Q.01

What is cadmium and why is it restricted?

Cadmium (CAS 7440-43-9, EC 231-152-8) is a metal. In the EU it and its compounds are restricted because they are classified as a carcinogen, a suspected mutagen and reproductive toxicant, acutely toxic by inhalation, damaging to organs on repeated exposure, and very toxic to aquatic life with long-lasting effects. Because of those hazards, REACH Annex XVII entry 23 limits cadmium in plastics, paints, plating, brazing fillers and jewellery [1], and RoHS caps it at 0.01% in electrical and electronic equipment [2].

Approach: I checked the EU harmonised classifications (CLP Annex VI), the REACH Candidate List, REACH Annex XVII and the RoHS Directive. I did not look at rules outside the EU.

Why it is restricted: the hazards

Harmonised classification under CLP Annex VI. Annex VI has two entries, one for non-pyrophoric cadmium (index 048-002-00-0) and one for pyrophoric cadmium (index 048-011-00-X). Both carry the same health and environmental classifications:

Hazard classH-statement
Carc. 1BH350 [3]
Muta. 2H341 [4]
Repr. 2H361fd [5]
Acute Tox. 2H330 [6]
STOT RE 1H372 [7]
Aquatic Acute 1H400 [8]
Aquatic Chronic 1H410 [9]

The pyrophoric form is also classified Pyr. Sol. 1 (H250) [10].

Substance of very high concern (SVHC). Cadmium was added to the Candidate List on 20 June 2013 for two reasons: it is carcinogenic (Article 57(a)), and it causes specific target organ toxicity after repeated exposure (Article 57(f)) [11].

What REACH Annex XVII entry 23 restricts

The entry covers "Cadmium and its compounds". The Commission regulation behind it is in OJ L 40 of 2016 [12].

  • Plastics: cadmium may not be used in listed polymers, including PVC, PUR, LDPE, PET, PP and epoxy resins. Mixtures and articles made from them may not be placed on the market at 0.01% Cd or more by weight of the plastic. Articles placed on the market before 10 December 2011 are exempt [1].

  • Recovered PVC: a derogation allows up to 0.1% Cd in certain rigid PVC uses: building profiles, windows, decks, cable ducts and some non-drinking-water pipes. These products must be marked "Contains recovered PVC" [13].

  • Paints: the limit is 0.01% Cd. It rises to 0.1% for paints with more than 10% zinc, and painted articles are also capped at 0.1% of the paint. Articles coloured with cadmium mixtures for safety reasons are exempt [13].

  • Cadmium plating: prohibited on metal articles used in listed sectors, including:

    • food production, agriculture, and cooling and freezing equipment;
    • household goods, furniture and sanitary ware;
    • industrial handling equipment, road and agricultural vehicles, rolling stock and vessels.

    Exemptions cover the aeronautical, aerospace, mining, offshore and nuclear sectors, certain vehicle safety devices, and electrical contacts where they are needed for reliability [14][15].

  • Brazing fillers: the limit is 0.01%, except for defence, aerospace and safety uses [15].

  • Jewellery: the limit is 0.01% by weight of the metal in jewellery-making components, metal parts of jewellery and imitation jewellery, hair accessories, watches and piercing jewellery. Articles placed on the market before 10 December 2011 are exempt, as is jewellery that was already more than 50 years old on that date [15].

Electrical and electronic equipment

Annex II of the RoHS Directive (2011/65/EU) sets a maximum of 0.01% cadmium [2].

If useful, I can next compare the GB position (the UK REACH restrictions and the GB mandatory classification list) or look up a specific cadmium compound.

Q.02

Is cadmium plating still allowed in the EU?

Yes, but only outside the sectors REACH lists. REACH Annex XVII entry 23 bans cadmium plating of metal articles and components used in a defined set of equipment and machinery sectors. It also bans placing such plated articles on the EU market. Where no sector ban applies, cadmium plating is still allowed. The current consolidated REACH text, dated 11 May 2026, keeps the wording unchanged, and I found no new EU restriction proposal under way. Two separate laws limit cadmium further, plating included: RoHS for electrical and electronic equipment, and the End-of-Life Vehicles Directive for cars.

Approach: I read entry 23 in the consolidated REACH Regulation and in ECHA's restriction list. I also checked ECHA's restriction dossiers, the Annex XIV authorisation list, the consolidated RoHS Directive and the End-of-Life Vehicles Directive.

REACH Annex XVII entry 23 (paragraphs 5 to 7)

The entry defines "cadmium plating" as "any deposit or coating of metallic cadmium on a metallic surface" [16].

Paragraph 5: no plating, and no placing such articles on the market, "whatever their use or intended final purpose"

  • Equipment and machinery for food production, agriculture, cooling and freezing, and printing and book-binding.
  • Equipment and machinery for producing household goods, furniture, sanitary ware, and central heating and air-conditioning plant. Articles made in these sectors are covered too.

Paragraph 6: the same ban extends to cadmium-plated articles used in

  • Machinery for producing paper and board, and textiles and clothing.
  • Machinery for producing industrial handling equipment, road and agricultural vehicles (chapter 87), rolling stock (chapter 86) and vessels (chapter 89).

The source for both lists is [16].

Paragraph 7: exemptions (plating stays allowed here)

  • Articles and components in the aeronautical, aerospace, mining, offshore and nuclear sectors where the application requires high safety standards.
  • Safety devices in road and agricultural vehicles, rolling stock and vessels.
  • Electrical contacts in any sector, where cadmium is needed for the reliability of the apparatus.

The same exemptions appear in ECHA's published entry [16][17][18].

Status: ECHA's restriction dossiers for cadmium and its compounds show only cases already decided by the Commission under entry 23, with no open proposal [19][20]. I found no cadmium entry on the Annex XIV authorisation list, so no authorisation is needed for uses that remain allowed.

Electrical and electronic equipment (RoHS 2011/65/EU)

The REACH exemption for electrical contacts does not override RoHS. In electrical and electronic equipment, Annex II caps cadmium at 0.01% [2]. In the consolidated text, the RoHS exemptions for cadmium in electrical contacts all have expiry dates that have now passed:

  • Entry 8(b): categories 8, 9 and 11, expiring between 21 July 2021 and 21 July 2024 [21].
  • Entry 8(b)-I: listed breakers, switches and thermal controls in categories 1 to 7 and 10, expired 21 July 2021 [22].

Vehicles (End-of-Life Vehicles Directive 2000/53/EC)

Materials and components of vehicles placed on the market after 1 July 2003 must not contain cadmium unless a case is listed in Annex II [23]. Up to 0.01% by weight in homogeneous material is tolerated [24]. The only cadmium exemption in Annex II covers batteries for electric vehicles, as spare parts for vehicles placed on the market before 31 December 2008 [25]. So the REACH exemption for vehicle safety devices does not, on its own, let plated parts into cars covered by this Directive.

Bottom line by use

UseStatus in the EU
Equipment in the paragraph 5 and 6 sectors (food, agriculture, household goods, furniture, vehicles and similar)Banned under REACH entry 23
Aerospace, mining, offshore and nuclear (high-safety); safety devices in vehicles, rolling stock and vessels; reliability-critical electrical contactsAllowed under REACH, but RoHS and the End-of-Life Vehicles Directive apply where the product falls under them
Other metal articles not in the listed sectors and outside RoHS and the vehicles DirectiveNot restricted by entry 23

I can check the GB position under UK REACH next if useful.

Q.03

What are the limits for cadmium in food like chocolate?

In the EU, how much cadmium chocolate may contain depends on its cocoa solids. The limits are 0.10 mg/kg for milk chocolate under 30% dry cocoa solids, 0.30 mg/kg for chocolate under 50% (and milk chocolate at 30% or more), 0.80 mg/kg for chocolate at 50% or more, and 0.60 mg/kg for cocoa powder sold to consumers. These are set in Annex I, entry 3.2.15, of Regulation (EU) 2023/915 [26]. Great Britain has the same four figures. Switzerland and Brazil set different bands.

Approach: I read the current consolidated EU contaminants Regulation 2023/915, the Swiss contaminants ordinance (SR 817.022.15), ANVISA's limits for Brazil, Health Canada's maximum levels and India's FSSAI contaminant regulations. For GB I opened the assimilated Regulation 1881/2006 on legislation.gov.uk.

EU: Regulation (EU) 2023/915, Annex I, section 3.2 (cadmium)

Consolidated version 02023R0915-20260819:

EntryProductMax level (mg/kg)
3.2.15.1Milk chocolate, < 30% total dry cocoa solids0.10
3.2.15.2Chocolate, < 50% total dry cocoa solids; milk chocolate, ≥ 30%0.30
3.2.15.3Chocolate, ≥ 50% total dry cocoa solids0.80
3.2.15.4Cocoa powder sold to the final consumer, or used as an ingredient in sweetened cocoa powder or powdered chocolate (drinking chocolate) sold to the final consumer0.60

All four rows: [26]

  • Which products are covered: footnote 14 limits "cocoa and chocolate products" to the products defined in points 2, 3 and 4 of Part A of Annex I to Directive 2000/36/EC [27].
  • No band above 70%: the EU has no separate band for very dark chocolate, so 0.80 mg/kg covers everything from 50% to 100%.
  • Other foods: the same section sets cadmium limits for many other foods, for example:
    • cereals 0.10 mg/kg, and rice 0.15 mg/kg [26];
    • baby food and processed cereal-based food 0.040 mg/kg [28];
    • food supplements 1.0 mg/kg, or 3.0 mg/kg where they are mostly seaweed or dried bivalve molluscs [28].

Other jurisdictions

JurisdictionChocolate / cocoa categoryCd max (mg/kg)
Great Britain (assimilated Reg. 1881/2006, entry 3.2.7)Same four categories and figures as the EU: 0.10, 0.30, 0.80 and 0.60, applying from 1 January 2019 (legislation.gov.uk; latest revised version shown there is dated 28 September 2020)as EU
Switzerland (SR 817.022.15, version 8 September 2025)Milk chocolate, < 30% total cocoa dry matter0.1
Chocolate, ≥ 30% and < 50%0.3
Chocolate, ≥ 50% and < 70%0.8
Chocolate, ≥ 70%0.9
Cocoa powder (100% cocoa dry matter) for consumers or as an ingredient in sweetened cocoa powder0.6
Brazil (ANVISA, data dated 12 Oct 2026)Chocolates and cocoa-based products, < 40% cocoa0.20
Chocolates and cocoa-based products, > 40% cocoa0.30
Cocoa mass (pasta de cacau)0.30

Sources for the table:

  • Switzerland: all five rows come from the ordinance's metals table, whose column heading is "Höchstgehalt (mg/kg)" [29].
  • Brazil: < 40% row [30]; > 40% row [31]; cocoa mass row [32].

What the other searches showed:

  • Canada: I found no cadmium entries in Health Canada's maximum levels.
  • India: FSSAI's cadmium limits have no chocolate or cocoa category.
  • Codex: CXS 193 has limits for cadmium in chocolate, set in several cocoa-solids bands, but I couldn't open the current text of the standard on the Codex site. So I can't confirm the figures.

I can also pull the lead limits for chocolate and cocoa next, or the Swiss lead and nickel entries.

Q.04