such as puffs, rusks, teething biscuits), infant formula, or beverages (including toddler drinks); juice lead levels are addressed in separate draft guidance [1][3]. Cadmium draft guidance likewise excludes snack foods (grain-based or freeze-dried), infant formula, and beverages, and says FDA is still collecting grain-based snack data [5].

That shared gap matters because independent tests often find higher heavy-metal readings in snack formats than in purées — see why rice snacks tested higher for arsenic in CR 2026 and our infant formula vs FDA/CR testing. Action levels are not a free pass for excluded products: FDA still can act if a food is unsafe even without a published action level [6].

Is lead final and cadmium still draft?

Yes. Lead baby-food action levels are final as of January 2025 [1][3][6]. Cadmium baby-food action levels are draft as of October 2026; FDA asks for comments by December 22, 2026 on docket FDA-2025-D-4023, and will host a free webinar on November 16, 2026 (1:00–2:00 p.m. ET) [2][4][7]. Draft numbers can change before finalization. Do not treat the cadmium column as settled law.

How do I compare an AB 899 result to both?

California AB 899 requires manufacturers selling baby food in the state to test for lead, arsenic, cadmium, and mercury and to make results available (public pages and/or lot-code lookups) [8][9]. For a parent-facing walkthrough of public pages vs lot codes, see AB 899 public vs lot-code.

A careful dual check:

  1. Pull the lot result for the package you have (or the brand's public table) and confirm units are ppb (µg/kg) [8].
  2. Classify the product the way FDA does — single-ingredient root vs mixture vs dry cereal vs yogurt — separately for each metal's category list [3][5].
  3. Compare lead to the FINAL column and cadmium to the DRAFT column, and label the cadmium comparison as draft [1][4].
  4. Check the lab reporting limit. "ND" / non-detect means below that lab's limit, not necessarily zero [8].
  5. Remember one lot ≠ every lot. Our methodology weights disclosure completeness and independent flags over single cherry-picked numbers; rankings live on the homepage.

Action levels are enforcement tools for FDA, not DIY "safe/unsafe" stickers. If a lot is near a number, treat that as a prompt to rotate foods and read the brand's full disclosure trail — not medical advice.

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

Are FDA lead and cadmium baby-food limits the same numbers?

No. Several categories share a 10 ppb line for fruits/most vegetables/mixtures, but yogurts/puddings, meats, dry cereals, and root/carrot exceptions differ between the final lead guidance and the draft cadmium guidance [3][5].

Do sweet potatoes get the same special cadmium level as carrots?

No. Cadmium's elevated draft bucket is single-ingredient carrots at 25 ppb [5]. Lead's elevated final bucket is single-ingredient root vegetables (carrots or sweet potatoes) at 20 ppb [3].

Can I use these action levels on puffs or infant formula?

Not as published category limits. Both guidances exclude snack foods and infant formula (and beverages); juice lead is a separate draft track [1][3][5].

Where should I look if I want cadmium-only detail or how to comment?

Use FDA draft cadmium action levels explained for the cadmium table and rationale, and how to comment + Nov 16 webinar for participation steps before December 22, 2026.

Does Closer to Zero already cover arsenic the same way?

Not yet for broad processed baby food. FDA's Closer to Zero status table targets 2027 for draft inorganic-arsenic guidance for processed food intended for babies and young children; lead-in-juices final guidance is also targeted for 2027 [6]. See Closer to Zero roadmap 2026.

References

  1. U.S. FDA, FDA Issues Final Guidance for Industry on Action Levels for Lead in Processed Food Intended for Babies and Young Children (January 6, 2025).
  2. U.S. FDA, FDA Advances Closer to Zero Initiative to Safeguard Food for Children (October 22, 2026).
  3. U.S. FDA, Action Levels for Lead in Processed Food Intended for Babies and Young Children: Guidance for Industry (final guidance PDF).
  4. 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).
  5. U.S. FDA, Action Levels for Cadmium in Processed Food Intended for Babies and Young Children: Draft Guidance for Industry (draft PDF).
  6. U.S. FDA, Closer to Zero: Reducing Childhood Exposure to Heavy Metals from Foods.
  7. U.S. FDA, Webinar on Closer to Zero Updates Including Cadmium Action Levels — November 16, 2026.
  8. Consumer Reports, Best Baby Food Brands for Reporting Heavy Metals: California AB 899.
  9. Unleaded Kids, Update on Baby Food disclosure tracker.