Pascha and Heavy Metals

There has been a lot of publicity about the presence of heavy metals, lead and cadmium, in chocolate. It is an emotive issue as no one wants to consume more of these metals than they have to, and so we wanted to provide information about how Pascha deals with this.

Where do these metals come from?

The prime source of these metals is their naturally occurring presence in the soil that the cocoa beans are grown in. This is true for almost any crop, not just cocoa beans and this is true all over the world.

The best tasting cocoa beans in the world are generally regarded as coming from Latin America, and in particular in the foothills of the Andes mountains leading down to the Amazon rainforest. This is where Pascha sources its cocoa beans from. This soil is volcanic and rich, which supports wonderful growing conditions and biodiversity, which leads to great flavor in the beans. But this volcanic soil also contains trace metal content and this can be taken up by the roots of the cocoa trees and into the cocoa fruit which is how it gets into cocoa beans. All cocoa beans from wherever they are sourced will contain these heavy metals, with the actual amount depending (primarily) on the mineral content of the soil.

It is not though just a regional issue. There are significant variations on a micro geographic basis, partly because the natural occurrence in the soil is not evenly distributed and partly also because of other local factors - based on things like seasonality, rainfall, farming techniques, choice of fertiliser, actual cocoa tree species. You can find variations in metal content from farm to farm within a growing area and even from tree to tree within a farm. So the good news is that there are opportunities to choose cocoa beans that have fewer of these metals, even though they cannot be completely eliminated.

What are Safe Levels of these Metals?

There has been a lot of debate as well as legal cases over the last 15 years or so about what a “safe” level of these metals are. There is not a national legal limit in the US for these metals. The only legal limit is one that exists in California, under their Prop 65 requirements. These limits have been defined back in 2018 through a legal process involving all the major chocolate producers in the United States, and one of the main consumer advocacy groups who act to support consumer interests around the Prop 65 law. Proposition 65 (officially the Safe Drinking Water and Toxic Enforcement Act of 1986) is a California "right-to-know" law. It requires businesses to provide clear warnings to Californians before exposing them to chemicals the state identifies as causing cancer, birth defects, or reproductive harm. The maximum limits of lead and cadmium in chocolate were defined in a legal Agreement in 2018. Chocolate products containing more than these limits require a warning notice on their label, and below that warnings are not required. It is generally accepted that if California does not require a warning label on a product that is a good indicator that the product can be regarded by consumers as “safe”.

Pascha applies these California limits as though they are national. We also note that these California limits are stricter than limits for these metals in chocolate that have been defined for the whole of the European Union, where chocolate consumption per head is on average double the level of the US. If the Europeans with their much higher level of chocolate consumption define safe levels as being higher than the levels defined in California, we think that is very supportive of using the California levels as being generally safe in the USA.

The limits were set as follows. There were limits for 2018-2025 and a lower Drop-down level that came into effect in 2025, 7 years after the original agreement. The limits are based on the cocoa content of an individual product. The rationale for this is that the higher the cocoa content in a chocolate product, the lower the sugar, so the less sweet the product and the harder it is to consume a large volume.

For Lead:

For Cadmium:

These are very small amounts – In an 80-gram bar of 70% chocolate the total amount of cadmium that would be allowed would be 0.032 milligrams, or 0.00267 milligrams per square (if there are 12 squares in the bar).

Please note these are limits defined as being generally applicable in terms of the amount of metal per bar (parts per million in a product). This does not define a set number of squares of chocolate or bars etc., that are safe to eat. These are generally safe levels as opposed to always safe levels regardless of quantity of chocolate consumed.

How does Pascha Control against these limits?

Quite simply, we measure the metal content of every batch of cocoa beans before they are used to make our chocolate, and we measure the metal content of every batch of finished chocolate products. We will only sell products that are below these limits. In fact, because we manufacture at the origin in Peru, we do not even import finished products into the US unless they are below these limits.

So how does Pascha Chocolate stack up against these limits?

Because we have been testing every single batch of chocolate since 2018 we have an enormous data set of these test results. The mean test results are now meaningful because of the very large number of test results and we have decided it makes sense to publish these results. It can be expected that any individual batch of a Pascha product will have a metal value close to these average numbers – and always below the maximum level.

These are our average results, which we will update over time:

PPM: parts per million

Note we do not publish results for the White Chips & Bars, No Milk Baking Chips, and Salted Caramel Chips, since there are no cocoa solids in these products other than cocoa butter, and there is no metal content in cocoa butter.

As you can see in the data, there is no measurable lead in our chocolate – the test limits are not able to detect it at their lower resolution limit. There is some cadmium, but in all products, it is significantly below the maximum limit allowed in California.