California AB 899 and Maryland's Rudy's Law require batch testing of baby food for arsenic, cadmium, lead and mercury with QR-code disclosure. What to look for.
9/8/2026 · 8 min read · Chris Carrillo · Reviewed by Armin Rad, Co-Founder & CTO, Aurascan · Last reviewed 9/8/2026
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Written by Chris Carrillo. Reviewed by Armin Rad, Co-Founder & CTO, Aurascan. It cites 6 sources; use the source list and methodology to check the evidence directly.
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View the sample resultSACRAMENTO, Calif., Sept. 8, 2026 -- Two states now require baby food makers to test every production batch for arsenic, cadmium, lead and mercury and to show parents the results. California's Assembly Bill 899 has required on-package QR codes linking to batch results since January 1, 2025, and Maryland's Rudy's Law (House Bill 97) added website and on-label disclosure from January 1, 2026. Because brands ship one national package, most shoppers anywhere in the U.S. can now scan for the numbers.
Key takeaways:
On October 10, 2023, California Governor Gavin Newsom signed Assembly Bill 899 into law, adding Section 110552 to the California Health and Safety Code. The legislation created the first comprehensive state regulatory structure requiring commercial baby food producers to test finished products for four major environmental contaminants: inorganic arsenic, cadmium, lead, and mercury. The statute structured implementation into two sequential compliance phases designed to transform supply chain oversight and consumer transparency.
The initial phase took effect on January 1, 2024, obligating food manufacturers to begin representative monthly testing of finished baby food products distributed or offered for sale in California. The second phase took effect on January 1, 2025, requiring companies to place a scannable QR code or direct digital link on packaging so retail consumers could instantly view batch level laboratory results alongside corresponding federal safety thresholds.
Maryland followed with House Bill 97, Rudy's Law, signed by Governor Wes Moore on May 16, 2024 and named for a 17-month-old poisoned by lead-contaminated cinnamon apple pouches. The law took effect October 1, 2024; manufacturers had to begin testing a representative sample of each production batch for arsenic, cadmium, lead and mercury by January 1, 2025, and from January 1, 2026 must disclose the results on their websites and provide a code on the label linking to them. Together, California AB 899 and Maryland's Rudy's Law are the statutory models other states are copying.
The fundamental operational change is the mandatory shift from private, voluntary internal quality controls to statutory testing and public digital disclosure. Prior to state legislative intervention, federal law did not require commercial baby food processors to conduct finished product heavy metal testing or publish laboratory findings for consumers. Legal analysts at Reed Smith LLP noted that this framework radically shifts legal exposure by requiring verifiable batch documentation.
Under California AB 899, the regulatory mechanism establishes specific operational requirements:
This framework replaces opaque internal supplier assurances with open point-of-sale data, granting caregivers direct visibility into analytical laboratory measurements.
These state regulations govern commercial infant food processors, national grocery retailers, ingredient distributors, and households purchasing baby food. State statutory frameworks define baby food as any prepared food packaged in jars, pouches, tubs, or boxes that is marketed specifically for infants and children under 24 months of age.
Product categories subject to mandatory testing and disclosure include:
Geographically, the impact reaches far beyond California. In Maryland, Rudy's Law brought the same batch-testing and disclosure duties to the Mid-Atlantic market. Because food processors utilize unified national packaging and distribution lines, the scale of California and Maryland markets has led many manufacturers to roll out QR codes and standardized batch testing nationwide rather than segmenting regional inventory.
Families with infants and toddlers are directly impacted by these policies. Infants possess developing neurological systems, lower body weight, and higher food intake per kilogram of body weight compared to adults, making dietary heavy metal exposure a primary health consideration.
For grocery shoppers, these legislative standards provide verifiable packaging data where parents previously had no visibility. Instead of guessing whether a root vegetable puree absorbed soil contaminants during cultivation, consumers can scan on-pack digital codes to examine precise laboratory metrics before buying. Consumer advocacy groups such as the Clean Label Project have emphasized that open laboratory metrics are vital for rebuilding consumer trust.
When evaluating baby food containers on retail shelves, shoppers can look for several practical disclosure features:
Trace concentrations of heavy metals occur naturally in soil and water, meaning complete zero detection is often chemically impossible in root crops such as carrots and sweet potatoes. Nevertheless, published metrics allow parents to compare formulations and balance dietary selections. For more context on evolving safety frameworks, read how FDA Proposes Ending Self-Affirmed GRAS: What Changes for You and see our analysis on how Food Brands Race to Drop Artificial Dyes Before 2027.
Parents and caregivers can take practical, immediate steps to navigate the baby food aisle and minimize cumulative heavy metal exposure:
Heavy metals enter agricultural supply chains through natural geological composition, historical industrial activity, environmental pollution, and irrigation sources. Crops absorb these elements through root networks during normal growth cycles. In early childhood, chronic exposure to heavy metals has been linked by health authorities to developmental delays, cognitive vulnerabilities, and neurological risks, according to interagency summaries from the National Institute of Environmental Health Sciences.
In April 2021, the FDA introduced its Closer to Zero initiative, outlining a multi-year strategy to lower dietary toxic element exposure across commercial infant nutrition. The agency planned to assess scientific findings, publish proposed action levels, review stakeholder feedback, and finalize non-binding guidance standards.
However, the federal process has progressed gradually. The FDA finalized a 100 ppb action level for inorganic arsenic in infant rice cereal in 2020, and on January 6, 2025 issued final action levels for lead in processed baby food: 10 ppb for fruits, most vegetables, mixtures, yogurts and meats, and 20 ppb for single-ingredient root vegetables and dry infant cereals. These are guidance, not enforceable limits, and action levels for cadmium and for inorganic arsenic outside rice cereal remain pending. Broader federal reviews of food substances are also ongoing, as seen when the FDA Opens Formal Safety Reassessment of BHT: What It Means for additive safety. Frustrated by lengthy federal timelines, states enacted independent measures such as California AB 899 and Maryland's Rudy's Law (HB 97) to establish mandatory standards immediately.
The regulatory landscape surrounding baby food safety will continue to develop as state and federal authorities monitor compliance and policy updates.
Key areas to track moving forward include:
Important scientific limitations remain: analytical testing data cannot establish individual biological absorption rates or absolute health outcomes for any specific infant, as personal genetics, total diet, and background environmental factors influence actual metabolic uptake. Shoppers can use on-pack transparency data alongside tools like Aurascan to easily interpret product labels and make informed decisions for their families.
California Assembly Bill 899 is a state statute requiring commercial baby food manufacturers to test finished products for inorganic arsenic, cadmium, lead, and mercury, and disclose testing data to consumers via on-package QR codes.
Maryland HB 425 establishes state level infant food safety standards, requiring baby food processors to maintain heavy metal testing protocols, document compliance, and support public transparency.
State laws specifically require testing for four toxic heavy metals: inorganic arsenic, cadmium, lead, and mercury.
Parents can scan the QR code printed on the baby food package with a smartphone camera, which opens a webpage displaying batch-specific laboratory test results alongside FDA action levels.
No. Heavy metals occur naturally in soil and water and are absorbed by agricultural crops. State testing laws and FDA programs aim to reduce concentrations to the lowest achievable levels rather than zero.
No. Most federal FDA Closer to Zero action levels are currently non-binding guidance, whereas state laws like California AB 899 create mandatory testing and label disclosure requirements.
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