Decoding EU Food Contaminant Regulations: A Guide to Heavy-Metal Compliance

EU Regulatory Framework: Setting Maximum Levels and Control Methods

⚖️

The trade of seafood products with the European Union is currently in an era of continuous refinement and strengthening of regulations. Through a series of precisely interlocking legal instruments, the EU has established a complete regulatory closed loop from limit standards to testing methods. A deep understanding of this system is not only a compliance requirement to meet market access, but also a commercial cornerstone for establishing long-term, stable supply relationships and winning customer trust. This issue aims to clearly sort out the core EU pollutant regulatory framework and its key testing requirements, helping your business navigate with confidence.

📋

EU Core Pollutant Regulatory Framework

•

The EU manages contaminants in food mainly by setting unified maximum limits and stipulating official sampling and testing methods. These two pillars are constructed by the following core regulations:

📊

Limit Standards Foundation: (EU) 2023/915

This regulation is the core codex for current EU food contaminant limits. It integrates and replaces the old regulation (EC) No 1881/2006, setting clear maximum allowable levels for various contaminants (such as heavy metals, dioxins, mycotoxins, etc.) in different foods (including fish, crustaceans, cephalopods, etc.).

A key dynamic is that the limits for inorganic arsenic in fish and seafood were not part of the initial content of this regulation, but were added through Amendment (EU) 2025/1891 in September 2025. This reflects the EU's trend of dynamically tightening control over specific high-risk contaminants based on the latest risk assessments.

📱 Quick Scan on Mobile:

Use your mobile device to scan the QR code for quick access to the regulation summary.

(EU) 2023/915 QR Code

Scan with mobile device

🔬

Methodology Anchor: (EC) No 333/2007

Having only limit standards is insufficient; ensuring the accuracy, comparability, and legal validity of test results is equally crucial. (EC) No 333/2007 is precisely the "methodology anchor" that ensures this. It stipulates the mandatory method standards for sampling and analyzing contaminants such as lead, cadmium, mercury, and inorganic arsenic in food for official control purposes.

When (EU) 2023/915 requires compliance verification at the implementation level, it references this regulation. Its appendices list the EU-recognized test method standards, which are updated and replaced through amendments. Therefore, ensuring that the laboratory methods used comply with the latest appendix requirements of (EC) No 333/2007 is a legal prerequisite for proving product compliance.

📱 Quick Scan on Mobile:

Use your mobile device to scan the QR code for quick access to the methodology summary.

(EC) No 333/2007 QR Code

Scan with mobile device

🧪

Key Heavy Metal Testing Method Overview

•

Within the framework of (EC) No 333/2007, and considering the specific properties and risks of different heavy metals, the EU has established specific testing method standards. Below is an overview of the main risk substances:

⚙️ General Heavy Metal Determination: Lead and Cadmium

For elements such as lead and cadmium, general trace element determination method standard series are typically used.

Example Method Standards: EN 13804 (performance standards), EN 13805 (pressure digestion), and other pretreatment and basic standards are often used as part of method combinations.
Purpose Explanation: These standards provide the foundation and performance requirements for laboratories to establish reliable analytical processes, ensuring quality control throughout the entire process from sample preparation to instrumental measurement.

🧬 Mercury Speciation Analysis: Focusing on Methylmercury

In seafood, the toxicity of mercury mainly comes from its organic form—methylmercury. Therefore, EU regulations require specific analysis for it.

Example Method Standards:
- EN 16801: Using gas chromatography-inductively coupled plasma mass spectrometry, this is the reference method for determining methylmercury content in seafood.
- EN 17266: Using a direct mercury analyzer, mainly for determining total mercury content.
Purpose Explanation: EN 16801 can accurately distinguish and quantify methylmercury, making it a key method for meeting EU requirements for mercury risk assessment in seafood.

🔍 Arsenic Speciation Analysis: Targeting Inorganic Arsenic

The toxicity of arsenic is highly dependent on its chemical form, with inorganic arsenic being recognized as a carcinogen. The EU's newly added limits for seafood (such as seaweed, rice, specific fish) specifically refer to inorganic arsenic.

Example Method Standards: EN 16802. This standard is the sister standard to EN 16801, specifically designed for determining inorganic arsenic content in food using high-performance liquid chromatography-inductively coupled plasma mass spectrometry.
Purpose Explanation: This method is currently the EU-recognized authoritative method for accurately quantifying toxic inorganic arsenic (such as As(III) and As(V)), which is crucial for proving product compliance with the new limits in (EU) 2023/915 and its amendments.

🔄

Regulatory Dynamics and Our Compliance Strategy

•

The EU's regulatory system is dynamically developing, as evident from the addition of new inorganic arsenic limits. This dynamic nature requires all participants in the supply chain to be forward-looking and adaptable.

Continuous Monitoring and Proactive Adaptation

We will continue to monitor official information flows, including amendments to EU food safety regulations. This enables us to anticipate potential regulatory changes and initiate adjustment procedures in the supply chain in advance, such as conducting risk assessments and testing validations for newly set contaminant limits.

Ensuring Testing Effectiveness from the Source

Based on understanding (EC) No 333/2007, when selecting third-party laboratories, we not only confirm their qualifications but also verify that their specific testing methods for particular projects (especially methylmercury, inorganic arsenic, etc.) fully comply with currently effective EU method standards. This ensures that each test report has solid legal effect and international credibility, providing strong support for your smooth customs clearance.

Building a Traceable Compliance Evidence Chain

Compliance is not just about final product testing qualification, but a management process throughout. We will rely on existing quality control systems to ensure that all key control point information related to contaminant risks (such as raw material origin certificates, processing records, laboratory test reports) from raw material batches to finished product shipments are traceable and queryable, building a complete, transparent compliance evidence chain for you.

🏆

Conclusion: Transforming Compliance into Trust and Competitiveness

Under the EU's rigorous and even demanding regulatory system, a deep understanding of the rules is the first step in turning challenges into opportunities. By systematically managing every compliance link from limit standards to testing methods, we not only aim to ensure smooth market entry for products but also hope to jointly build "compliance" into a reliable label for the supply chain and a core added value for products.

Faced with an evolving regulatory environment, Angfa is willing to be your trusted partner, providing solutions based on professional knowledge and practical experience, jointly safeguarding food safety, and winning market trust.

We hope this article brings you clear value. If you have specific product compliance questions or need further information, please feel free to contact us.

📜