{"id":"F2015L00454","name":"Australia New Zealand Food Standards Code – Schedule 19 – Maximum levels of contaminants and natural toxicants","slug":"australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":93067,"registerId":"commonwealth-F2015L00454-current","compilationNumber":null,"startDate":"2026-04-02","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Australia New Zealand Food Standards Code – Schedule 19 – Maximum levels of contaminants and natural toxicants","content":"Schedule 19 Maximum levels of contaminants and natural toxicants\n\nNote 1 This instrument is a standard under the Food Standards Australia New Zealand Act 1991 (Cth). The standards together make up the Australia New Zealand Food Standards Code. See also section 1.1.1—3.\n\nMaximum levels of contaminants and natural toxicants are regulated by subsection 1.1.1—10(6) and Standard 1.4.1. This Standard lists contaminants and natural toxicants for food for subsection 1.4.1—3(1), and sets out the requirements for and method of calculating the level of mercury in fish for subsection 1.4.1—3(2).\n\nNote 2 The provisions of the Code that apply in New Zealand are incorporated in, or adopted under, the Food Act 2014 (NZ). See also section 1.1.1—3.\n\nS19—1 Name\n\nThis Standard is Australia New Zealand Food Standards Code – Schedule 19 – Maximum levels of contaminants and natural toxicants.\n\nNote Commencement: \nThis Standard commences on 1 March 2016, being the date specified as the commencement date in notices in the Gazette and the New Zealand Gazette under section 92 of the Food Standards Australia New Zealand Act 1991 (Cth). See also section 93 of that Act.\n\nS19—2 Definitions\n\nIn this Schedule:\n\narsenic is taken to be a metal.\n\nergot means the sclerotium or dormant winter form of the fungus Claviceps purpurea.\n\nhoney includes comb honey.\n\nhydrocyanic acid, total means all hydrocyanic acid including hydrocyanic acid evolved from cyanogenic glycosides and cyanohydrins during or following enzyme hydrolysis or acid hydrolysis.\n\nMU means the unit of measurement for neurotoxic shellfish poisons described in Recommended procedures for examination of seawater and shellfish, Irwin N. (ed) fourth edition, American Public Health Association Inc.\n\nready-to-eat cassava chips means the product made from sweet cassava that is represented as ready for immediate consumption with no further preparation required, and includes crisps, crackers and ‘vege’ crackers.\n\nNote In this Code (see section 1.1.2—3):\n\nhoney means the natural sweet substance produced by honey bees from the nectar of blossoms or from secretions of living parts of plants or excretions of plant sucking insects on the living parts of plants, which honey bees collect, transform and combine with specific substances of their own, store and leave in the honey comb to ripen and mature.\n\nS19—3 Calculating levels of contaminants and toxicants\n\n(1) In this Schedule:\n\n(a) a reference to a metal is taken to include a reference to each chemical species of that metal; and\n\n(b) for a food for which only a portion is ordinarily consumed—a reference to the food is taken to be a reference to that portion; and\n\n(c) in the case of seaweed—calculations are to be based on seaweed at 85% hydration; and\n\n(d) subject to subsection S19—7(3), if food other than seaweed is dried, dehydrated or concentrated—calculations are to be based on the food or its ingredients prior to drying, dehydration or concentration.\n\n(2) For paragraph (1)(d), calculations must be based on 1 or more of:\n\n(a) the manufacturer’s analysis of the food; or\n\n(b) the actual amount or \\*average quantity of water in the ingredients of the food; or\n\n(c) generally accepted data.\n\nS19—4 Maximum levels of metal contaminants\n\nNote For mean levels of mercury in fish, crustacea and molluscs, see section S19—7.\n\nFor each metal contaminant listed below, the maximum level (in mg/kg) for a particular food is listed in relation to that food:\n\nMaximum levels of metal contaminants\n\n```html\n

Contaminant

Food

Maximum level

Aluminium

Infant formula, follow-on formula and special medical purpose product for infants (other than special medical purpose product for infants formulated for pre-term infants)

0.5

Soy-based infant formula products

1

Special medical purpose product for infants formulated for pre-term infants

0.2

Arsenic (total)

Cereal grains and milled cereal products (as specified in Schedule 22 - except sweet corns)

1

Salt

0.5

Arsenic (inorganic)

Crustacea

2

Fish

2

Molluscs

1

Seaweed

1

Cadmium

Amaranth, grain

0.1

Chinese cabbage (Pe-tsai)

0.1

Chocolate and cocoa products

0.5

Kidney of cattle, sheep and pig

2.5

Leafy vegetables (as specified in Schedule 22)

0.1

Liver of cattle, sheep and pig

1.25

Meat of cattle, sheep and pig (excluding offal)

0.05

Molluscs (excluding dredge/bluff oysters and queen scallops)

2

Peanuts

0.5

Rice

0.1

Root and tuber vegetables (as specified in Schedule 22)

0.1

Salt

0.5

Wheat

0.1

Lead

Brassicas

0.3

Cereals (except sweet corns), pulses and legumes

0.2

Edible offal of cattle, sheep, pig and poultry

0.5

Fish

0.5

Fruit

0.1

Infant formula products

0.01

Meat of cattle, sheep, pig and poultry (excluding offal)

0.1

Molluscs

2

Salt

2

Sweet corns

0.1

Vegetables (except brassicas)

0.1

Mercury

Fish, crustacea and molluscs

See S19—7

Salt

0.1

Tin

All canned foods

250

\n```\n\nS19—5 Maximum levels of non-metal contaminants\n\nFor each non-metal contaminant listed below, the maximum level (in mg/kg unless specified otherwise) for a particular food is listed in relation to that food:\n\nMaximum levels of non-metal contaminants\n\n```html\n

Contaminant

Food

Maximum level

Acrylonitrile

All food

0.02

Aflatoxin

Peanuts

0.015

Tree nuts (as specified in Schedule 22)

0.015

Amnesic shellfish poisons (Domoic acid equivalent)

Bivalve molluscs

20

3-chloro-1,2-propanediol

Soy sauce and oyster sauce

0.2
calculated on a 40% dry matter content

Diarrhetic shellfish poisons (Okadaic acid equivalent)

Bivalve molluscs

0.16

1,3-dichloro-2-propanol

Soy sauce and oyster sauce

0.005
calculated on a 40% dry matter content

Ergot

Cereal grains

500

Methanol

Red wine, white wine and fortified wine

3 g methanol / L of ethanol

Whisky, rum, gin and vodka

0.4 g methanol / L of ethanol

Other spirits, fruit wine, vegetable wine and mead

8 g methanol / L of ethanol

Neurotoxic shellfish poisons

Bivalve molluscs

200 MU/kg

Paralytic shellfish poisons (Saxitoxin dihydrochloride equivalent)

Bivalve molluscs

0.8

Phomopsins

Lupin seeds and the products of lupin seeds

0.005

Polychlorinated biphenyls, total

Mammalian fat

0.2

Poultry fat

0.2

Milk and milk products

0.2

Eggs

0.2

Fish

0.5

Vinyl chloride

All food except packaged water

0.01

\n```\n\nS19—6 Maximum levels of natural toxicants\n\n(1) For each natural toxicant listed below, the maximum level (in mg/kg) for a particular food is listed in relation to that food:\n\nMaximum levels of natural toxicants\n\n| Natural toxicant | Food | Maximum level |\n| ------------------------- | ------------------------------------------------------------------ | ------------- |\n| Agaric acid | Food containing mushrooms | 100 |\n| | Alcoholic beverages | 100 |\n| Aloin | Alcoholic beverages | 50 |\n| Berberine | Alcoholic beverages | 10 |\n| Coumarin | Alcoholic beverages | 10 |\n| Hypericine | Alcoholic beverages | 2 |\n| Lupin alkaloids | Lupin flour, lupin kernel flour, lupin kernel meal and lupin hulls | 200 |\n| Pulegone | Confectionery | 350 |\n| | Beverages | 250 |\n| Quassine | Alcoholic beverages | 50 |\n| Quinine | Mixed alcoholic drinks not elsewhere classified | 300 |\n| | Tonic drinks, bitter drinks and quinine drinks | 100 |\n| | Wine based drinks and reduced alcohol wines | 300 |\n| Safrole | Food containing mace and nutmeg | 15 |\n| | Meat products | 10 |\n| | Alcoholic beverages | 5 |\n| Santonin | Alcoholic beverages | 1 |\n| Sparteine | Alcoholic beverages | 5 |\n| Thujones (alpha and beta) | Sage stuffing | 250 |\n| | Bitters | 35 |\n| | Sage flavoured foods | 25 |\n| | Alcoholic beverages | 10 |\n\n(2) For each natural toxicant listed below, the maximum level (in mg/kg) for a particular food is listed in relation to that food:\n\nMaximum levels of natural toxicants\n\n| Natural toxicant | Food | Maximum level |\n| ----------------------- | -------------------------- | --------------------------- |\n| Erucic acid | Edible oils | 20 000 |\n| Histamine | Fish and fish products | 200 |\n| Hydrocyanic acid, total | Confectionery | 25 |\n| | Stone fruit juices | 5 |\n| | Marzipan | 50 |\n| | Ready-to-eat cassava chips | 10 |\n| | Alcoholic beverages | 1 mg per 1% alcohol content |\n| Tutin | Honey | 0.7 |\n\nNote The New Zealand Food (Tutin in Honey) Standard 2010 also regulates beekeepers, packers and exporters of honey in New Zealand. It provides options for demonstrating compliance with the maximum level for tutin in honey set by section 1.4.1—3.\n\nS19—7 Mean and maximum levels of mercury in fish, crustacea and molluscs\n\n(1) For subsection 1.4.1—3(2), the following table applies:\n\n```html\n

For:

if:

the mean level of mercury in sample units must be no greater than:

the maximum level of mercury in any sample unit must be no greater than:

gemfish, billfish (including marlin), southern bluefin tuna, barramundi, ling, orange roughy, rays and all species of shark;

(a) both of the following are satisfied:

(i) 10 or more sample units are available;

(ii) the concentration of mercury in any sample unit is greater than 1.0 mg/kg:

1.0 mg/kg

1.5 mg/kg

(b) 5 sample units are available:

1.0 mg/kg

(no level set)

(c) there are insufficient samples to analyse in accordance with subsection S19—7(2):

1.0 mg/kg

other fish, fish products, crustacea and molluscs;

(a) both of the following are satisfied:

(i) 10 or more sample units are available;

(ii) the concentration of mercury in any sample unit is greater than 1.0 mg/kg:

0.5 mg/kg

1.5 mg/kg

(b) 5 sample units are available:

0.5 mg/kg

(no level set)

(c) there are insufficient samples to analyse in accordance with subsection S19—7(2):

1.0 mg/kg

\n```\n\n(2) For the table in subsection (1), calculations must be done on the basis of the following number of sample units:\n\n(a) for fish other than crustacea or molluscs:\n\n (i) for a \\*lot of not more than 5 tonnes—10;\n (ii) for a lot of more than 5 but not more than 10 tonnes—15;\n (iii) for a lot of more than 10 but not more than 30 tonnes—20;\n (iv) for a lot of more than 30 but not more than 100 tonnes—25;\n (v) for a lot of more than 100 but not more than 200 tonnes—30;\n (vi) for a lot of more than 200 tonnes—40;\n\n(b) for crustacea and molluscs:\n\n (i) for a lot of not more than 1 tonne—10;\n (ii) for a lot of more than 1 but not more than 5 tonnes—15;\n (iii) for a lot of more than 5 but not more than 30 tonnes—20;\n (iv) for a lot of more than 30 but not more than 100 tonnes—25;\n (v) for a lot of more than 100 tonnes—30;\n\n(c) if the number of sampling units specified in paragraph (a) or (b) is not available—5.\n\n(3) In this section, the mercury content of dried or partially dried fish must be calculated on an 80% moisture basis.\n\nDefinition of sample unit\n\n(4) In this section:\n\nsample unit means a sample:\n\n(a) that has been randomly selected from the \\*lot being analysed; and\n\n(b) that has been taken from the edible portion of a fish, mollusc or crustacean, whether packaged or otherwise; and\n\n(c) that is sufficient for the purposes of analysis.\n\n(5) Each sample unit must be taken from a separate fish, mollusc, crustacean or package of fish product.\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n \n\nApplication, saving and transitional provisions\n\nThe table below details information on application, saving or transitional provisions in instruments affecting this Standard.\n\n```html\n

Instrument items affected

A’ment No.

FRLI registration

Gazette

Instrument’s transitional provision

Description of transitional arrangement

Food Standards (Proposal P1028 – Infant Formula Products – Consequential Amendments) Variation

Items [22] and [23] of Schedule 2

231

F2024L01151

13 Sept 2024

FSC 171

13 Sept 2024

Clause 4

Clause 4 establishes a transitional arrangement for variations to the Code made by Items [22] and [23] of Schedule 3 and by the Food Standards (Proposal P1028 – Infant Formula Products – Consequential Amendments) Variation.

The transition period is the period of time that commences on 13 September 2024 and ends on 13 September 2029.

Subclause 4(1) provides that section 1.1.1—9 of the Code does not apply to the variations.

Subclause 4(2) provides that during the transition period a food product may be sold if the product complies with one of the following:

(a) the Code as in force without the above variations;

(b) the Code as amended by the above variations.

Subclause 4(3) provides that a food product that was labelled before the end of the transition period may be sold after the transition period if the product complies with one of the following:

(a) the Code as in force without the above variations;

(b) the Code as amended by the above variations.

\n```\n\nAmendment History\n\nThe Amendment History provides information about each amendment to the Schedule. The information includes commencement or cessation information for relevant amendments.\n\nThese amendments are made under section 92 of the Food Standards Australia New Zealand Act 1991 unless otherwise indicated. Amendments do not have a specific date for cessation unless indicated as such.\n\nAbout this compilation\n\nThis is compilation No. 6 of Schedule 19 as in force on 13 September 2024 (up to Amendment No. 231). It includes any commenced amendment affecting the compilation to that date.\n\nPrepared by Food Standards Australia New Zealand on 13 September 2024.\n\nUncommenced amendments or provisions ceasing to have effect\n\nTo assist stakeholders, the effect of any uncommenced amendments or provisions which will cease to have effect, may be reflected in the Schedule as shaded boxed text with the relevant commencement or cessation date. These amendments will be reflected in a compilation registered on the Federal Register of Legislation including or omitting those amendments and provided in the Amendment History once the date is passed.\n\n \n\nThe following abbreviations may be used in the table below:\n\nad = added or inserted am = amended\n\nexp = expired or ceased to have effect rep = repealed\n\nrs = repealed and substituted\n\nSchedule 19 was published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00454 –- 1 April 2015) and has since been amended as follows:\n\n| Section affected | A’ment No. | FRL registrationGazette | Commencement(Cessation) | How affected | Description of amendment |\n| ----------------- | ---------- | ----------------------------------------------- | ----------------------- | ------------ | ----------------------------------------------------------------------------------------------------------------------------- |\n| S19—2 | 157 | F2015L013741 Sept 2015FSC993 Sept 2015 | 1 March 2016 | ad | Definition of ‘honey’ and related Note previously included in the Code as part of P1029. |\n| table to S19—6(2) | 157 | F2015L013741 Sept 2015FSC993 Sept 2015 | 1 March 2016 | ad | Entry for tutin and related Note previously included in the Code as part of P1029. |\n| S19—7(2) | 168 | F2017L0041411 April 2017FSC11013 April 2017 | 13 April 2017 | am | Correction of typographical error. |\n| S19—7(2)(c) | 200 | F2021L006842 June 2021FSC1413 June 2021 | 3 June 2021 | am | Correction of typographical error. |\n| S19—4 | 211 | F2022L0111826 Aug 2022FSC1511 Sept 2022 | 1 September 2022 | am | Entry for Cadmium |\n| S19—4 | 211 | F2022L0111826 Aug 2022FSC1511 Sept 2022 | 1 September 2022 | am | Entry for Lead |\n| S19—5 | 225 | F2024L0008018 January 2024FSC16519 January 2024 | 19 January 2024 | rs | Repeal and substitute table items, Diarrhetic shellfish poisons - maximum level and paralytic shellfish poison – contaminant. |\n| S19—4 | 231 | F2024L0115113 Sept 2024FSC17113 Sept 2024 | 13 September 2024 | ad | Insert entry for aluminium into S19—4 table. |\n| S19—4 | 231 | F2024L0115113 Sept 2024FSC17113 Sept 2024 | 13 September 2024 | rs | Repeal the maximum level of lead in infant formula products (0.01) and substitute 0.02 |","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"kimi_summary":{"content_quality":"ok","complexity_score":6,"scope_assessment":{"changed":false,"description":"The legislation appears to maintain its original scope as a technical schedule setting maximum levels for contaminants and natural toxicants. While it has been amended multiple times (6 compilations since 2016) to add new contaminants (aluminium in infant formula) and adjust existing limits (lead in infant formula, cadmium in various foods), these changes represent updates to the regulatory framework rather than scope creep. The core purpose—establishing maximum permissible levels for food safety—remains consistent."},"complexity_factors":["Extensive cross-referencing to other schedules (Schedule 22 for food definitions, Standard 1.4.1 for general contaminant rules)","Multiple calculation methods required for different food states (dried vs fresh, 85% hydration for seaweed, 80% moisture for dried fish)","Complex sampling protocols for mercury in fish with tiered requirements based on lot size (ranging from 5 to 40 sample units)","Dual calculation standards for mercury (mean levels vs maximum levels in individual samples) with different thresholds for different fish species","Nested conditional logic in S19-7 with three different compliance pathways depending on sample availability","Special definitions required for technical terms (ergot, MU for shellfish poisons, 'total' hydrocyanic acid)","Transitional provisions with specific dates and dual compliance periods for recent amendments","Multiple measurement units (mg/kg, g/L, MU/kg) requiring careful attention to context"],"plain_english_summary":"This standard sets legal maximums for metal, non‑metal and naturally occurring toxicants in foods sold in Australia and New Zealand, with specific limits for items like infant formula, seafood, nuts, shellfish and honey. It binds food businesses, importers, primary producers and regulators to reduce exposure from pollution, processing or natural sources. By capping hazardous substances, it protects public health across both countries as part of the Food Standards Code."},"flash_summary":{"complexity_score":7,"scope_assessment":{"changed":false,"description":"The Schedule remains focused on its original legislative purpose: setting maximum levels of contaminants and natural toxicants in food and specifying how those levels are to be calculated and sampled. Recent variations reflected in the compilation (for example insertion of an aluminium maximum for infant formula and a change to the lead maximum for infant formula, plus transitional arrangements for an infant‑formula variation) are updates within that existing regulatory scope rather than an expansion beyond the Schedule’s original objective. These are substantive updates to the numeric limits and compliance timing but do not change the fundamental scope (S19—4; Application, saving and transitional provisions)."},"complexity_factors":["Multiple tabulated contaminant/food combinations across three distinct tables (metals, non‑metals, natural toxicants) — dozens of entries to interpret and apply","Defined terms and special measurement rules in S19—2 and S19—3 that affect calculation (seaweed hydration 85%, dried foods measured pre‑drying except where specified, 80% moisture basis for dried fish)","Detailed, conditional sampling regime for mercury (S19—7) with multiple lot‑size bands and differing sample unit counts (10–40 for fish; 10–30 for crustacea/molluscs)","Nested conditional logic for mercury mean vs maximum levels depending on species groupings, number of samples available and concentration thresholds (S19—7(1) clauses (a)–(c))","Cross‑references to other parts of the Code and to external procedural standards (e.g. MU unit reference, Schedule 22 food lists, and subsections 1.1.1—10(6) and 1.4.1)","Multiple non‑standard measurement bases to apply (mg/kg, MU/kg, mg per % alcohol, g methanol/L ethanol, 40% dry matter basis) requiring calculation steps","Transitional arrangements and amendment history woven into the Schedule (multiple amendments cited, and a 5‑year transition window for specific infant formula amendments)","Enforcement implications: reliance on laboratory analysis and random sampling increases administrative and technical complexity for businesses and regulators"],"plain_english_summary":"**What this instrument does (mechanics)**\n\n- Schedule 19 sets maximum allowed levels of contaminants (metals and non-metals) and certain naturally occurring toxicants in foods for the Australia New Zealand Food Standards Code. It is a numerical, product-by-product limit list (mg/kg or other units) that food businesses must meet (S19—4, S19—5, S19—6).\n\n- It provides a small set of definitions that affect measurement and scope (for example: how “honey”, “arsenic”, “hydrocyanic acid, total” and “ready-to-eat cassava chips” are treated) and rules for how concentrations must be calculated in specific circumstances (drying, seaweed hydration, portion consumed) (S19—2, S19—3).\n\n- It lists separate tables of limits:\n - Maximum levels for metal contaminants by food (aluminium, arsenic, cadmium, lead, mercury, tin, etc.) (S19—4).\n - Maximum levels for non-metal contaminants by food (aflatoxin, shellfish biotoxins, methanol in alcoholic drinks, vinyl chloride, polychlorinated biphenyls, etc.) (S19—5).\n - Maximum levels for natural toxicants (e.g. lupin alkaloids, hydrocyanic acid, tutin in honey, erucic acid, histamine, thujones) (S19—6).\n\n- There are special, prescriptive rules for measuring mercury in fish, crustacea and molluscs: how many sample units to take depending on lot size, how to treat dried fish (80% moisture basis), and different mean/maximum cut‑offs for certain high‑mercury species versus other fish (S19—7(1)–(5)).\n\n- Where a food is dried, concentrated or dehydrated, concentrations are generally to be calculated on the food prior to drying unless seaweed (which is measured at 85% hydration) (S19—3(1)(c)–(d), S19—3(2)).\n\n- The Schedule incorporates transitional arrangements and records amendment history (for example, a transition period that allows products to comply with either the old or new rules for a fixed period following specified variations) (Application, saving and transitional provisions).\n\n**Who this affects**\n\n- Food manufacturers, processors and packers who produce any foods listed in the tables (infant formula manufacturers, seafood and fish processors, shellfish harvesters, honey producers, alcoholic beverage producers, cereal/seed handlers, etc.) — these businesses must ensure products meet the numeric limits and the calculation rules (S19—4 to S19—7).\n\n- Importers and exporters: imported foods must meet these Code limits to be sold or labelled for sale in Australia and New Zealand; exporters relying on specified sampling regimes (e.g. for mercury) must follow the sampling rules when demonstrating compliance (S19—7).\n\n- Regulators and testing laboratories: state, territory and New Zealand enforcement authorities apply these limits and accredited labs will be asked to test to show compliance (note: the Code is applied/ adopted under domestic food laws) (Note 2).\n\n- Consumers indirectly: the numerical limits determine whether certain products can be sold; limits for infant formula and specific seafood species are particularly relevant to infants and high‑consumption seafood consumers (S19—4, S19—7).\n\n**Why it matters (purpose claims and practical effects)**\n\n- The stated purpose of the Schedule is to reduce exposure to harmful chemicals and natural toxicants in the food supply by setting upper limits for specific food/contaminant combinations (front matter and tables S19—4 to S19—6).\n\n- Mechanically, the law forces businesses to test, reformulate, change ingredients or reject raw materials that exceed the limits. It creates enforceable ceilings that food safety authorities can use to refuse sale, require product removal, or take compliance action (entire Schedule).\n\n**Costs, incentives and trade-offs**\n\n- Who pays: testing, sampling, compliance testing and any reformulation or raw‑material substitution costs fall on the food business or supplier. For fisheries and large lots, the mercury sampling regime (S19—7(2)) requires dozens of sample units depending on lot size, which raises direct testing costs and logistical burden for fish harvesters, processors and exporters.\n\n- Incentives: stricter numerical limits create an incentive for suppliers to source lower‑contaminant raw materials, to process to remove contaminants, or to avoid particular species/ingredients. For infant formula manufacturers, the addition of aluminium limits and the amendment to the lead limit directly affect formulations and ingredient sourcing (S19—4; Application/transitional provisions).\n\n- Trade and competition: exporters/importers must meet these limits for access to the Australian/New Zealand market; firms already operating with lower contaminant levels face lower incremental compliance costs, so the burden is concentrated on suppliers with higher contaminant inputs. Where testing or analytical methods are expensive or variable, smaller businesses may face proportionally higher compliance costs.\n\n- Compliance burden and bureaucracy: the Schedule creates prescriptive sampling and calculation rules (S19—3, S19—7) that require record‑keeping, validated analytical methods and possible use of accredited laboratories. Regulators must interpret and enforce the numerical thresholds; there is reliance on laboratory comparability and sampling randomness.\n\n- Implementation risk and measurement error: for contaminants present at low levels or near detection limits, lab variability and sample heterogeneity (e.g. mercury concentrations vary by fish size/age) can make compliance determinations uncertain. The Schedule reduces some uncertainty by specifying sample sizes and calculation bases (S19—7), but analytical variability remains an enforcement and commercial risk.\n\n**Concrete behavioural changes the Schedule drives**\n\n- Seafood businesses will apply the mercury sampling scheme and may segregate lots by species, size or provenance to manage compliance risk (S19—7).\n\n- Infant formula and other infant food manufacturers will adjust ingredient sourcing and quality control to meet metal limits (e.g. aluminium, lead) and may rely on the transitional arrangements while reformulation or stock turnover occurs (S19—4; Application/transitional provisions).\n\n- Producers of honey, lupin products, alcoholic beverages and processed foods will monitor specified natural toxicants (tutin, lupin alkaloids, thujones, methanol) and change recipes, processing steps or raw materials if levels approach limits (S19—6, S19—5).\n\n**Notes on legal mechanics and cross‑jurisdictional application**\n\n- The Standard is part of the Food Standards Code and is applied in New Zealand by incorporation or adoption under their Food Act (Note 2).\n\n- Some limits are expressed on special bases (e.g. methanol per litre ethanol for wines and spirits; soy sauce limits calculated on a 40% dry matter content; neurotoxic shellfish poison measured in MU units) and require specific calculation steps (S19—5).\n\n- The Schedule records amendment history and contains transitional arrangements for recent amendments (for example a transition period allowing products to comply with either the old or new Code for a fixed time following the infant formula-related variation) (Application, saving and transitional provisions).\n\n**Key sections to refer to when applying these rules**\n- Definitions and special measurement rules: S19—2, S19—3.\n- Metal contaminant table: S19—4.\n- Non‑metal contaminant table: S19—5.\n- Natural toxicants table: S19—6.\n- Mercury sampling, mean and maximum rules for seafood: S19—7.\n\n(References in parentheses are to the Schedule’s section numbers.)"}},"importantCases":[],"_links":{"self":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox","history":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox/history","analysis":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox/analysis","conflicts":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox/conflicts","importantCases":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox/important-cases","documents":"/api/acts/australia-new-zealand-food-standards-code-schedule-19-maximum-levels-of-contaminants-and-natural-tox/documents"}}