Food safety regulations are something we all have to deal with along the cocoa and chocolate value chain. By knowing how and where cacao is grown and processed and how it is transported and stored, we can determine which potential food safety risks are involved with a particular cocoa type or product.
Through understanding which food health risks are linked to cocoa, you will also know which requirements you have to comply with as a producer or exporter and what kind of information and analyses you have to ask for or have to get done when buying your cocoa.
Below is a small overview of the contamination risks that are present throughout the cocoa value chain.
Polycyclic-aromatic hydrocarbons (PAHs)
5.0 μg /kg benzoapyrene and 30 μg/kg of fat in total
What are they?
PAHs are a class of compounds considered as contaminants. Among these, benzoapyrene is classified as a Group 1 substance – carcinogenic to humans – by the International Agency for Research on Cancer.
These compounds can be found in smoked products, teas, coffee, cocoa, vegetable oils and fats, fruits and vegetables. Contamination can take place through the soil or during the processing of the ingredients at high temperatures.
The presence of Polycyclic Aromatic Hydrocarbons in cocoa usually results from cross contamination from artificial drying. The artificial drying units are fueled with wood and the resulting smoke may contaminate the beans.
Does your cocoa have a smoky flavour? Chances are it was dried artificially or might have been exposed to an external source of smoke. Make sure to have your beans analysed for PAHs.
Abballe, Moralez Leme Gomes, Dezembro Lopes, Ferreira de Oliveira, Berto, Efraim, Verdiani Tfouni (2021); Cocoa beans and derived products: Effect of processing on polycyclic aromatic hydrocarbons levels; LWT – Food Science and Technology Journal; Elsevier, Volume 135 – 2021
Artificial drying in Papua New Guinea. In some instances, smoke leakages in wood or organic fueled artificial driers may contaminate the beans with PAH. Photo for illustrative purposes only.
Cadmium limits are calculated based on the concentration in finished chocolate products.
To be on the safe side, importers and chocolate manufacturers usually will accept cadmium levels in cocoa beans which would translate into lower levels in chocolate than those permitted by the EU.
What is it?
Cadmium (Cd) is a heavy metal found as an environmental contaminant, mainly through natural but also from industrial and agrochemical sources. Cadmium is considered a carcinogenic and can cause kidney problems as well as bone de-mineralization.
Geologically younger soils like the ones found in Latin America and the Caribbean have a naturally higher cadmium occurrence than older soils like the ones found in the African continent. However, this is not the only determinant for higher cadmium concentrations. Studies have shown that cadmium levels in cocoa are not only affected by soil concentrations of the heavy metal, but also by the PH and carbon content of the soil.
Countries like Ecuador, Colombia, Peru and Venezuela have conducted studies to identify the regions with the highest cadmium risk within their territories.
Cocoa pods harvested in the Tumaco region of Colombia. Through regular testing of cocoa beans produced in different areas, Colombia has been able to identify low-cadmium producing areas.
Maximum residue limits: In the EU Pesticides Database you can find the latest version of the MRL’s which are applicable to cocoa beans.
What are they?
Pesticides are used in cacao farming to control insect infestation. Chemicals might also be applied during fumigation of a parcel before or after transportation. Maximum residue limits have been established by the European Union to ensure that the chemicals applied during cultivation, storage or transportation will not compromise food health.
It is therefore very important to know who the producers are with which you are working and which farming and pesticide control methods are applied.
Strict controls are carried out on organic certified parcels. Therefore testing of each and every lot that is imported into the EU is essential.
Warehouses in the EU are also strictly monitored and they rarely or no longer apply fumigation on cocoa parcels. Alternative methods which are much more environmentally friendly like freezing or CO2 treatments are applied.
Through trainings and monitoring, partners like Cosecha Partners in Nicaragua can guarantee that the farmers they work with are applying best farming practices to safeguard the organic quality of their cocoa beans. Picture courtesy of Cosecha Partners.
Mycotoxins: Ochratoxin A
Maximum limit: the European Union has established a maximum level of 3 mg/kg of cocoa powder. At the time of writing, there are no regulations on cocoa beans regarding mycotoxins.
What are they?
Ochratoxin A is a mycotoxin naturally produced by fungi of the genus Aspergillus and Penicillium and is found as a contaminant in a wide variety of foods, such as cereals and cereal products, coffee beans, dried fruits, wine and grape juice, spices and liquorice. Ochratoxin A is formed during sun drying and storage of crops. The formation can be prevented by applying good drying and storage practices.
Source: Commission Regulation (EU) 2022/1370 of 5 August 2022 amending Regulation (EC) No 1881/2006 as regards maximum levels of ochratoxin A in certain foodstuffs (Text with EEA relevance)
Berawang Baro delegation head Ali who is leading the operations regarding the use of the ambulance.
Mineral Oil Hydrocarbons: Mineral Oil Saturated Hydrocarbons – MOSH and Mineral Oil Aromatic Hydrocarbons – MOAH
Maximum limit: MOAH 1 mg/kg for foods with a higher fat/oil content than 4% and 2 mg/kg for oils and fats
These limits are recommendations at EU level and as of today, only German legislation has officially established legal limits. Countries like Italy, France and Belgium have also started to monitor these limits at national level.
What are they? MOAH is a mineral oil contamination with possible carcinogenic and genotoxic effects, which can be caused by recycling paper (through migration of printing inks), release or dust binding agents, packaging materials (e.g. non-food grade jute bags) or environmental pollution.
Our partner Finca La Rioja in Mexico, like many other producers we work with who also use jute bags, uses food grade jute bags only. Food grade jute bags have been produced to safeguard the integrity of the products that are contained in them.
As an importer and distributor, Daarnhouwer has the responsibility to guarantee that all of its cocoa beans comply with EU food health regulations. We have mapped the risks according to region, country and production and post-production methods and have our cocoa beans tested accordingly.
Whether you import directly from a partner in origin or through a third party, stay updated on regulatory requirements through EU websites, talk to your importer or distributor and stay informed on the production, post-production, transportation and warehousing practices that are applied to the cocoa beans you use.