Statement from the Alter Eco Leadership Team

The topic of heavy metals in chocolate is a complex one, and over the years different press coverage has caused further confusion amongst many consumers, regulatory agencies, and other industry stakeholders.

We at Alter Eco Foods have a great sense of pride in not only our mission and products that help regenerate the land and empower farmers, but also our consumers. Our team, in addition to our global supply chain partners, remain fully committed to ensuring safety, quality and regulatory compliance for all products.

Alter Eco recognizes that heavy metals (such as cadmium) are naturally occurring elements in the earth’s soil, which can be absorbed through the roots in fruits, legumes, grains, leafy vegetables, and trees. We employ good agricultural practices and good manufacturing practices to ensure that no heavy metals are introduced into our products from human activity at any point in our production process. Any trace levels of cadmium in our chocolate products are naturally occurring, from the absorption of the heavy metal present in tropical soils via the roots of cacao trees and deposited into the center of cacao beans.

We are aware and continue to remain compliant to all safety, legal and regulatory requirements applicable to our products. Regarding heavy metals, there is currently no nationwide FDA limit for chocolate. In the absence of this regulation, many over the years have turned to California’s Proposition 65 law, which sets Maximum Allowable Dose Levels (MADLs) for heavy metals. This law does provide an exemption for food containing naturally occurring elements including heavy metals in soil where the food is grown. See Cal. Code Regs, tit. 27, § 25501. Any trace levels of heavy metals detectable in our products are naturally occurring as previously mentioned.

Additionally, in 2018 a California Proposition 65 Consent Judgment was entered into by the chocolate industry, which established clear limits to follow for cadmium and lead (based on cacao %) when selling chocolate products in California. See As You Sow v. Trader Joe’s Company et. al., San Francisco Superior Court Case No. CGC-15-548791. All Alter Eco chocolate is compliant to the heavy metal limits set forth in this Consent Judgment. Dark chocolate with 65-95% cacao has a cadmium limit of 0.45 parts per million (ppm) per the Consent Judgment. For chocolate with greater than 95% cacao, such as our Total Blackout bar, the cadmium limit is higher at 0.96 ppm. Confusion from media coverage often results from testing and reporting heavy metal values in different units than ppm, such as micrograms (ug) per serving size, so it is important to do the unit conversions first.

Alter Eco and our supply chain work very hard to adhere to current laws, and we remain proactive in reducing naturally occurring heavy metals even further to the lowest levels currently feasible. In early 2024, we did another reformulation of the cacao blend for our dark chocolate products to include more cacao beans from the Dominican Republic, a region known to have lower heavy metal content in the soil. We also have a heavy metal testing program in place for both cacao beans and finished chocolate with our production partners. These steps allow us to continue delivering safe and clean products to you while staying true to our mission.

As always, we thank you for your continued support and we hope you find this information helpful.

Regeneratively,

Alter Eco Leadership Team