Responding to EU Customer Questions on Contaminants and Pesticide Residues

M·05 / READINGS2026-07-29

Responding to EU Customer Questions on Contaminants and Pesticide Residues

Customer assurance starts with the scope of available evidence.

EU export customers may review food contaminants, heavy metals, process contaminants and pesticide residues together. Our response begins with the product category, ingredient basis, destination-market requirements and the scope of available testing evidence.

Hydrolyzed vegetable protein powder sample

01 · REGULATORY CONTEXT

Requirements must be assessed by product and analyte

Commission Regulation (EU) 2023/915 sets maximum levels by contaminant and food category. Regulation (EC) No 396/2005 is the principal EU framework for pesticide maximum residue levels. Regulation (EC) No 839/2008, cited in the customer question, is a historical amendment to the annexes of Regulation 396/2005; current decisions should use the consolidated text and the EU Pesticides Database.

A list of contaminants in a regulation does not mean that the same limit applies to every food ingredient. An HVP powder assessment must consider the product form, plant-protein source, analyte and relevant food category. Pesticide-residue review also requires the applicable raw commodity, residue definition, current MRL and any justified processing or mixing factor.

02 · HISTORICAL EVIDENCE

Start with what the historical reports demonstrate

We reviewed third-party reports issued from 2023 to 2026. The reports cover 3-MCPD, lead and total arsenic across multiple batches, together with one proactive pesticide-residue screen on a representative batch. The figures below apply only to the tested batches and reported analytes.

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Parameter	Historical scope	Result summary
3-MCPD	Six batches, 2023-2026	One result at 0.0155 mg/kg; all others ND <0.010 mg/kg or ND <0.005 mg/kg. All six were below the moisture-adjusted EU HVP maximum used in the review.
Lead	Six batches, 2023-2026	Four results below the respective LOQs; two quantified results at 0.072 mg/kg and 0.062 mg/kg.
Total arsenic	Six batches, 2023-2026	All results below the respective report LOQs.
Pesticide-residue screen	One representative batch, 2023	All 102 analytes actually listed in the report were below their respective LOQs.

ND means not detected above the stated limit of quantification. Analytes not listed in the historical reports are not presented as previously tested.

03 · TRACEABILITY

Combine supplier documentation, traceability and verification

Extended pesticide-residue and heavy-metal panels are not routine batch-release tests for every production batch. Our ongoing approach combines supplier document review, raw-material origin and batch traceability, quality-control records and proactive third-party verification of selected batches.

For parameters not covered by existing reports, these records, production experience and historical product performance support a preliminary assessment. That assessment is not presented as a third-party test conclusion for a specific batch.

04 · PRE-SUPPLY VERIFICATION

Project-specific confirmation can be arranged before supply

Where broader or batch-specific confirmation is required, the product, batch, analyte list, methods and LOQs can be agreed before testing. The work may then be performed by SGS, Eurofins or another customer-designated or mutually accepted accredited laboratory.

This route preserves the true scope of historical evidence while providing test results aligned with the customer's requested items and the intended supply batch.

05 · OFFICIAL SOURCES

EU regulatory and database links

EU legislation and MRLs are updated over time. Product-specific decisions should use the current versions and database results available on the date of assessment.

06 · MODULE LINK

Responding to EU Customer Questions on Contaminants and Pesticide Residues