From July 2025, new maximum levels for nickel in certain foodstuffs, including chocolate and cocoa powder, will come into force across the EU. PRONATEC conducted extensive analyses at an early stage and made product-specific changes to ensure that their products remain available and compliant with the law. Read here about the challenges posed by the implementation of the new regulation.

Jun 12, 2025

With its regulation (EU) 2024/1987, the European Union is stipulating binding maximum levels of nickel in a range of product groups. This is an amendment to an existing directive and will have a significant impact on our industry. Different limit values apply to chocolate, depending on the overall percentage of cocoa. For cocoa powder, the new maximum level only applies to certain uses – namely when it is sold to end consumers directly or as an ingredient in sweetened cocoa powder such as drinking chocolate. The new limit values apply from 1 July 2025, whereby the date the foodstuff is put on the market is key, rather than the production date.

Internal coordination for handling the new limit values

As a company that continually monitors legal developments, PRONATEC tackled the issue of nickel levels at an early stage. We believe it is important to uphold our end-to-end quality assurance system even as requirements increase. Our strategy includes aspects and measures from different departments. To ensure sensible forward planning, for example, volume availabilities need to be estimated, existing stock levels considered, bean availability from suitable sources ensured, specifications adapted and ongoing contracts carefully checked. A dedicated interdisciplinary team with members from Quality Management, Purchasing and Order Processing oversees this.

Internal coordination in dealing with new limit values

Challenges in the geographical assignment of nickel levels

The most urgent matters that had to be addressed in advance were:

Challenges in the geographical allocation of nickel values

  • Is there an interrelation between the maximum cadmium levels, which are already regulated, and the newly regulated maximum nickel levels?

  • How are nickel levels spread across our countries of origin?

  • Can we still produce sufficient quantities of all cocoa products covering all certifications with the available cocoa beans while complying with the cadmium and nickel limits?

There is no correlation between the heavy metal cadmium, the content of which has been regulated for years, and the newly regulated nickel content. This means that cocoa beans with a low cadmium level do not necessarily have a low nickel level. At the start, there was also scarce data on the nickel content of different growing areas. This was all the more reason for us to act in a timely manner and invest in extensive analysis processes at an early stage.

Early risk assessment of countries of origin

Initial assessments from the end of 2024 present a mixed picture, but we are optimistic. Although nickel levels in the Dominican Republic, one of our most important countries of origin, are comparatively high, there are also existing growing areas there with low nickel and low cadmium levels. We are also encouraged by the fact that these growing regions meet all required certifications. In Peru, nickel levels are significantly lower, but the cadmium levels are higher. Sierra Leone also shows low nickel levels. Further bean analyses confirm our initial measurement results.

Early risk assessment

Optimum mixing ratios thanks to sound data set

In order to create a reliable basis for the future availability of our semi-finished cocoa products, we have been conducting extensive analyses since June 2024. Since then, the nickel content of every cocoa bean batch has been checked, and we now have well over 300 readings. This dataset enables us to calculate optimum mixing ratios for cocoa powder production at our production plant in Beringen.

Additionally, since September 2024 we have been recording the nickel levels of all cocoa mass and cocoa powder we produce. Thanks to the now extensive database, we are able to ensure that all of our products subject to the new regulations also meet the nickel limit levels – from cocoa powder and coatings through to chocolate.

Full transparency thanks to batch-based analysis and declaration

For PRONATEC, the new EU nickel regulation primarily concerns cocoa powder. Although cocoa mass can contain nickel, according to the regulations there are no legal limits. Regardless, we have decided to analyse the cocoa mass from our own production plant as standard, so that we can provide our customers with a reliable basis for further processing. Each batch and delivery of cocoa mass and cocoa powder will be accompanied by an analysis certificate that verifies the nickel content. As far as our chocolates and coatings are concerned, we take regular samples to ensure conformity with the legal requirements.

“When it became apparent that regulatory limits for nickel were on the horizon, we began to systematically record the data at an early stage. This has given us clear benefits today, as we are able to continue supplying our customers with products that meet all the legal requirements.”

Samuel Hanimann, Head of Quality Management at PRONATEC

Quality Assurance nickel regulation