The 18th session of the Codex Alimentarius Committee on Contaminants in Foods (CCCF18) successfully addressed all the topics on its draft agenda and a few more under “other business”. Worth noting that CCCF18 approved two new international maximum limits (MLs) for the ‘heavy metal’ lead, in dried bark spice and in dried culinary herbs at 2.5 mg/ kg and 2.0 mg/kg respectively (for future inclusion in CXS 193). CCCF18 adopted the sampling plans for total aflatoxins and for Ochratoxin A in certain spices. CCCF18 also adopted a revised version of the existing Codex Code of Practice (CoP) for the prevention and reduction of aflatoxin contamination in peanuts (i.e., CXC 55), but decided to stop working on a ML for total aflatoxins in ready-to-eat peanuts and its associated sampling plan. CCCF18 finalized two other important documents on an internal Guidance to Codex members and observers on data analysis for the development of MLs and improve data collections; and, on the proposed numerical performance criteria (NPC) for methods of analysis (MOA) of total aflatoxins in several nuts and in dried figs. CCCF18 deleted some text in the main standard (CXS 193) referring to health effects of radioactive substances after a nuclear accident. CCCF18 agreed to start several new works, such as the revision of two existing CoPs on pyrrolizidine alkaloids (CXC 74) and on Aflatoxin B1 in raw materials and supplemental feedingstuffs (CXC 45)), and a new CoP on tropane alkaloids. CCCF18 adopted a revised list of priorities for risk assessment and evaluations (e.g., Dioxins and dioxin-like PCBs; Perfluoroalkyl substances (including PFAS); Ethylene Oxide; Bisphenols; etc.) by the FAO/WHO JECFA expert committee. CCCF18 also agreed to return for further elaboration the new CoP on the prevention and reduction of cadmium contamination in (all) foods. Finally, CCCF18 discussed five other businesses, including an update about a possible future new work proposal for a further guidance on food safety aspects related to the use of recycled plastic materials in food contact packaging.1
See more information available about CCCF18 working documents quoted in this article,2 as well as in the official report of the CCCF18 meeting.3 Codex standards, guidelines, codes of practices and related miscellaneous texts quoted in this article are readily and freely available.4 Mrs Sally Hoffer, Chairperson of CCCF18, in her closing remarks said, “I am elevated at the Chair-person’s head table, but I am not: I, and the Committee, wouldn’t deliver much without the chairs and co-chairs [of the electronic, physical, virtual and in-session working groups], who all do the ground work, based on the contributions of all Codex members in collecting, sharing, and analysing the data, and for their inputs to Codex drafts in such a collaborative spirit; including but not limited to the USA, the EU, the Netherlands, Türkiye, Saudi Arabia, Brazil, India, China, Canada, the United Kingdom, Thailand, and so many more.”
New MLs for lead (Pb) in dried bark spices and for dried culinary herbs
CCCF18 approved two new international maximum limits (MLs) for the ‘heavy metal’ lead (Pb) in dried bark spice and in dried culinary herbs (respectively at 2.5 mg/kg and 2.0 mg/kg) for final adoption by CAC48, noting that the level applicable to dried culinary herb could be used to derive a related ML for fresh culinary herbs, based on the moisture content of the fresh herb in relation to the dried herb (a note was added). CCCF18 indeed lowered slightly the proposals from the EWG (which was 3.0 mg/kg for lead in dried bark spices and 2.5 mg/kg in dried culinary herbs). China expressed its reservations on the two proposed MLs, while India expressed theirs on the dried bark spice only, as India supported rather the EWG proposed ML of 3.0 mg/kg, as India was of the view that a Codex ML should be determined based on the 95th percentile (P95) value of 59 or more data points. For reasons of data points showing high levels of rejections in domestic production, China also preferred the EWG proposed ML of 3.0 mg/kg for dried bark spice. Regarding dried culinary herbs, China supported an ML of 2.5 mg/kg, citing general support during the previous session and new data from developed countries. The EWG Chair emphasized that there had been several calls for data over the years (in 2019, 2020, 2021, 2022 and 2024) and that these calls for data included occurrence data of lead in dried bark spices and dried culinary herbs and that the MLs were therefore based on the best data available. Another Member did not support the proposed ML for dried culinary herbs, and their preference was for a lower ML of 1.5 mg/kg.5
Sampling plans for total Aflatoxins and Ochratoxin A in certain spices (pending endorsement by CCMAS)
CCCF18 concluded all the technical discussions on the sampling plans for total aflatoxins (AFT) and for Ochratoxin A in Nutmeg, Dried Chilli, and Paprika (both as a whole or as crushed/cracked/broken/ flakes). CCCF18 sent these sampling plans to the Codex Committee on Methods of Analysis and Sampling (CCMAS) for endorsement, and to the Codex Alimentarius Commission (CAC48) for final approval, and future inclusion into the Codex General Standard on Contaminants and Toxins in Food and Feed, i.e., the ‘GSTCFF’ (CXS 193). The proposed sampling plans discussed by CCCF18 resulted from an intersessional work of an EWG and a PWG chaired by India.6
Revised version of the existing Codex Code of Practice (CoP) for the prevention and reduction of aflatoxin contamination in peanuts (i.e., CXC 55) approved, but discussion on a possible ML for AFT in Ready-to-Eat (RTE) peanuts discontinued
CCCF18 adopted a revised version of the existing Codex Code of Practice (CoP) for the prevention and reduction of aflatoxin contamination in peanuts (CXC 55) based on the outcome of an intersessional work (EWG and PWG) led by Brazil and presented in CCCF18-CRD31, noting one point for further discussion: whether the section on roasting (section 7.6, paragraph 65) in the proposed code should be deleted as concerns were expressed that roasting was not recognized in some member countries as a step that could reduce aflatoxin in peanuts, and that aflatoxin could bind to components of the peanut matrix, making them less detectable during routine analytical testing of the “free” mycotoxin. CCCF18 agreed to retain the section on roasting in the final text of the revised CoP.7
On a separate note, and discussion, CCCF18 agreed to discontinue the work engaged 10+ years ago on a possible ML for total aflatoxins in RTE peanuts and to inform CAC48 accordingly. CCCF18 recognized that more time should be given for the implementation of the revised CoP and for new data to be generated and submitted to the WHO-GEMS/Food database specifically on AFT levels in RTE peanuts (as per the working definition adopted by CCCF previously). Only then, CCCF18 may consider again discussing a draft ML for AFT in RTE peanuts, as a possible new work in the future.8
Informative Guidance to Codex members and observers on data analysis for the development of MLs and improve data collections
CCCF18 finalized a very important internal document in endorsing the main body text of the “Guidance on data analysis for the development of maximum levels and for improved data collection” for Codex members and Observers generating, collecting, sending occurrence data to the WHO-GEMS/Food database, and analyzing such data from that database. CCCF18 agreed to publish it as an information document on the Codex website, with the understanding that the document would be updated following the implementation of the agreed changes to the WHO-GEMS/Food database’s template (for data collection) and the experience gained in applying the Guidance itself. CCCF18 also agreed to reconvene an EWG, led by the European Union, and co-led by Japan, the Netherlands and the USA, to continue elaborating the Guidance, in particular on data analysis for the development of maximum levels and for improved data collection (i.e., on the Guidance’s annexes on (a) “Drawing charts/ graphs and plots on distribution of occurrence data” (annex III), (b) “Presentation of data analysis/statis-tical analysis” (annex V) and (c) “Glossary of terms” (annex VI). The EWG was also tasked to prepare a further discussion paper on (i) the “Determination of outliers/extreme values and handling them” (annex I), (ii) the “Minimum number of data points for estimating high percentile values” (annex II), (iii) the “Preliminary calculation of dietary exposure and its reduction rate to the contaminants from target commodity(ies) at the hypothetical MLs” (annex IV), and (iv) possible topics for future discussion taking into account existing publications, such as IPCS Principles and Methods for the Risk Assessments of Chemicals in Foods (EHC 240, FAO/WHO) for consideration by CCCF19.9
Numerical Performance Criteria (NPC) for Methods of Analysis (MOA) for total aflatoxins (AFT) for several nuts and dried figs (i.e., Peanuts intended for further processing; tree nuts destined for further processing: almonds, hazelnuts, pistachios, and shelled Brazil nuts; Ready-to-eat tree nuts: almonds, hazelnuts, pistachios and shelled Brazil nuts; and, for Dried figs).
CCF18 agreed to forward these NPC to CCMAS45 for endorsement and inclusion in the general standard on methods of analysis and sampling (CXS 234) and request the Codex Secretariat to amend the relevant sampling plans set in the Codex GSTCFF (CXS 193), by replacing the current NPCs and related texts with a reference to CXS 234, but only once CCMAS would have endorsed the new NPC, and also inform the CAC accordingly.10 CCCF18 also requested an advice from CCMAS45 on the determination of the appropriate LOQ for AFT (relationship between individual LOQs for each mycotoxin and the LOQ for total AFT). This issue was handled under the lead of Brazil, which noted that establishing NPC for sum of components was a complex issue and that, while there was guidance provided in an information document titled, “Approaches which use a ‘sum of components’” published on the Codex website, such guidance equally stated that NPCs should be set on a case-by-case basis.
Revised list of priorities for assessments and evaluations by the FAO/WHO expert body JECFA and CCCF follow-up on previous evaluations by JECFA
CCCF18 also adopted a revised priority list of several assessment and evaluation works directed to the FAO/WHO JECFA scientific expert body on chemical substances and toxins (i.e., an update on Dioxins and dioxin-like PCBs, an update on Arsenic (inorganic and organic); full risk evaluations of Scopoletin; Thallium; Perfluoroalkyl substances (e.g., PFOS, PFOA, PFNA, PFHxS); and, Ethylene Oxide (EtO) and 2-Chloro-Eth-anol; a refined exposure assessment to Ochratoxin A (OTA) via occurrence in and consumption of dried fruits; risk assessment of Cadmium and Lead present in Yerba Mate (via the consumption of Yerba Mate infusions)).11 Qatar expressed the need for a JECFA opinion on BPA (and other bisphenols, like BPS and BPF) given current divergent national risk assessments conclusions on the safety (or lack of safety) of these substances would lead to restrictions, entering into effect early 2027. On ETO and 2-CE, Indonesia suggested JECFA should assess the risks for EtO and 2-CE separately based on existing scientific literature, while, at the same time, CCCF could invite Codex members to provide additional occurrence data, given that generating new and primary data to support JECFA evaluation of these compounds was challenging.
CCCF18 noted that both UN agencies, the FAO and the WHO, were prioritizing scientific advice based on Codex criteria and moreover based on resource availability. Increased demands for JECFA evaluations (on contaminants, but also on food additives and residues of veterinary drugs) combined with the current reduced donor fundings impacted greatly the ability of JECFA to meeting with all these Codex needs. Regarding JECFA support to CCCF, the WHO representative informed the Committee that the 101st JECFA meeting (scheduled in October 2025) would only be able to perform the requested risk assessment of Arsenic (organic and inorganic), due to WHO budget constraints and on-going restructuration and re-prioritization of the agency. As such, the originally planned evaluation of dioxins and dioxin-like PCBs had been deferred, noting that financial limitations also led to the postponement of a veterinary drug residue meeting and would likely lead to possible reductions in scope of future JECFA sessions (on all three domains JECFA covers). Both FAO and WHO representatives called upon countries for increasing their current contribution to or providing extra-funding for the joint FAO/WHO scientific program.
The FAO-JECFA Secretariat reprentative further mentioned that FAO and WHO jointly determine what could be accomplished from the overall work program assigned to JECFA, considering available resources, suitability of experts, existing data available, and it would report on that review work to the CCCF19 accordingly. CCCF18 noted the ongoing FAO/WHO supportive work to address chemical contaminants in water used throughout the agrifood systems, on evaluating emerging and known contaminants, including pharmaceuticals, agrochemicals, and fluorinated compounds.
With regards to past JECFA evaluations, CCCF agreed to establish a new EWG, led by the European Union to prepare a discussion paper on mycotoxins T-2, HT-2, 4,15-diacetoxyscirpenol (called ‘DAS’) and ergot alkaloids for consideration by CCCF19 and to reconvene a separate WG led by USA to consider the follow-up work on all the outcomes of JECFA evaluations to be held prior to CCCF19.
Update on radionuclides after a nuclear accident
CCCF18 agreed to amend the annex X of the 2024 version of the GSCTFF (CXS 193) by deleting the footnote stating, “The Codex Alimentarius Commission at its 18th Session (Geneva 1989) adopted Guideline Levels for Radionuclides in Foods Following Accidental Nuclear Contamination for Use in International Trade (CXG 5-1989) applicable for six radionuclides (90Sr, 131I, 137Cs, 134Cs, 239Pu and 241Am) during one year after the nuclear accident” and the related paragraph that read, “Significant improvements in the assessment of radiation doses resulting from the human intake of radioactive substances have become available since the adoption of CXG 5”.12
Returning the draft Code of Practice on Cadmium in Foods for further elaboration
CCCF18 agreed to return the draft CoP for further intersessional elaboration with the aim to find a consensus for advancing it at CCCF19. For that purpose, CCCF18 re-established an EWG, led again by the USA, to further develop the CoP, taking into account the discussions held at CCCF18 as well as all the written comments submitted in advanced and raised during the CCCF18 session. That EWG was tasked to refine existing annexes on seaweed and rice and develop new annexes for commodities for which there were specific mitigation measures not covered under general provisions applicable to all foods. To that effect, a circular letter would seek information on general and commodity specific mitigation measures including for cereal and cereal products (e.g., wheat and its derivatives; maize), vegetables (including leafy vegetables), pulses and legumes, and shellfish.
The EWG was also tasked to integrate the existing CoP on the prevention and reduction of cadmium in cocoa beans (CXC 81), possibly as an adapted annex, but only when the general provisions applicable to all foods included in the body of that new CoP would be completed or reaching a near completion stage.
NEW WORK PROPOSALS
Revisions of the existing Code of Practice (CoP) on weed control to prevent and reduce pyrrolizidine alkaloid contamination in food and feed (CXC 74) and its associated Guidance on sampling and analysis performance characteristics for the collection of data to be submitted to the GEMS/food database for pyrrolizidine alkaloids in foods
CCCF18 agreed to start new work on the revision of the Code of practice for weed control to prevent and reduce pyrrolizidine alkaloid contamination in food and feed (CXC 74) by forwarding the project document to the CAC48 for approval as new work.13 CCCF18 agreed to include the Guidance on sampling and its key appendix on performance as part of the CCCF18 report, as a reference point to be used for any future calls for data. CCCF18 agreed to establish a new EWG led by Türkiye, and co-led by the United Kingdom and the Netherlands, to revise the existing CXC 74.
Revision of the existing code of practice for the prevention and reduction of aflatoxin B1 (AB1) in raw materials and supplemental feedingstuffs for milk-producing animals (CXC 45)
CCCF18 agreed to start new work to revise the CoP for the reduction of AB1 in raw materials and supplemental feedingstuffs for milk-producing animals (CXC 45) and forwarded the revised project document to the CAC48 for a formal approval of that new work.14 The goal of such a revision was to refer to new control measures for AB1, particularly concerning forage crops, silage, hay, oilseeds, pulses, and legumes, aiming for applicability across temperate and tropical climates, noting that climate change impacts and the increasing detection of main metabolite of AB1 (i.e., aflatoxin M1) in milk were clearly observable in several African regions. Structural changes to the Code covered new subsections for purpose/scope, definitions, related guidance, general recommendations, and preparation for storage and animal feeding. It was also decided to add cross-references to other relevant Codex texts to avoid any duplication of information. CCCF18 tasked an intersessional EWG, led by Canada and co-led by Saudi Arabia, to develop the revised CoP. A circular letter would be issued for Codex members and Observers to share further risk management best practices, as well as other relevant data and information that could support such a revision.
Development of a new Code of Practice for the prevention and reduction of tropane alkaloids contamination in food and feed.
CCCF18 agreed to start new work on a code of practice for the prevention and reduction of tropane alkaloids in food and feed by forwarding the project document to the CAC48 for a formal approval as a new work.15 CCCF18 tasked a new intersessional EWG, led by China and co-led by Saudi Arabia, to draft this new CoP in taking into account the written comments submitted to CCCF18, comments made at the session, for further consideration and discussion at CCCF19. A circular letter would be issued to request risk management best practices, as well as other relevant data and information to support the development of the CoP. The discussion paper presenting that new work was developed through a past EWG and an inSession Working Group (ISWG) which were also chaired by China and co-chaired by Saudi Arabia.
Application of Maximum Levels to Multi-Ingredient Products and Analysis of Occurrence Data of Lead in Spice Mixtures
CCCF18 agreed to establish a new EWG, led by Japan and co-lead by India, Panama and the USA to prepare a discussion paper exploring options for guidance on the application of MLs to spice mixtures, for further discussion at CCCF19, using information provided in CCCF18 working document (CX/CF 18/25/18) and the CCCF18-CRD27 as a starting point to perform a further data analysis on spices mixtures, while noting the limited support to establish a single ML for lead in spice mixtures, based solely on the JECFA analysis presented at CCCF18. One of the issue discussed was the compatibility of setting a single ML for spice mixtures that would be higher than each individual ML set for each spice present in the mixture with the ALARA principle and good risk management practices (i.e., to avoid already prohibited or, at least, questionable blending practices).
No agreement to move forward with the revision of the existing Code of Practice (CoP) for the reduction of acrylamide in foods (CXC 67)
CCCF18 agreed to further develop and refine the discussion paper and the project document supportive of the revision of the existing CoP for the reduction of acrylamide in foods (CXC 67), as well as the proposed draft revisions foreseen to this code, with the help of an intersessional EWG led by India, co-led by Qatar and Saudi Arabia. The Codex Secretariat was tasked to issue a circular letter to gather more information on mitigation measures that have been proven to be feasible and effective for application for local and/or regional conditions to reduce acrylamide contamination in foods.16
Post-CCCF19 Future Call for Data on the Occurrence of AFT in Cereals
CCCF18 agreed to establish an EWG led by Brazil, co-led by Thailand to prepare a discussion paper for consideration at the after-next CCCF plenary (i.e., at CCCF20). The paper would review all data in the WHO-GEMS/Food database to assess the need for revising existing MLs set in the GSCTFF (CXS 193) for total aflatoxins in cereal grains and cereal-derived products, considering the derivation of new MLs for specific cereals, and evaluate the need for revising the related Codex Code of Practice on the Prevention and Reduction of Mycotoxin Contamination in Cereals (CXC 51, last revised in 2016). CCCF18 discussed issues like a ML for AFT in Sorghum, a possible separate ML for AFT in husked rice, the influence and impacts of agri-climatic conditions and good practices implemented throughout the supply chain; and, the requirements for a forthcoming call for data (the scope of which is to be prepared by Brazil, together with the JECFA secretariat, for future discussion and approval by CCCF19).
Review of Codex Standards for Contaminants (i.e., MLs and associated sampling plan and/or related CoPs) Possibly Requiring an Update
Based on the work from a EWG and VWG, led by Canada, CCCF18 agreed to move several existing standards from the wish-lists A and B to the Overall Highest Priority List (‘OHPL’) on (a) ML of Cadmium in cereal grains; (b) Ochratoxin A in coffee (and its related CoP (CXC 69)); (c) Seven MLs for aflatoxins in various cereals and cereal-based foods; and (d) MLs for Polycyclic aromatic hydrocarbons (PAHs) in smoked and dried foods (and its related CoP (CXC 68)). It also agreed to add new prioritization criteria, rationale and other information to justify entries in the ‘OHPL’ and also track (in a new annex to the OHPL) the various on-going re-evaluations of sampling plans (for alignment with CXG 50, where relevant), and to be part of the annual circular letter. CCCF18 therefore agreed to re-convene a PWG prior to CCCF19, led by Canada, and update the lists based on the comments to be received in response to a new Circular Letter. Last, CCCF18 agreed to establish a new EWG, led by New Zealand and co-led by Canada to review the current ML set for Methylmercury in Tuna (and its associated sampling plan), pending consideration of the overall workload of CCCF19.
OTHER ISSUES DISCUSSED
CCCF18 also discussed other businesses on (a) an update about possible future new work proposal on a guidance on food safety aspects related to the use of recycled plastics in food packaging (USA);17 (b) a proposal for the development of a new Code of Practice for the Prevention and Reduction of Ochratoxin A in Dried Fruits (Türkiye);18 (c) a proposal to identify maximum levels (MLs) in the GSCTFF (CXS 193) that do not have corresponding methods of analysis or numeric performance criteria (NPC) in the standard on methods of analysis and sampling (CXS 234), and the identification of appropriate analytical methods or NPC for these MLs (Brazil);19 (d) the inclusion of the MLs set for marine biotoxins (saxitoxin group, okadaic acid group, domoic acid group, breve-toxin group and azaspiracid group) in Section 1.5 of the Codex Standard for live and raw bivalve molluscs (CXS 292) into CXS 193 (Codex Secretariat);20 and, (e) the outcome of the evaluation of the CCCF activities for the period 2020-2023 (The Netherlands).21
The publication will be posted to World Food Regulation Review soon.