FDA proposes cadmium action levels for baby and toddler foods

The Food and Drug Administration has proposed numerical limits for cadmium, a toxic metal, in processed foods made for babies and young children. A draft guidance published in the Federal Register on 23 October 2026 would, when finalised, establish "action levels" for cadmium in several categories of food intended for children less than two years old [s1]. The agency says the levels are meant to be "achievable action levels that will help further reduce cadmium in the food supply" [s1].

Cadmium is one of a group of metals that occur naturally in soil and water and can be taken up by crops, so it reaches food without being deliberately added. Young children are a particular focus because they eat more food relative to their body weight than adults and because their developing organs can be more vulnerable to toxic exposures. The draft is part of a longer FDA effort to lower children's dietary exposure to contaminant metals.

The proposed numbers

The draft guidance would set the following action levels for cadmium in processed food intended for babies and young children less than two years old: "10 parts per billion (ppb) for fruits, vegetables (excluding single-ingredient carrots), and mixtures (including grain- and meat-based mixtures); 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" [s1].

The separate, higher figure for carrots and for dry cereals reflects that some foods tend to carry more cadmium from the crops they are made from. A part per billion is a very small concentration — roughly one microgram of cadmium per kilogram of food — and the levels are framed as targets manufacturers should be able to meet with good sourcing and manufacturing practices rather than as a measure of acute danger from any single serving.

What an "action level" actually means

An action level is not the same as a legally binding maximum. FDA explains that, consistent with its regulations, these levels "would reflect levels of cadmium at which FDA may regard the food as adulterated" under section 402(a)(1) of the Federal Food, Drug, and Cosmetic Act [s1]. In other words, exceeding an action level does not automatically make a product illegal, but it is one of the factors the agency weighs when deciding whether to treat a food as adulterated and whether to "bring enforcement action in a particular case" [s1].

The guidance itself is also non-binding. Like other FDA guidance, it is issued under the agency's good guidance practices regulation and, when finalised, "will represent the current thinking of FDA on this topic," without establishing rights or binding the agency or industry; a manufacturer may use an alternative approach that still satisfies the law [s1]. The practical weight of an action level comes from its role in enforcement, not from the guidance document carrying the force of a regulation.

Comment period and open questions

The draft is open for public comment. FDA asks for comments by 22 December 2026 "to ensure that the Agency considers your comments on the draft guidance before it begins work on the final version" [s1]. The agency specifically requests comment "on these proposed action levels in general, including on whether there may be sufficient data or information that would support different levels for these categories of foods" [s1] — an unusually direct invitation to argue the numbers up or down with evidence.

Comments may be submitted through the rulemaking docket, FDA-2025-D-4023 [s2]. FDA also notes that, as it develops the final guidance, it will consider comments on any costs or cost savings the guidance may generate [s1].

Where this fits

For parents, the immediate effect is limited: the guidance is a proposal, action levels are targets rather than bans, and the levels are set at concentrations measured in parts per billion. What the document signals is regulatory direction. By attaching specific cadmium figures to defined categories — carrots, cereals, yogurts, meats, and the broad "fruits, vegetables and mixtures" group — FDA is giving manufacturers a concrete yardstick and giving itself an enforcement reference point for a contaminant that cannot be eliminated outright but can, the agency argues, be steadily reduced.

The fixed points for now are the proposal and its deadline: the five category-specific cadmium action levels for foods aimed at children under two, and the 22 December 2026 close of comment before FDA turns to a final version.