2.2.2 Other SPS Risks

Consumer concerns on food safety and the threat of contaminants to human health have caused tightening of regulations in consuming countries. This increases the risk of disruption to cocoa trade, so poor Sanitary and Phyto-Sanitary (SPS) standards have the potential to harm the welfare of farmers in a number of cocoa-growing countries.

Although not the subject of this manual, readers should be aware that in addition to pesticide residues, food safety and cocoa quality concerns include:

• Mycotoxins: especially Ochratoxin A (OTA), often due to poor crop drying – potential damage to DNA (mutagens)
• FFA (Free/trans Fatty Acid): also an indicator of poor cocoa quality – risk of exacerbating diabetes
• PAHs (Polycyclic Aromatic Hydrocarbons): usually due to smoke from badly designed crop dryers – are often carcinogens (risk of causing cancer)
• Mineral oil hydrocarbons (MOH) contain MOSH (mineral oil saturated hydrocarbons) and MOAH (mineral oil aromatic hydrocarbons, including PAH): exposure through packing materials, food additives, lubricants and fuel – MOAH may be mutagenic and carcinogenic
• Acrylamide: formed in starchy foods when cooked at high temperatures (frying, roasting and baking) - carcinogens (risk of causing cancer)
• Heavy/toxic metals, often associated with crops grown on volcanic or polluted soils, include:
  • Aluminium (Al) – potential neurotoxin
  • Cadmium (Cd) – highly toxic and carcinogenic
  • Hexavalent chromium (Cr(VI) ) – toxin and carcinogen
  • Lead (Pb) – carcinogen can cause miscarriages and infertility in males
  • Mercury (Hg) – damages the nervous system
  • Nickel (Ni)

The levels of heavy/toxic metals are routinely monitored in a variety of different foodstuff to enforce regulatory standards and protect the health of consumers, especially that of young children. In recent years, focus has fallen on cadmium and in 2014 the EU announced the setting of maximum permissible levels in various food stuffs including cocoa and chocolate products [1]. 

To allow cocoa producers and processors time to prepare, a 4-year implementation period was granted and on 1 January 2019, the new legislation came into force. 

From that point forward, cocoa and chocolate products exceeding the maximum permissible levels cannot be marketed in the EU. In 2025, EU maximum limits for Nickel in some chocolate products came into force. (Source: European Commission [2]). 

The European Commission operates a Rapid Alert System for Food and Feed (RASFF). This is a notification system to exchange information on identified hazards between Member States on food, food contact materials and animal feed. 

In 2014, the RASFF consumers’ portal was launched, a free internet tool to allow the public to access the latest information on food recall notices. It includes public health warnings issued by food safety authorities and food companies [3].

Limits for cadmium in chocolate have since been put in place in other countries including: Australia, Indonesia, New Zealand, Russia and the USA (California), as well as standards being introduced by the Codex Alimentarius. 

Smallholder producers are most affected from some parts of Latin American and the Caribbean where levels of cadmium in cocoa beans can be high. 

Although the levels for cadmium are not set on unprocessed raw cocoa beans, buyers are placing arbitrary limits to ensure the final chocolate products do not exceed the maximum permissible levels [4]. 

Research efforts are continuing in the region to find solutions to prevent and reduce cadmium contamination in cocoa beans.

More information on food safety and cocoa quality can be found in the CAOBISCO/ECA/FCC Chocolate and Cocoa Industry Quality Requirements Manual [5].