The FDA’s lead limits in food run from 5 parts per billion in bottled water to 100 ppb in candy marketed to children, with baby foods held to 10 or 20 ppb depending on the category and juice limits currently proposed at 10 ppb for apple juice and 20 ppb for others. Each food type has its own threshold based on who eats it, how often, and how much lead careful sourcing and manufacturing can realistically remove. The tightest numbers apply to foods for babies and toddlers, where even trace exposure carries outsized developmental risk.
Current Lead Limits by Food Category
- Bottled water: 5 ppb, an enforceable standard under 21 CFR 165.110.
- Baby food fruits, most vegetables, mixtures, yogurts, custards, puddings, and single-ingredient meats: 10 ppb (Action Level).
- Baby food single-ingredient root vegetables and dry infant cereals: 20 ppb (Action Level).
- Single-strength apple juice: 10 ppb (proposed Action Level, not yet finalized).
- Other single-strength juices, including apple blends: 20 ppb (proposed Action Level, not yet finalized).
- Candy likely to be eaten frequently by small children: 100 ppb, or 0.1 ppm (Guidance Level).
These numbers apply to finished products as sold, not to raw ingredients. A cinnamon that tests at one level as a raw spice will contribute a different amount to a finished cookie depending on the recipe, and the FDA evaluates food as the consumer actually eats it.
Two different labels show up in that list, and the difference matters. An Action Level is a hard line: hit or exceed it, and the FDA can treat the product as adulterated and pursue warning letters, import refusals, or recalls. A Guidance Level is softer, representing what manufacturers should be able to achieve with careful production. Exceeding it doesn’t automatically trigger enforcement, but the agency can still act against any product it considers a health risk under the general adulteration standard in the Federal Food, Drug, and Cosmetic Act.1Office of the Law Revision Counsel. 21 USC 342 – Adulterated Food
Baby and Toddler Foods
Foods marketed for children under two get the strictest limits, set through the FDA’s “Closer to Zero” initiative and finalized in January 2025.2Food and Drug Administration. Guidance for Industry: Action Levels for Lead in Processed Food Intended for Babies and Young Children The 10 ppb Action Level covers processed fruits, most vegetables, grain- and meat-based mixtures, yogurts, custards, puddings, and single-ingredient meats. Single-ingredient root vegetables such as carrots and sweet potatoes get 20 ppb, as do dry infant cereals.
Root vegetables and grains carry the higher number because they naturally absorb more lead from soil, and there are physical limits to what farming and processing can strip out. The FDA estimates the action levels could cut lead exposure from baby foods by roughly 24 to 27 percent.
Fruit Juices
The juice numbers are still in draft form. The FDA has proposed 10 ppb for single-strength apple juice and 20 ppb for other single-strength juices, including blends containing apple juice.3Food and Drug Administration. FDA Issues Draft Guidance to Industry on Action Levels for Lead in Juice Once finalized, they would replace the 50 ppb standard that had been in place for years.4Food and Drug Administration. Action Levels for Lead in Juice: Draft Guidance for Industry
Draft status doesn’t leave juice unregulated. The FDA can still act against any juice with lead levels that render it injurious to health under the adulteration standard, and most major manufacturers have already begun working toward the proposed targets. Apple juice gets the tightest number because children drink so much of it.
Candy
Candy sits at 0.1 ppm, or 100 ppb, as a Guidance Level for products likely to be eaten frequently by small children.5Food and Drug Administration. Guidance for Industry: Lead in Candy Likely To Be Consumed Frequently by Small Children That replaced an older 0.5 ppm recommendation the agency rescinded because it no longer reflected what manufacturers could achieve.6Food and Drug Administration. Supporting Document for Recommended Maximum Level for Lead in Candy Likely To Be Consumed Frequently by Small Children
Imported candies draw extra attention, especially those containing chili powder or tamarind. Both ingredients have historically tested higher for lead, often from contamination during drying, grinding, or storage rather than the raw material itself. A candy that looks fine on a shelf can carry lead well above the guidance.
Bottled Water
Bottled water has the lowest limit of any FDA-regulated food product at 5 ppb, or 0.005 milligrams per liter, and unlike most limits on this list, it is an enforceable standard rather than an action level.7eCFR. 21 CFR 165.110 – Bottled Water It applies to every type of bottled water, including spring, purified, and mineral varieties.8Food and Drug Administration. Bottled Water Everywhere: Keeping it Safe The number is tighter than the EPA’s 15 ppb action level for tap water partly because bottled water doesn’t run through the lead pipes and solder joints that create most tap contamination, so manufacturers can hit a lower target.
Spices
The FDA has no published action level specifically for lead in spices, but that gap hasn’t stopped enforcement. Ground cinnamon became a high-profile example starting in 2023, when testing found lead between 2.03 and 3.4 ppm in products from six distributors, prompting recall recommendations across all of them.9Food and Drug Administration. FDA Alert Concerning Certain Cinnamon Products Due to Presence of Elevated Levels of Lead A separate investigation traced ground cinnamon from Ecuador to a single supplier whose product contained lead at 2,270 to 5,110 ppm.
Without a formal action level, the agency falls back on the general adulteration standard: enough lead to potentially harm consumers makes the spice adulterated. After the cinnamon episode, the FDA sent letters to all U.S. cinnamon manufacturers reminding them of their obligation to control chemical hazards, and broader spice testing is ongoing.
What Happens When a Product Exceeds the Limit
The FDA’s response depends on the severity and source of the problem. For domestic products, the agency can issue warning letters demanding corrective action, request voluntary recalls, or pursue mandatory recalls when a company won’t cooperate. In more serious cases it can seek a court order to seize contaminated product already in distribution, or an injunction to shut down operations. Consumer alerts go out for products that have already reached households, as they did with the cinnamon recalls, telling people to discard specific brands.
Imports are handled at the port. Under Import Alert 99-42, FDA field staff can detain shipments suspected of heavy metal contamination without testing each one first, and refused shipments never reach store shelves.10U.S. Food and Drug Administration. Import Alert 99-42: Detention Without Physical Examination of Foods Due to Heavy Metal (Toxic Element) Contamination To get a detained shipment released, the importer has to produce lab results showing the product is within safe levels. Candy products dominate the alert’s Red List, particularly from regions where lead contamination in confectionery ingredients has been documented.