AB 899 for Baby Food Brands: What California Requires

California's AB 899, signed in October 2023, is one of the most significant laws on heavy metals in baby food in the United States. If you make baby food sold in California, it already shapes your testing calendar and your packaging.

This is a summary for brand teams, not legal advice. Confirm your obligations against the statute and with your counsel. For more detail, see California baby-food testing and disclosure (AB 899) on Heavy Metal Certified, and the California Department of Public Health AB 899 FAQ.

What the law requires

AB 899 covers four "toxic elements": arsenic, cadmium, lead, and mercury.

Testing (since January 1, 2024):

• Test a representative sample of each production aggregate of your final baby food product.
• Test each final product at least once a month.
• Use a proficient laboratory. The law requires labs to demonstrate they can quantify each element down to at least 6 micrograms per kilogram, through an independent proficiency test.
• Provide results to the California Department of Public Health on request.

Disclosure (since January 1, 2025):

• Post the name and level of each toxic element for each production aggregate on your website.
• Keep results posted for the product's shelf life plus one month.
• If the product is tested for an element with an FDA action level, regulatory limit, or tolerance, print a QR code on the label linking to the results and to FDA information about health effects, along with the statement: "For information about toxic element testing on this product, scan the QR code."

Why the QR code now applies broadly

When FDA finalized lead action levels for packaged foods for children under 2 in January 2025, the QR code requirement came into effect for most purees and cereals, since nearly all of them are tested for lead. FDA also has an arsenic action level for infant rice cereal. FDA levels explained.

What is and is not covered

AB 899 applies to baby food intended for children under 2, sold in forms like jars, pouches, tubs, and boxes. Infant formula and some other product types fall outside the law's definition of baby food. Confirm your product scope with counsel.

Other states have passed related laws, such as Maryland's Rudy's Law, so brands selling nationally should check each state they sell in.

How teams usually divide the work

• Regulatory owns the statute, scope decisions, and records.
• Quality owns sampling, lab relationships, and lot results.
• Digital or e-commerce owns the results page and QR landing experience.
• Brand and legal review any claims made alongside the disclosure.

How certification relates

AB 899 is a testing and disclosure law. It does not create a certification mark, and following it does not certify a product.

Heavy Metal Tested is a separate, voluntary certification program from the Paleo Foundation. Products earn the Heavy Metal Certified mark when testing through a qualified independent ISO/IEC 17025 laboratory shows they meet a published standard covering eight metals (the four in AB 899, plus chromium, nickel, tin, and aluminum). Certification lasts one year and renews with retesting.

The two work side by side:

• AB 899 gives parents the raw numbers for each lot.
• Certification gives parents a recognizable mark showing the product met a published standard.

Certification does not satisfy, replace, or discharge AB 899. A covered brand remains responsible for all statutory testing, disclosure, labeling, and records. California does not require certification. QR results vs a certification mark.

FAQ

Does California require Heavy Metal Tested certification? No. AB 899 is a testing and disclosure law. Certification is voluntary and separate.

Which metals does AB 899 cover? Arsenic, cadmium, lead, and mercury.

When did AB 899 take effect? Monthly testing began January 1, 2024. Public disclosure began January 1, 2025.

Does the QR code requirement apply to all baby food? It applies when a product is tested for an element with an FDA action level, regulatory limit, or tolerance. Since FDA finalized lead action levels in 2025, that includes most purees and cereals.

Does certification make us compliant with AB 899? No. Compliance with the statute is the brand's responsibility.

Next step

Selling baby food in California and considering certification alongside AB 899? Book a 30-minute call. Bring your product list.