Authentic Ceylon Organic Produce · Exporting worldwide since 2014 info@esilkroute.com.lk +94 76 441 0388
E-Silk Route Ventures
Insights

Per-Lot Heavy Metal and Pesticide Testing: How to Read a COA

By E-Silk Route Ventures ·

Per-Lot Heavy Metal and Pesticide Testing: How to Read a COA

Compliance snapshot

  • EU maximum levels for lead in spices are set by plant part, not by species: 0.60 mg/kg for dried fruit spices, 0.90 mg/kg for seed spices, 1.0 mg/kg for bud and flower pistil spices, 1.50 mg/kg for root and rhizome spices, and 2.0 mg/kg for bark spices (Commission Regulation (EU) 2023/915).
  • Where no pesticide MRL is set for a spice, the EU default of 0.01 mg/kg applies (Regulation (EC) No 396/2005). For most dried herbs and spices that default is at or near the laboratory’s own reporting limit.
  • A residue above the MRL is not automatically non-compliant. EU enforcement applies a default expanded measurement uncertainty of 50% and treats a lot as non-compliant only when the measured value minus that uncertainty still exceeds the MRL (SANTE/11312/2021 V2).
  • Silk Route Ventures issues a Certificate of Analysis on every batch, with in-house testing on the standard panel and third-party testing on customer-specific parameters, traceable to farm level on organic SKUs.
  • The comparison table below maps the EU and US positions side by side. The COA reading checklist is the section to send to your QA lead.

Sixteen. That is how many lead notifications the EU’s Rapid Alert System logged against herbs and spices in 2025, against a historical run rate of three to five a year (CBI, 2026). Pesticide residues accounted for 35% of the 279 herb and spice issues recorded that year, with chlorpyrifos the single most-notified substance. For procurement teams in the US and EU, the practical consequence is not a new regulation. It is that the certificate of analysis attached to a lot has stopped being a filing formality and started being the document that decides whether the container clears. This piece covers what per-lot heavy metal and pesticide testing actually measures, which methods produce those numbers, how the limits differ between the EU and the US, and how to read a COA without over-rejecting or under-rejecting a lot.

What per-lot testing actually covers

Per-lot testing on a spice, herb, or botanical powder resolves into two separate analytical programmes that arrive on the same page of paper.

The heavy metals panel is an elemental analysis, usually reporting lead, cadmium, arsenic, and mercury in mg/kg. The pesticide programme is a multi-residue screen, typically covering 300 to 600 active substances in a single injection sequence, reporting each detected compound in mg/kg and reporting everything else as below the reporting limit. Buyers often assume the second one is a pass or fail against a single number. It is not. It is a list, and the list has to be read against a destination-market table that changes by substance and by commodity.

Two things sit outside this scope and are worth naming, because buyers regularly assume the COA covers them. Mycotoxins (aflatoxins and ochratoxin A) are a separate assay on a separate sample preparation. So is ethylene oxide, which is treated in the EU as a pesticide residue but is not always inside a standard multi-residue package. If your spec requires them, they belong in the spec in writing, not in an assumption about what a standard panel includes.

Which methods produce the numbers on your COA

The methods matter because they set the floor on what the laboratory can see, and that floor is what most COA disputes turn on.

For pesticides, the reference method across the EU is EN 15662:2018, the modular QuEChERS method: acetonitrile extraction and partitioning, dispersive solid phase extraction clean-up, then quantification by gas chromatography and liquid chromatography with tandem mass spectrometry. The AOAC 2007.01 QuEChERS variant is its common US-side equivalent. Dried spices are a difficult matrix for this method. Low water content, high essential oil and pigment load, and heavy co-extractives all push recovery and reproducibility harder than they are pushed on a fresh vegetable.

For heavy metals, the standard route is pressure digestion under EN 13805 followed by inductively coupled plasma mass spectrometry under EN 15763. ICP-MS at that specification reads well below the regulatory limits for spices, which is why an elemental result reported as “less than 0.01 mg/kg” is usually a real analytical statement rather than a rounding convention.

Ask for three things in writing when you qualify a laboratory: the method reference, the reporting limit per analyte, and confirmation that the specific matrix sits inside the laboratory’s accreditation scope. A laboratory can be accredited and still have your commodity outside its scope for that analyte. That distinction never appears on the front page of a COA.

What are the EU limits for heavy metals in spices and herbs?

Commission Regulation (EU) 2023/915, which replaced Regulation (EC) No 1881/2006, sets lead maximum levels for spices by the part of the plant used rather than by botanical species. The logic is exposure: roots and bark accumulate more lead from soil than fruits or seeds do, so the limit tracks the plant part.

Spice category (dried)Lead maximum levelTypical commodities
Fruit spices0.60 mg/kgPepper, chilli, allspice, cardamom
Seed spices0.90 mg/kgCoriander, cumin, fennel, fenugreek, nutmeg
Bud and flower pistil spices1.0 mg/kgCloves, saffron
Root and rhizome spices1.50 mg/kgGinger, turmeric
Bark spices2.0 mg/kgCinnamon, cassia

Two adjacent limits belong on the same qualification sheet, because a lot that clears lead can still be rejected on them. Ochratoxin A is capped at 15 micrograms per kg for spices generally, 20 micrograms per kg for dried Capsicum fruits, and 10 micrograms per kg for dried herbs. Aflatoxin B1 is capped at 5 micrograms per kg with a 10 micrograms per kg ceiling on the sum of B1, B2, G1, and G2 across the listed spices.

How do EU pesticide MRLs apply to a dried spice?

This is where most first-time importers of dried botanicals get the arithmetic wrong.

Regulation (EC) No 396/2005 sets a default MRL of 0.01 mg/kg for any active substance and commodity combination without a specific entry. Because dried spices and herbs are a small-volume trade, a large share of substance and commodity pairs fall to that default. The practical effect is that the compliance threshold sits at, or just above, the reporting limit a competent laboratory can achieve.

Drying concentrates residues, and the regulation accounts for it. Under Article 20 of Regulation (EC) No 396/2005, a dehydration factor is applied when the MRL is expressed on the fresh commodity. The European Commission’s guidance note (SANTE-2021-10704) puts those factors across a wide range, from 3 for dried garlic to 13 for dried coriander leaves. The exception matters as much as the rule: commodities that carry their own MRL entry directly for the dried form, including several spices and teas, take no further drying factor on top. Applying one anyway is the most common way a buyer rejects a lot that was compliant to begin with.

Buyer’s checklist: reading a heavy metal and pesticide COA

  1. Confirm the reporting basis. Results should state mg/kg on the product as sold, and note whether they are dry weight corrected.
  2. Check the reporting limit column, not just the results column. “Not detected” against a 0.05 mg/kg limit does not clear a 0.01 mg/kg MRL.
  3. Match each detected residue to the destination market’s table for that exact commodity, not for a related one.
  4. Confirm whether a dehydration factor has already been applied, and whether the commodity has a direct dried-form MRL.
  5. Apply the enforcement decision rule before rejecting on a marginal exceedance.
  6. Verify the method reference and that your matrix and analyte sit within the laboratory’s accreditation scope.
  7. Confirm the lot number on the COA matches the lot on the packing list and the container.
  8. Ask whether mycotoxins and ethylene oxide were in the tested panel, or whether they need a separate request.

Where the US expectation diverges from the EU

The two markets are not stricter and looser versions of each other. They are structured differently, and a lot that clears one can fail the other on a technicality that has nothing to do with quality.

European UnionUnited States
Pesticide frameworkMRLs under Regulation (EC) No 396/2005, with a 0.01 mg/kg default where none is setTolerances set by the EPA under 40 CFR 180
No entry for the substanceDefault MRL of 0.01 mg/kg appliesNo tolerance and no exemption means the food is adulterated under section 402 of the FFDCA
Heavy metals in spicesLead maximum levels set by plant part under Regulation (EU) 2023/915No spice-specific lead action level; the Closer to Zero programme has so far finalised levels for processed baby food
Baby food reference pointCovered by the general contaminants regulation10 ppb lead for fruits, vegetables, and mixtures, finalised January 2025
Border control layerIncreased official controls listed under Regulation (EU) 2019/1793, updated periodicallyImport alerts and detention without physical examination

Read the second row twice. In the EU, a substance with no entry gets a numerical threshold to test against. In the US, a substance with no tolerance and no exemption has no threshold at all, so a confirmed detection at any level makes the lot legally adulterated. A residue at 0.008 mg/kg that comfortably clears the EU default can put the same container out of compliance in the US. This is why the American Spice Trade Association petitions the EPA for import tolerances on specific pairs, as it did in October 2024 for imidacloprid in black pepper at 0.05 ppm. It is also why the EPA’s July 2025 acetamiprid rule, setting 0.1 ppm for black pepper and 2.0 ppm for other listed spices, was worth reading for anyone shipping into the US.

The border layer moves too, and it moves by country. Under the June 2026 update to the increased official controls list (Commission Implementing Regulation (EU) 2026/1206, applying from 30 June 2026), Sri Lanka appears in Annex I for yardlong beans on pesticide residues, and for nothing else. No Sri Lankan spice or herb sits on the increased-controls list. Indian cumin seed is listed for pesticide residues and Indian cinnamon for ethylene oxide, with a set of Indian dried spices carrying special conditions under Annex II. That is not a quality verdict on any origin. It is a statement about where the EU is currently spending its inspection budget, and it is a real input into a landed-cost and lead-time model, because a listed consignment carries a check frequency and the delay that comes with it.

How to read the numbers on a COA

Most rejections that turn into disputes come from four misreadings, and none of them require a chemistry background to avoid.

The uncertainty rule. A measured residue above the MRL is not automatically an exceedance. Under SANTE/11312/2021 V2, EU official control laboratories apply a default expanded measurement uncertainty of 50%, corresponding to a 95% confidence level at a coverage factor of 2, calculated from EU proficiency tests. Compliance is decided by subtracting that uncertainty from the measured value: the lot is non-compliant only if the result minus the uncertainty still exceeds the MRL. Worked through, a result of 2.2 mg/kg against an MRL of 1.0 mg/kg gives 2.2 minus 1.1, which equals 1.1, so it exceeds. A result of 1.8 mg/kg against the same MRL gives 0.9, which does not. Buyers who reject on the raw number alone reject compliant lots. Buyers who never apply it accept lots their destination authority will not.

Reporting limits are not zero. A result of “not detected” is only as good as the limit behind it. If the laboratory’s reporting limit for a substance is 0.05 mg/kg and the applicable MRL is 0.01 mg/kg, the COA has not demonstrated compliance. It has demonstrated that the method could not see far enough down. The reporting limit must be equal to or below the limit you are testing against, and the laboratory’s lowest calibration level has to sit at or below that reporting limit.

Units and basis. Milligrams per kilogram and parts per million are the same number. Micrograms per kilogram and parts per billion are the same number, and they are a thousand times smaller. Mycotoxin limits are conventionally written in micrograms per kg and heavy metal limits in mg/kg, on the same document, which is exactly how a decimal place goes missing.

Lot identity. A COA is a statement about a specific lot. Where a supplier issues a certificate against a production run rather than the dispatched lot, the document has drifted from the shipment it is meant to describe.

Certification snapshot: Silk Foods Ceylon, Matale BRCGS (covers spice, herb, coconut, plant-based, and retorted product lines) FSSC 22000 V6 (covers the full processing scope, including capsules, plant-based meats, and retort lines) USDA Organic and EU Organic (per SKU) Sri Lanka EDB-registered, US FDA-registered facility Certificate of Analysis issued on every batch, with traceability to farm level on organic SKUs

What this means for supplier qualification

In the first half of 2026, the Silk Route Ventures procurement desk fielded the same request three times from US and EU QA teams that had never asked it before: send the reporting limits, not just the results. All three had been burned the same way, by a supplier COA that showed a clean screen against limits too high to prove anything about the market they were shipping into. The change in what buyers ask for is the real signal. The regulations moved a little. What buyers now consider a complete document moved a lot.

Build the qualification around four requirements and the rest of the process gets simpler. Require a COA per dispatched lot rather than per production run. Require the reporting limit column alongside the results. Name the destination market in the specification so the supplier tests against the right table from the start. And require that the testing scope be written into the purchase order, because “standard panel” means different things at different laboratories.

Silk Route Ventures (SRV) supplies bulk spices, herbs, and botanical powders against the buyer’s written spec, manufactured and packed at the Silk Foods Ceylon (SFC) facility in Matale, in the historic spice and herb growing belt at the geographic centre of Sri Lanka. In-house testing covers the standard panel on every batch. Third-party testing is run on customer-specific parameters, which is the mechanism buyers use when a destination market or a retail customer requires a named laboratory or a named method. The point of doing it that way is that the spec, not the supplier’s default, sets what gets measured.

Frequently asked questions

What heavy metals are tested in a standard spice COA? A standard elemental panel reports lead, cadmium, arsenic, and mercury in mg/kg, determined by pressure digestion under EN 13805 followed by ICP-MS under EN 15763. EU maximum levels for lead in spices range from 0.60 mg/kg for dried fruit spices to 2.0 mg/kg for bark spices under Commission Regulation (EU) 2023/915.

Can a pesticide residue exceed the MRL and still be compliant? Yes. EU official control laboratories apply a default expanded measurement uncertainty of 50% at a coverage factor of 2, per SANTE/11312/2021 V2. A lot is treated as non-compliant only when the measured value minus that uncertainty still exceeds the MRL, so a result of 1.8 mg/kg against a 1.0 mg/kg MRL is compliant on the enforcement decision rule.

Why do US and EU pesticide results need reading differently? The EU applies a default MRL of 0.01 mg/kg where no specific level is set under Regulation (EC) No 396/2005. The US sets tolerances through the EPA under 40 CFR 180, and where no tolerance or exemption exists, the food is adulterated under section 402 of the FFDCA regardless of the level detected.

Does Silk Route Ventures provide a Certificate of Analysis with every shipment? Yes. A batch COA ships with every order alongside the standard documentation pack. In-house testing covers the standard panel, third-party testing covers customer-specific parameters, and organic SKUs carry traceability to farm level. Buyers can specify the destination market and the required reporting limits at RFQ stage so the testing scope is fixed before the first production run.

How Silk Route Ventures can help

Silk Route Ventures supplies certified bulk spices, herbs, and botanical powders to procurement and QA teams across the US, EU, and Australia, shipped against the buyer’s written specification from the BRCGS and FSSC 22000 V6 audited Silk Foods Ceylon facility in Matale, with USDA Organic and EU Organic on the relevant SKUs. First-order MOQ is 50 kg per SKU, samples ship door to door by international courier at 3 to 5 business days, and production lead time runs 2 to 3 weeks from purchase order to dispatch. Every batch carries a Certificate of Analysis, and the testing scope, including named methods and reporting limits, can be fixed in the specification before the first run. Contact us to send an inquiry or request the certification and testing dossier.

Further reading

Sources

Written by the Silk Route Ventures Trade Team. Silk Route Ventures (E-Silk Route Ventures Ltd) is a Sri Lankan B2B supply-chain operator for the Food, Beverage, Wellness, and Nutraceuticals sectors. The Silk Foods Ceylon manufacturing arm holds BRCGS and FSSC 22000 V6 certification. Questions or to request a sample: Contact us or email info@esilkroute.com.lk.

Sourcing authentic Ceylon produce?

Talk to our team about products, specifications and quotes.

Request a Quote Chat on WhatsApp