• On March 6, 2026, California Attorney General, Rob Bonta, issued an enforcement letter to baby food manufacturers, reminding industry of its obligations under AB 899, which requires that any baby food products sold or made in the state be tested for arsenic, cadmium, lead, and mercury.
  • As we previously reported, under AB 899, manufacturers of baby food (not including infant formula) for sale or distribution in California must test a representative sample of each production aggregate of the final baby food product at least once a month.  Test results must be provided to the California Department of Public Health upon request.  Starting January 1, 2025, manufacturers were also required to make publicly available on the manufacturer’s website, for the duration of the product shelf life for a final baby food product plus one month, the name and level of each toxic element present in each production aggregate of a final baby food product. 
  • The enforcement letter responds to Consumer Reports’ 2025 article which that found some baby food manufacturers were not making their product testing easily available.  Attorney General Bonta reiterated that “[f]ailure to comply with AB 899’s requirements may constitute a violation of California’s Unfair Competition Law, Business and Professions Code section 17200, and other applicable laws.”
  • Just weeks before the issuance of the enforcement letter, California also introduced AB 2302 in February 2026, which would require heavy metals testing and reporting for infant formula manufacturers. The bill is currently undergoing committee review.
  • Keller and Heckman will continue to relay any developments in baby food and infant formula regulation.