Cocoa is one of the most heavily regulated raw materials in the food industry when it comes to heavy metals and for good reason. Cadmium accumulates naturally in cocoa trees depending on soil composition, meaning contamination risk is tied to where cocoa is grown, not just how it’s processed. In 2026, buyers and manufacturers sourcing cocoa and cocoa-derived ingredients need to understand exactly where the regulatory bar sits, and how it’s shifting.
The current cadmium limits
Under EU Regulation (EU) 2023/915 (which recast and consolidated the earlier Regulation (EC) 1881/2006), cadmium in cocoa and chocolate products is capped based on the product’s cocoa solids content:
- Cocoa powder sold to the final consumer, or used as an ingredient in sweetened cocoa powder / drinking chocolate for the final consumer: 0.60 mg/kg
- Chocolate with ≥ 50% total dry cocoa solids: capped at a higher threshold, reflecting the diluting effect of other ingredients
- Chocolate with lower cocoa solids content: correspondingly lower limits
These limits were originally introduced by Commission Regulation (EU) No. 488/2014, with a transition period before taking full effect on 1 January 2019. The 2023 recast didn’t change the thresholds it renumbered and consolidated them into the broader food contaminants framework.
What's new: nickel limits arrive in 2025
Until recently, the EU had no harmonized nickel limit for cocoa products. That changed with an amendment to Regulation (EU) 2023/915, introducing nickel maximum levels that took effect from July 2025 including a limit of 15 mg/kg for cocoa powder intended for the final consumer.
This is a meaningful shift for the industry, nickel testing wasn’t previously a standard part of most cocoa CoAs, and suppliers who haven’t updated their testing panels may be caught off guard by customer requests for nickel data in 2026.
Why this matters for sourcing decisions in 2026
1. Origin matters more than ever. Cadmium levels in cocoa correlate strongly with growing region cocoa from certain Latin American origins, for example, tends to run higher in cadmium than cocoa from West Africa, due to underlying soil geochemistry. Buyers sourcing cocoa for consumer-facing products need visibility into origin, not just a generic “cocoa powder” spec.
2. Testing scope needs to expand. A CoA that only covers moisture, fat content, and particle size no longer tells the full compliance story. Buyers should confirm whether cadmium and nickel are tested per batch, and request actual lab data rather than a general compliance statement.
3. B2B supply chains carry the risk forward, even without a direct legal obligation. The EU limits apply at the point of sale to the final consumer but an ingredient that exceeds these thresholds today will still be non-compliant once it reaches that stage, regardless of how many intermediate B2B transactions happen in between. Buyers further up the chain (ingredient distributors, private-label manufacturers) carry real commercial risk if they don’t verify compliance before it becomes someone else’s problem downstream.
4. Blending and dilution are not a compliance strategy. Because chocolate’s cadmium limit scales with cocoa solids content, some suppliers may be tempted to blend high-cadmium cocoa with lower-cadmium sources to stay under the threshold on paper. Buyers should ask suppliers directly about blending practices and request batch-level (not blended-average) data where possible.
What buyers should be asking suppliers right now
- What are the actual, current cadmium and nickel levels for this specific batch not a historical average?
- Where does the cocoa originate, and has that origin’s typical heavy-metal profile been assessed?
- Has the supplier’s CoA panel been updated to include nickel testing following the 2025 regulatory change?
- What is the supplier’s process if a batch test above the applicable limit is flagged proactively, or only on request?
The bottom line
Heavy-metal compliance in cocoa is no longer a background regulatory detail; it’s an active, evolving part of sourcing due diligence. With nickel limits newly in force and cadmium limits well-established but easy to overlook, 2026 is the year for buyers to push suppliers for real batch-level data rather than assuming a supplier’s general reputation is enough.
How Waves Ingredients Supports Your Cocoa Sourcing
At Waves Ingredients, we source and supply high-quality cocoa ingredients, including cocoa powder (natural and alkalised), cocoa butter, cocoa mass and organic grades, for food manufacturers, confectioners and beverage brands across Europe.
We stay close to market developments in the cocoa sector, tracking crop conditions in West Africa, pricing dynamics, certification requirements and availability, so our partners can make better-informed purchasing decisions.
Whether you are developing a new chocolate or beverage product, looking to secure supply for existing formulations, or exploring alternatives in the current volatile market, we are here to help.
Looking to discuss your cocoa sourcing? Get in touch with our team →
