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For those new to this website:

Tamara Rubin is a multiple-federal-award-winning independent advocate for childhood Lead poisoning prevention and consumer goods safety, and a documentary filmmaker. She is also a mother of Lead-poisoned children (two of her sons were acutely Lead-poisoned in 2005). Since 2009, Tamara has been using XRF technology (a scientific method used by the U.S. Consumer Product Safety Commission) to test consumer goods for toxicants (specifically heavy metals — including Lead, Cadmium, Mercury, Antimony, and Arsenic). Tamara’s work was featured in Consumer Reports Magazine in February 2023 (March 2023 print edition).

This is an ad-free article.

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Originally written in December of 2013 (updated November of 2021, but all these years later, still almost nothing has changed since then)!

I first learned of the concern for Lead in chocolate shortly after my children were poisoned — when the Dagoba organic dark chocolate Lead-contamination recall happened in April 2006. This recall happened just 6 months after I found out about my boys’ poisoning, and — as a result — I was definitely paying attention to all the news about Lead at the time! Here are some links about that, if you hadn’t heard about this before and you want to read more: link one, two, and link three.

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Lead-in-chocolate shedding light on ALL manufacturing…

This incident had such a profound impact on my understanding of the complexity, depth, and breadth of Lead contamination in our lives — especially given Dagoba was a local (Ashland, Oregon-based) company that manufactured expensive, ostensibly high-quality Organic products that were available every day in my neighborhood natural foods grocery store.

Learning the story of how Lead got into my chocolate (and how chocolate was virtually unregulated at the time) shaped my understanding of Lead contamination in manufactured food products — and marked the beginning of my exploration into the issue of Lead in manufactured goods in general.

This issue was so important (and is such a personal concern to so many other parents, and women especially) that I decided to include a scene about it in my documentary film, MisLEAD: America’s Secret Epidemic; I felt others would find the story of Lead in chocolate equally fascinating — a cautionary tale, shedding light on who we trust (when it comes to feeding, housing, and clothing our families) and why we trust them, or what we can expect (vs. what we should expect) from the companies whose products we allow into our lives and our bodies.

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Corporate Responsibility?

In one of my favorite scenes in the film, my friend Ronnie (a scientist) talks about Lead in chocolate and wine:

“The really bad news is, chocolate is the food item with the most Lead in it!” says Ronnie Levin (research scientist, Harvard professor and retired EPA employee), in MisLEAD: America’s Secret Epidemic.

In the film, Levin goes on to explain that when one industry — the California wine industry — was faced with a challenge by the State of California to either remove the Lead from their wine or to label their product as “toxic,” they were able to quickly mobilize and take the necessary actions to bring the Lead-levels in California wine down by 300 parts per billion (quite a lot for a food item — Lead in food and beverages is measured in parts per billion (ppb), with water considered toxic at levels as low as 1 ppb).

The intention behind the scene in my film is not to single out or demonize chocolate (or wine), but to let the comparative stories of Lead-in-chocolate and Lead-in-wine — stories highlighting the different regulatory standards (or complete lack thereof) in separate segments of the food industry — serve as an example for other industries (an example of the importance and potential impact of consumer demand for corporate accountability when it comes to the presence of toxicants in products, including food).

Unfortunately, no public agency (not even the FDA, the CDC or the EPA) has ever challenged the candy or chocolate industry as a whole with a similar challenge to that demanded of the California wine industry (when this was originally written, as of 12/2013) and chocolate and candy are not well-regulated for toxicants (nor are they even regularly tested by independent agencies) in the same way some other products are.*

This issue is compounded by the fact that chocolate is a highly processed food — and so Lead has the potential to get added as a trace contaminant of the manufacturing process to chocolate, as well as to each of its ingredients separately, at the many stages and steps along the way…

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How does Lead (& Cadmium) end up in Chocolate?

1. Leaded gasoline is still used in many of the countries where chocolate ingredients are grown (and in fact, when specifically used in farm vehicles, Leaded gasoline is often exempt from laws restricting its use — even in countries where it is otherwise prohibited)!
2. The husk of the cocoa bean has been shown to be a very effective “tool” in terms of its ability to absorb Lead (it’s absorbent, like a sponge) from polluted air and soil (from continuous emissions and deposits of Leaded exhaust and deteriorating Lead paint from tractors and other vehicles, and generators and other equipment, Lead-painted machinery and buildings, etc.).
3. Transport packaging (industry reusable, labeled canvas bags, cartons, and crates) may be painted or treated with Lead and Cadmium-containing coatings (there is nothing regulating that).
4. Shipping containers (the ones the size of train cars) and container-ships used for international transport may be legally painted with Lead-based paint, and also often with red or orange Cadmium-based pigments. Even in the U.S., what is historically known as “Lead paint,” from a regulatory standpoint, has only been fully outlawed for “residential use” and is 100% legal for industrial uses.  (I actually — recently (in California in 2019) — tested a fairly-new shipping container that was being used for storage in the driveway of the home of a Lead-poisoned child. The paint was positive for Lead with readings in the 7,000 to 10,000 ppm range.)
5. Equipment and machines for grinding and processing food (at every step of the process) may have both Leaded components that, as they wear, cause traces of Lead to be mixed into the food product that they are processing AND Cadmium-plated components (with the Cadmium-plating used on metal machine components to help prevent corrosion from moisture).
6. Not every batch of imported food ingredient (cocoa beans, sugar, cocoa butter, etc.) is tested for toxicants (only random, spot testing is done by manufacturers who voluntarily opt to watch for this sort of thing).

Simply put, as a general rule, the more processed a chocolate item is, the more Lead (and Cadmium) it has in it.

So, Tamara — what do you do? Do you eat chocolate?

1. I personally ALWAYS avoid transnational conglomerate brands (like Nestle’s or Hershey’s).
2. I try to stick with Organic and local, small-batch manufacturers (and as you can see from the above-referenced Dagoba recall, even buying organic and local doesn’t necessarily solve the problem)!
3. I buy minimally-processed ingredients — like raw Cacao (you can read more about that here) and often make my own chocolate treats.
4. My main defense: I limit my consumption of processed chocolate bars and stick with Organic cacao or cocoa powder and roasted cocoa nibs, from local companies that I trust (a shout out to People’s Coop, here in Portland!).

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What about “Fair-Trade Certified” Organic chocolate products?

One thing I have personally chosen to avoid (based solely on my own theoretical musings, not on any particular study I have read): Chocolate processed in developing countries are often marketed as “Fair-Trade Certifed”** as an economic stimulus activity to support local farmers, etc. This type of marketing and labeling on products actually raises quite a few alarm bells for me.

The main reason I avoid these products is because of what the phrases like “Fair Trade Certified” and “Small Family Farms” can imply (correlate to) — in a manufacturing context. Commonly, the processing equipment in these countries (on “Fair Trade-Certified” small family farms) is less likely to be modern, high-tech stainless steel, contaminant-free, state-of-the-art equipment; work-flows and supply chains at this level are also typically not necessarily reflective of best practices for the stringent avoidance of (and measurement/monitoring of) toxicants-contamination.

Small family farms in really anywhere other than Europe and the United States are much more likely to use “legacy” equipment that has one or more of the following characteristics:

• it is older (often antiquated and with well worn components and coatings)
• it is made of recycled components (sometimes from equipment not intended for food processing applications)
• it is re-furbished
• it is re-purposed
• or it is re-used
• it is painted with industrial Lead-based paint
• it is coated with Cadmium-based plating to avoid corrosion 
• it integrates many Leaded brass components (often in contact with or in close proximity to the food), brass which can also contain Cadmium, Antimony, Arsenic and other toxic metals

And all this (usually) is pitched/spun by marketing departments and sales teams as something positive, with the related messaging including emotionally-alluring narratives that this legacy (toxic) equipment and workflow is somehow beneficial — contributing to the positive “sustainable” qualities of that particular farm.

Don’t get me wrong — in general, I am very pro-sustainability (I started working with pioneers in the sustainability movement on various projects back in 1991/1992, before it was an overused phrase appearing in ad-copy for almost anything that can be sold). However, when it comes to food processing, it’s just a fact: Older equipment is more likely to have components made of Lead or Leaded brass or painted with high-Lead or high-Cadmium content paint or with Cadmium plating (which is not outlawed in many of these countries where cocoa is grown).

Why do they use Leaded brass in these machines?

Leaded brass components are actually still intentionally used in many types of processing equipment and in machines used every day across countless industries (including here in the United States where we ostensibly have better regulatory standards) — due to the “easy machinability” and the “self-lubricating” properties of “red” (i.e. Leaded) brass (these components make it possible for moving parts to actually move)!

“Self-lubrication” is a well-known quality of brass that makes the machine movements function better and inexpensively maintain working tolerances over time. Yet inherent in the benefit of using brass in moving components is how this function (the ease with which brass components move in a machine) is also what causes them to wear more quickly than components made of other, harder metals (in fact “sacrificial” is the technical industry term to describe these replaceable brass parts — often used at points of high friction and rapid wear).

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Why is Leaded brass a problem in machines used for food processing?

In food processing equipment where does the part that wears off of those components (the paint or the brass) go over years of use?

• The worn bits (the invisible particulates that come off with use of the machine) often wear right into the food manufactured or processed by that machine.
• The more processed a food is (the more machines it goes through) — especially noting the degree to which cocoa products may be heavily processed outside of the U.S. — the more likely it is for that product to have Lead added to it at every step along the way.
• Chocolate is one of the most heavily-processed foods.

Remember, it just takes a literally microscopic amount of Lead to poison a child, and Lead-poisoning causes permanent brain damage, learning disabilities, behavioral disorders, and life-long health challenges.

Some additional reading/ examples to illustrate the concerns mentioned in this article:

While I don’t have a lot of examples here on this website for machines I have tested, there is one such example in the links below. I have also linked several examples of brass objects with varying levels of contaminants to illustrate the concern. Another category of articles here that might be helpful in showing the level of potential contamination from equipment and machinery is the “tools” category. Here’s a link to that entire category to explore — many of these tools were found in my husband’s workshop and are either painted with Lead paint or have other types of heavy metal contamination.

• Here’s an example of high-Lead brass with Antimony — link
• Here’s an example of modern brass with Cadmium, Lead, and Antimony — link
• Here’s an example of modern brass with extremely high levels of Cadmium (plus Antimony and Lead) — link
• Here’s an example of a modern machine (in my husband’s workshop) that has many brass components positive for a high level of Lead (and also Cadmium) — link
• This article discusses the concern for Lead in processed baby food (and also has a picture of a coffee roasting machine, showing painted and brass components) — link

While the tiny amount of Lead in one particular chocolate bar might not be especially concerning in itself, it is our aggregate cumulative body burden of environmental toxicants (specifically heavy metals — like Lead, Cadmium, Arsenic, Mercury, and Antimony) that we do need to keep an eye on. And it is that aggregate cumulative exposure that is causing (or contributing to) long-term health impacts like heart disease, kidney disease, osteoporosis, accelerated cognitive decline/ early-onset Alzheimer’s, and more. The only way to keep an eye on this sort of thing as consumers is to be aware of what we are putting into our bodies.

Thanks for reading.

If you appreciate my work and the information we share, please consider making even a small monthly contribution via our “subscribe” link, to help Lead Safe Mama, LLC be able to continue helping other families by protecting their children from Lead in their homes, schools, and environment.

As always, please let me know if you have any questions.

Sincerely,

Tamara Rubin
#LeadSafeMama

*New European standards and limits for Cadmium in chocolate were implemented just recently, in 2015. Chocolate manufacturers were given four years to comply (with full compliance required no later than January 1, 2019). Link with more information.

**Note — I also appreciate genuine “Fair Trade” practices, but I think we need to examine these “Fair Trade” relationships and ask the U.S. companies that are the stewards of these relationships to make sure that protecting consumers from environmental toxicity (as well as protecting workers from toxicant exposure in the workplace) is at the top of their list of priorities (regardless of the environmental regulations [or lack thereof] in the countries with the industries and farming they are supporting).