CONTAMINANTS

New Codex Lead Limits for Spices and Herbs: What South African Blenders and Packers Must Do

By Mthokozisi Nkosi, Food Safety Specialist & Lead Auditor, ASC Food Safety · 15 min read

CAC48, the 48th Session of the Codex Alimentarius Commission, held from 10 to 14 November 2025 in Rome, added maximum levels to CXS 193-1995 of 2.5 mg per kg for lead in dried bark spices such as cinnamon and 2.0 mg per kg in dried culinary herbs, described by Codex as “Spices, dried bark” and “Culinary herbs, dried”, and removed outdated radionuclide guidance. The Chemical Contamination Risk Assessment Template (RA16) is R690.

What are the new Codex maximum levels for lead in spices and herbs?

CAC48, the 48th Session of the Codex Alimentarius Commission, met from 10 to 14 November 2025 in Rome and added maximum levels to CXS 193-1995, the General Standard for Contaminants and Toxins in Food and Feed: lead at 2.5 mg per kg in dried bark spices such as cinnamon and 2.0 mg per kg in dried culinary herbs.

Codex describes the two entries as “Spices, dried bark” and “Culinary herbs, dried”. Outdated radionuclide guidance was removed.

The published standard now carries a cover reading adopted in 1995, last amended in 2025, which is the line to quote when a customer asks which version you are working to. CXS 193-1995 is the single Codex text that collects contaminant maximum levels across commodities, so a spice buyer, a retailer technologist and an importing authority all reach for the same document. It is a free download from FAO. Nobody should be selling it to you, and nobody should be telling you they hold a privileged copy.

Two things are worth saying plainly at the start. First, a Codex maximum level is a risk management figure agreed between member governments, not a toxicological threshold below which lead is desirable. Lead has no useful role in food and the direction of travel in every jurisdiction is downward. Second, these two entries did not exist before. A spice blender who has never tested for lead has not been breaking a Codex rule, because there was no commodity level to break. From November 2025 there is one, and customer specifications follow Codex quickly.

What counts as a dried bark spice and what counts as a dried culinary herb?

A dried bark spice is made from the bark of a plant, cinnamon and cassia being the commercial examples, traded as quills, broken bark or ground powder. A dried culinary herb is the dried leaf of a plant, such as oregano, thyme, basil, parsley, rosemary and bay. The distinction decides which figure applies, 2.5 mg per kg or 2.0 mg per kg, so a specification cannot lump them together.

This sounds obvious until you look at a real raw material list. Most South African blenders buy across the whole botanical range in one purchase order: bark, leaf, seed, root, rhizome, fruit, berry and flower bud. Only two of those groups now have a Codex lead level attached to them. Ginger and turmeric are rhizomes. Pepper, coriander, cumin and fennel are seeds or fruits. Chilli is a fruit. Clove is a flower bud. None of those falls inside the bark spice or the culinary herb description, and a specification that applies 2.0 mg per kg across the whole list is not wrong so much as unexplained, which is what an auditor will pick up.

Ground material deserves separate treatment inside each group. Grinding destroys the visual cues a receiving clerk relies on, mixes lots, and adds an equipment contact step. If you buy cinnamon as quills and grind on site, your hazard picture is different from the site that buys ground cinnamon in a bag from a trader. Say which you do in the assessment.

Does the 2.5 mg per kg level apply to my blend, my rub or my retail pack?

A maximum level in CXS 193-1995 attaches to the commodity as the standard describes it. Dried bark spices and dried culinary herbs are the commodities. A blend, a rub, a marinade or a seasoning premix is a different product, and copying a commodity level onto it produces a specification you cannot defend to your customer or your supplier. Control the level where Codex sets it, at the incoming material.

The wording matters as much as the number. Codex describes the two entries as “Spices, dried bark” at 2.5 mg per kg and “Culinary herbs, dried” at 2.0 mg per kg, and that is the wording to write the specification against. Do not assert a basis of expression that the standard does not print. Read the expression basis off CXS 193-1995 itself before you write the parameter into a specification, and instruct the laboratory in the same line, because one that receives no instruction will report on whatever basis its method defaults to.

For a blender the practical route is arithmetic rather than argument. If you know the lead level of each component and the recipe percentage of each component, you can calculate the expected contribution to the blend and set an internal action level on the components that carry the risk. That calculation gives an expected value from component averages, not a guarantee for a given batch, because lead is not evenly distributed within a component lot, so set the component action level with enough headroom that one high lot cannot carry the blend past a customer limit on its own. Kept current with each recipe change, it is far stronger evidence than a single finished product test taken once a year, and it is exactly the kind of reasoning the Chemical Contamination Risk Assessment Template (RA16) at R690 is built to record.

How does lead get into spices and herbs in the first place?

Four routes account for most of it, and the order matters. For a dried leaf or a bark quill, most of the lead that arrives is on the surface, from soil and dust adhering to the crop and from atmospheric deposition. Root uptake comes next, then deliberate adulteration of ground spice with lead containing pigments, then carry over from milling, grinding and packing equipment.

Surface deposition and drying on open ground. A great deal of the world’s spice and herb crop is sun dried on bare ground, on roadside verges, on tarpaulins or on concrete aprons. Soil and dust adhering to the crop, and atmospheric deposition, settle lead onto the surface of a leaf or a bark quill, and it does not wash off in the way a buyer imagines. The same practice drives the microbiological load, which is why spices are also a recurring source of Salmonella findings, and why the Microbiological Contamination Risk Assessment Template (RA14) at R690 usually needs to be opened alongside the chemical one for this commodity group.

Soil and geology. Lead is taken up from soil, but it binds tightly to soil organic matter and is only weakly translocated into the parts you buy, so most of it stays in the roots. Root uptake still matters where the soil burden is high, the soil is acidic and the species accumulates, and it is the route to ask about for roots and rhizomes such as ginger and turmeric. For a dried leaf or a bark quill, ask about the drying surface, the handling and the washing before you ask about the geology, because that is where the control is. Growing areas near historic mining, smelting, informal battery recycling or long term traffic corridors still carry more, which is why a change of growing region matters even when the trading company has not changed.

Adulteration. Lead containing pigments have been used to add weight and colour to ground spice. This is a food fraud problem before it is a contaminant problem, and it is a strong argument for buying whole and grinding on site where the process allows it. Speak about it as origin risk and chain risk rather than as a national characteristic. I am not going to name a country here, because the honest position is that adulteration follows price pressure and weak chains, not borders, and a register entry that says a country is dangerous is both unfair and useless as a control.

Equipment. Grinders, hammer mills, sieves, blenders and filling heads are metal contact steps. Older equipment can carry brass and bronze fittings and lead bearing solder, and abrasive material such as bark and seed is aggressive on contact surfaces. Ask your engineering team for material certificates on food contact parts, and treat second hand equipment brought in without documentation as an open question. Good manufacturing practice is the layer that catches this, and the Implementation of Good Manufacturing Practices course at R1,950 is the fastest way to get a maintenance and production team speaking the same language about contact surfaces.

What a South African blender must change in its raw material specifications

Five changes, all small. Split bark spices and culinary herbs into their own specification groups. Add lead as a named parameter with the Codex figure, the Codex commodity wording, the unit and the expression basis read off CXS 193-1995. State the method family and an acceptable limit of quantification.

Set the frequency of supplier and verification testing. And add a change notification clause covering the growing region and the processing site, not only the trading company.

The specification is where this either becomes real or stays an intention. A parameter that appears only in your internal risk assessment has never been communicated to the person who can actually control it. Send the revised specification, get it signed, and diarise a review date. Where a supplier will not sign, that refusal is itself information for the approval file.

• Lead named as a parameter with the figure, the Codex commodity wording, the unit as mg per kg, and the expression basis read off CXS 193-1995 written in the same line
• An internal action level set below the Codex level so that a borderline result triggers a decision rather than a debate
• The required limit of quantification stated, so a certificate reading less than 5 mg per kg cannot be used to demonstrate conformance with a 2.0 mg per kg level
• Sampling responsibility named: who draws the sample, from how many bags, and to which sampling plan
• Testing frequency by lot, by consignment or by period, set from the risk tier rather than from habit
• A change notification clause covering growing region, processing site, grinding site and any change from whole to ground supply
• A statement of what happens on a non conforming result, agreed in advance, including who bears the cost of confirmatory testing
• The specification review date, the version number and the signature of both parties

Two of those deserve emphasis. The limit of quantification clause closes the most common loophole in spice certificates, where a laboratory reports below its own generous detection limit and the number looks like a pass. The change notification clause closes the second, where the same trading company quietly moves its source between shipments and every historical test result you hold stops describing the material you are now receiving. Our guide to importing food into South Africa covers the border side of the same problem, including Port Health detention of imported foodstuffs at points of entry.

What a certificate of analysis for lead should actually show

The laboratory name with its accreditation scope, the sample identity tied to your lot, the sampling date and sampler, the method, the limit of quantification, the result with its uncertainty, and the units and basis of expression. A result reported as less than the limit of quantification is useful only when that limit sits well below 2.0 mg per kg. A certificate missing method and uncertainty is a covering letter.

Certificates of analysis are batch evidence, not approval evidence. They tell you what the supplier says about one consignment against agreed parameters, and they say nothing about the system that produced it. Use them to verify an approved supplier consignment by consignment, and use specification, questionnaire, audit and testing to approve the supplier in the first place.

Sampling a spice consignment: increments, aggregate size and grinding

Lead in a spice consignment is not evenly distributed, so the sampling plan carries as much weight as the analysis. Draw incremental samples from bags across the lot, combine them into an aggregate sample, reduce it to a laboratory sample by a described method, and record every step. One scoop from the top bag of a pallet produces a number, not information, and it will not survive a challenge.

Write the plan down before the delivery arrives, because a sampling decision made on the receiving bay under time pressure is always the convenient one. The plan needs a stated number of increments related to lot size, named sampling points, a description of how the aggregate sample is mixed and divided, sample container and labelling requirements, storage conditions before dispatch to the laboratory, and retention of a reserve sample in case a confirmatory test is needed later.

1. Define the lot before you sample itA lot is material of one origin, one production period and one supplier delivery. Mixed origin pallets sampled as one lot give a result that describes nothing you can act on, and they break the traceability you will need if the result is high.
2. Take incremental samples across the lotSample from multiple bags at different positions in the load, not from the accessible face. Record which bags were sampled and by whom, with the date and the lot identity, on the sampling record.
3. Reduce to a laboratory sample by a described methodMix the aggregate, divide it by quartering or with a sample divider, and record the reduction. Where the material is whole and the test is on ground material, record who ground it and on what, because the grinder is itself a contact surface.
4. Retain a reserve sampleKeep a sealed retained portion under defined conditions for the shelf life of the material. When a result comes back high, the reserve sample is what lets you re-test the same material rather than argue about a different one.
5. Trend the results, do not file themPlot lead results by supplier, by origin and by commodity group over time. A supplier drifting from 0.4 to 1.6 mg per kg over four consignments has told you something before any single result fails.

A test result is only as good as the sample behind it, and most spice samples are drawn by the person with the shortest walk to the pallet.

What to do when a dried bark spice or a dried culinary herb exceeds the Codex lead level

The two figures are lead at 2.5 mg per kg for spices, dried bark, and at 2.0 mg per kg for culinary herbs, dried. Check which entry your material falls under before you act, because the wrong entry gives you the wrong answer in both directions.

Place the lot on hold under a documented non conforming product procedure before anything else, and extend the hold to earlier lots from the same source still in stock. Confirm by re-sampling and re-testing, ideally at a second accredited laboratory. Assess product already released and decide on withdrawal or recall. Raise a supplier corrective action request that asks for the cause. Record the disposal route for rejected material.

The same sampling logic applies to the revised peanut aflatoxin code of practice.

The sequence matters because the commercial pressure runs the other way. A high result on a bulk consignment is expensive, and the first instinct on most sites is to re-test until a lower number appears. Re-testing to confirm is legitimate. Re-testing until the answer is convenient is not, and the trail of results sits in your quality records where an auditor or an investigator will read it.

Do not blend down. Mixing a high lead lot with a compliant one to bring an average under a limit is dilution of a contaminant, and it is treated as such by every scheme and every regulator. It also destroys your traceability. If the conversation on your site has ever reached that suggestion, the control gap is cultural rather than technical, and it needs to be fixed at that level.

Is the Codex lead level the legal limit in South Africa?

No. Codex is not South African law. Our own regulations made under the Foodstuffs, Cosmetics and Disinfectants Act 54 of 1972 set the legal metal limits for food sold here, and those instruments sit in the ASC South African legislation register. The Codex figure is what a customer specification, an export buyer and an importing authority will reach for.

I am deliberately not printing a South African metal limit figure in this article. Metal limits move through amendment notices, the number that matters is the one in the instrument currently in force for your specific product category, and a figure copied from a blog into a specification is how sites end up defending a limit nobody can source. Check the register, read the instrument, and if you want the position confirmed for your product in writing, ask us and we will do it as a scoped piece of work through the labelling and regulatory advisory.

Two practical points follow from the split. For domestic sale, the South African instrument governs and the Codex level is a reference point that a retailer may still write into its own specification. For export, the importing country’s law governs, and where that country has no national level it will very often apply the Codex level, which is exactly why heavy metals in spices recur as an export rejection reason. A South African blender selling into both markets therefore needs to satisfy the stricter of the two, per destination, per commodity.

The wider picture of how Codex, the WTO SPS Agreement and our own regulations fit together is set out in our South African food legislation guide, and the full set of 2026 Codex changes is in the parent article, the full list of every Codex change from CAC48 and CAC49.

How the four new 2026 Codex spice standards fit with the lead limits

CAC49, the 49th Session, met from 6 to 10 July 2026 at the Centre International de Conferences Geneve and adopted four commodity standards for spices: CXS 366-2026 for fresh curry leaves, CXS 367-2026 for vanilla, CXS 368-2026 for large cardamom and CXS 369-2026 for coriander. They sit alongside the contaminant levels rather than repeating them. The July 2026 session was CAC49, not CAC48, and that error is everywhere.

The relationship is worth understanding because it changes how you build a specification. A commodity standard describes what the material is: its definition, its presentation, its quality factors and its labelling. CXS 193-1995 describes what may be in it by way of contaminants. A complete raw material specification for coriander in 2026 therefore has two Codex reference points, the commodity standard for identity and quality and the contaminants standard for the metal, and neither one covers the other.

Alongside those four, a further eight spice and culinary herb standards from the Codex Committee on Spices and Culinary Herbs were last modified in 2025: CXS 342-2021 dried oregano, CXS 343-2021 dried roots, rhizomes and bulbs, CXS 344-2021 cloves, CXS 345-2021 dried basil, CXS 347-2019 dried or dehydrated garlic, CXS 351-2022 saffron, CXS 352-2022 nutmeg, and CXS 353-2022 dried or dehydrated chilli pepper and paprika. The register carries the current version and modification date for each. Read them off the ASC Codex and guidelines register, which carries the full 2025 and 2026 change log. Every Codex text is a free download from FAO.

What a defensible heavy metal control programme looks like

Four parts, in this order. A written risk assessment that names the metals, the materials and the routes. A supplier approval file that reaches the processing site and the growing region, not only the trader. A verification testing programme sized to the risk tier and independent of supplier certificates. And a trend review that feeds results back into the tiers. Anything less is a folder of certificates.

The order is not decorative. Sites that start with testing end up spending money on analysis that tells them nothing, because they have not decided what they are looking for or what they will do with the answer. The risk assessment sets the question. The supplier file decides how much of the answer the supplier is trusted to provide. The testing verifies it. The trend review is where the programme either improves or quietly stops.

One correction worth making while you are rebuilding the programme, because the claim circulates and it wastes people’s time. CXC 1-1969, the General Principles of Food Hygiene, did not change in 2026. The current text is the 2022 revision, published as the 2023 edition, with its HACCP annex. A revision is in progress at the Committee on Food Hygiene and has not been adopted. There is no 2026 edition, so a consultant offering to upgrade your prerequisite programmes to one is selling you something that does not exist.

Where the programme touches microbiology as well, and for spices it usually does, the analytical side is easier to run when your technical staff understand what the laboratory is doing. Advanced Food Microbiology at R1,750 is the level that makes a technical officer useful in a laboratory conversation rather than dependent on it, and the practical side of the audit itself is set out in our guide to the complete guide to food hygiene audits.

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Published by ASC Food Safety, South African food safety and quality consultants. This article is general guidance and not a substitute for certification-specific advice.