Key takeaways
- Heavy metals in botanicals and dried fruit need matrix-specific controls. EU Regulation 2023/915 sets food-category limits for several metals, but many dried herbs are handled through buyer specifications, pharmacopoeial expectations, and risk assessment rather than one universal legal number.
- Lead and cadmium are the first screen for dried fruit and herbal raw materials. Arsenic and mercury become critical when the botanical comes from mineral-rich soils, irrigated river basins, seaweed-adjacent supply chains, or concentrated extracts.
- Dried products require processing-factor thinking. Regulation (EU) 2023/915 Article 3 requires operators to account for concentration or dilution when no dried-product limit is listed directly; buyers should ask the supplier how the factor was justified.
- ICP-MS is the normal release method for B2B lots. ICP-OES can screen higher levels, but ppb-level Pb, Cd, As and Hg decisions normally require accredited ICP-MS with clear LOQ and sample digestion details.
- Arovela should be evaluated on documented lot control, not invented credentials. The relevant Arovela systems are ISO 22000, ISO 9001 and ISO 27001; organic, GMP, Halal, Kosher or retailer schemes are buyer-side requirements unless separately documented.
Introduction
Heavy metals in botanicals and dried fruit are not a theoretical laboratory issue. They decide whether a tea blend can enter an EU warehouse, whether a dried fruit inclusion can be used in a child-facing snack, and whether a botanical extract can survive a supplement brand's supplier audit. The procurement problem is difficult because the legal architecture is uneven: dried fruit, fresh fruit, food supplements, infant products and herbal medicinal products do not all sit under the same numeric line.
This guide is written for QA managers, importers, private-label teams and regulatory staff buying Turkish dried fruit, medicinal herbs or botanical ingredients. It explains how to read EU Regulation 2023/915 without pretending it gives a single answer for every dried botanical, how to set realistic internal limits for Pb, Cd, As and Hg, and how to challenge a weak COA. For adjacent checks, use the Arovela guides on COA review, botanical ingredient testing and mycotoxin limits in dried fruit.
The regulatory map: law versus buyer policy
The EU's core legal source is Commission Regulation (EU) 2023/915. It replaced Regulation (EC) No 1881/2006 and sets maximum levels for contaminants in foods placed on the EU market. The rule is strict where a product category is listed: food above the maximum level cannot be placed on the market or used as an ingredient. But not every botanical matrix has a neat row. That is where Article 3 matters: for dried, diluted, processed or compound foods, the operator must account for concentration, dilution and ingredient proportions.
For dried fruit, the practical question is whether the food category has a direct dried-product line or whether the buyer must apply a processing factor from the fresh commodity. For herbal teas and dried medicinal herbs sold as food, EU-wide heavy-metal maximum levels are less comprehensive than buyers often assume. Retailers and brand owners therefore impose internal limits, sometimes borrowing from pharmacopoeial monographs, national guidance, or Proposition 65-style risk triggers for the US. A supplier who says "EU compliant" without naming the category, limit and calculation has not answered the question.
Working limits buyers actually use
The table below separates hard legal references from common B2B acceptance targets. It is intentionally conservative. It should not replace legal review for a finished product, but it gives procurement teams a starting point for RFQs and sample approval.
| Matrix and use case | Lead Pb | Cadmium Cd | Arsenic As | Mercury Hg | Compliance note |
|---|---|---|---|---|---|
| Fresh fruit under EU 2023/915 category logic | typically 0.10 mg/kg for many fruits | commonly 0.020-0.050 mg/kg depending on fruit group | no universal fruit line | no universal fruit line | Dried fruit may need Article 3 processing factor |
| Dried fruit for EU snack or bakery use | buyer target often ≤0.20-0.50 mg/kg Pb | buyer target often ≤0.05-0.20 mg/kg Cd | buyer target often ≤0.10-0.50 mg/kg total As | buyer target often ≤0.02-0.05 mg/kg Hg | Internal spec should justify processing factor and serving size |
| Dried herbs for infusion | buyer target often ≤2.0-5.0 mg/kg Pb | buyer target often ≤0.3-1.0 mg/kg Cd | buyer target often ≤1.0 mg/kg total As | buyer target often ≤0.1 mg/kg Hg | Many buyers set tighter limits for children's or wellness products |
| Botanical extracts | limits calculated from extract ratio and daily dose | limits calculated from extract ratio and daily dose | inorganic As may be requested separately | Hg usually low but screened | Concentration can raise metal levels versus raw herb |
| Food supplements in EU 2023/915 | 3.0 mg/kg Pb | 1.0 mg/kg Cd for many supplements; higher for some seaweed-derived products | category-specific | 0.10 mg/kg Hg | Relevant only if the ingredient is placed as supplement product |
The buyer-target rows are not Arovela claims and not universal law. They are common acceptance bands used to avoid surprises. A finished-product brand may be stricter, especially for baby food, pregnancy products, daily-use herbal teas or high-dose capsules. If a buyer wants lower limits, the RFQ should say so before sampling.
Why dried products cannot use fresh limits blindly
Drying removes water and concentrates minerals. If a fresh fruit loses 75 percent of its weight during drying, a metal concentration in mg/kg can rise roughly fourfold even when the absolute metal mass has not changed. EU Regulation 2023/915 recognises this by requiring concentration factors for dried or processed foods where no direct maximum level exists. The buyer should ask three questions: what fresh-product limit or reference category was used, what drying ratio or processing factor was applied, and whether the COA is reported on the product as sold or back-calculated to fresh weight.
A COA that reports "Pb: pass" without the numerical result and the applicable limit is weak. A better COA reports Pb 0.18 mg/kg, Cd 0.035 mg/kg, total As 0.09 mg/kg and Hg below LOQ, with the method, LOQ, sample date and lot number. If the product is an extract, the DER or native extract ratio must be visible because a 10:1 extract can concentrate metals as well as active compounds.
Sources of contamination by product type
Dried fruit risk usually starts with soil, irrigation water, atmospheric deposition and processing equipment. Lead may come from legacy industrial dust, old paint, traffic corridors or contaminated soil. Cadmium is linked to phosphate fertilizers, geology and certain crops' uptake behavior. Arsenic is more relevant where irrigation water has natural arsenic or where rice-based carriers are used in powdered ingredients. Mercury is usually low in terrestrial botanicals but still appears in broad four-metal panels.
Botanical herbs add two complications. First, leaves and flowers have high surface area and collect dust. Second, wild or semi-wild collection areas may be close to roads, mines or old industrial sites. Chamomile, nettle, sage and rosehip lots should therefore be linked to collection region and harvest year. Arovela must not invent a farm-level claim; it can provide lot-level documentation and supplier declarations for the material actually shipped.
Testing methods: ICP-MS versus cheaper screens
| Method | Best use | Typical strength | Buyer caution |
|---|---|---|---|
| ICP-MS | Export COA, low ppb screening, multi-metal panel | Low LOQ, multi-element, strong audit acceptance | Ask for digestion method and accreditation scope |
| ICP-OES | Higher-level mineral and contaminant screening | Robust and cost-effective | May be too insensitive for tight Pb/Cd limits |
| AAS / graphite furnace | Single-metal confirmation | Familiar and established | Slower for multi-metal release |
| XRF screening | Incoming raw-material triage | Fast, non-destructive | Not enough for final COA unless validated |
For arsenic, total arsenic is often the first screen. If total arsenic is elevated, buyers may request inorganic arsenic because toxicological relevance differs by species. Seaweed-derived ingredients require special attention; most Turkish dried fruit and terrestrial herbs are not in that risk class, but the COA should still match the buyer's intended use.
RFQ and COA language that prevents disputes
Use direct wording: "Supplier shall provide per-lot ICP-MS results for Pb, Cd, total As and Hg on the product as shipped. Results shall include method, LOQ, sample date, lot number and laboratory accreditation. If the product is dried or extracted and no direct EU maximum level applies, supplier shall state the processing or concentration factor used for regulatory assessment. Buyer limits are Pb ≤ X mg/kg, Cd ≤ Y mg/kg, total As ≤ Z mg/kg and Hg ≤ W mg/kg unless otherwise agreed in writing."
This protects both sides. The buyer gets a testable release gate, and the supplier avoids surprise rejection after production. It also prevents the common problem of mixing regulatory and marketing language. ISO 22000 supports food-safety management, but it is not a heavy-metal certificate. ISO 9001 supports quality management, but it does not guarantee a Pb result. ISO 27001 supports information security, not contaminant control.
Frequently asked questions
Does EU law set one heavy-metal limit for all dried botanicals?
No. EU Regulation 2023/915 sets maximum levels by food category. Some categories have clear limits, while many dried herbs and botanical ingredients require case-by-case assessment, buyer specifications and processing-factor logic. A responsible supplier should identify the applicable category instead of saying only "EU compliant."
Should buyers test every shipment?
For first orders, new origins, new harvest years and concentrated extracts, yes. Once several lots show stable results, some buyers move to risk-based testing, but they normally keep Pb, Cd, As and Hg in the annual monitoring plan. High-risk regions or child-facing products justify more frequent testing.
Is a low heavy-metal result enough for release?
No. It is one part of release. Dried fruit and botanicals also need microbiology, pesticide residues where relevant, mycotoxins for susceptible matrices, sensory approval, packaging checks and traceability. The COA should be reviewed as a complete lot file, not as a single number.
Build a defensible heavy-metal specification
If your team is buying dried fruit, herbs or botanical ingredients from Turkey, Arovela can support lot-specific documentation, COA review and export planning within its ISO 22000, ISO 9001 and ISO 27001 systems. Start with a technical quote request, compare wholesale supply options, or review Arovela certifications before setting your Pb, Cd, As and Hg limits.