Report on the Organic Monitoring Program of Baden-Württemberg 2024

The Federal State of Baden-Württemberg has been conducting a special monitoring program on organically produced foods since 2002. This monitoring is associated with Baden-Württemberg's overall concept of promoting organic farming. Organic products are systematically tested for residues and contaminants, as well as other relevant issues. The goal of the organic monitoring program is to prevent fraud by better tracking down cases of improper labeling in this fast expanding market and to strengthen consumers' confidence in the quality of organically produced foods.

 

Analytical Results from Organic Food Investigations

Following is a translation of the topic "Residues from pesticides and specific contaminants in plant-based-foods".

 

 

Residues from Pesticides and Specific Contaminants in Plant-Based Foods

Introduction

In 2024 a total of 502 samples of plant-based foods from organic cultivation were analyzed for residues of plant-protection substances and specific contaminants. The underlying spectrum of substances for which every sample is routinely analyzed comprises more than 700 components (active substances and metabolites or degradation products as well as particular contaminants such as perchlorate, melamine and cyanuric acid). Including those in the preliminary screening of samples, this spectrum exceeds 1,000 substances.

 

 

Fresh fruit and vegetables

As in previous years, fresh organic fruit and vegetables performed significantly better in 2024 than conventionally produced fresh products. In 76% of the organically grown samples there were no pesticide residues detected (compared with 77% in 2023; 75% in 2022; 76% in 2021; 68% in 2020; 77% in 2019; just under 60% in 2018; 50% in 2017; 65% in 2016; just under 60% in 2015; 52% in 2014; and 60 to 77% in 2013 and earlier). The rate for this reporting year is almost identical to the years of 2019 and 2021 to 2023 and somewhat higher than the value in 2020, but it continues to achieve a high level.

 

The percentage of samples containing residues of multiple pesticides in 2024 was 5.8%, which was somewhat lower than in the years from 2018 to 2022 (5.6% in 2023; 7.0% in 2022; 8.7% in 2021: 11% in 2020; 6.4% in 2019; and 10.5% in 2018), and significantly lower than in the years before: (15% in 2017; 19% in 2016 and 2015; 21% in 2014; and 12% in 2013). After a large spike in 2014, partly contingent on the expansion of investigated substances (the analytical spectrum), the averages have dropped significantly in recent years.

 

The majority of residues were detected in only trace amounts (< 0.01 mg/kg), considerably lower than the concentrations that can usually be found in harvested crops where pesticides have been used. All in all, the rate of violations in fresh, organically produced foods has stabilized at a low level over the past several years, and has dropped significantly since the organic monitoring program began 23 years ago. In 2024 in the category of fresh products (fruits, vegetables, potatoes/starchy plants and mushrooms) one sample of lemons and two samples of garlic from Spain as well as one sample of king oyster mushrooms from Germany were judged to be fraudulent due to the labeling of "organic" on products with elevated levels of plant protector residues. In the previous year of 2023 there were four such samples (avocados of unknown origin, lemons from Italy, sweet potatoes from Egypt and king oyster mushroom from Germany). In 2022 two samples of oranges and one of kiwi, both from Italy, in addition to a sample of bell peppers from Spain, were also deemed fraudulent, whereas in 2021 no such cases were found. In 2020 two organic fruit samples (bananas from Ecuador and the Dominican Republic) and three organic vegetable samples (garlic from Spain, parsley and coriander from Germany) were also judged to be fraudulent.

 

In this reporting year one sample of fresh organic food was in violation for containing pesticide residue levels that exceeded the legally valid maximum levels as stipulated in Regulation (EC) No. 396/2005. The affected sample involved arugula from a German grower, and contained residues of the insecticide spinosad at a level of 33.7 mg/kg. This significantly exceeded the legal maximum of 10 mg/kg, and was analytically verified. Spinosad is produced naturally from a bacterium and is authorized for use in organic farming. Another sample from the same grower that was analyzed later in the same reporting year was found to be free of any residues. In the previous year a sample containing residues above the legally permitted level was also found: sweet potatoes from Egypt. These contained residues of the growth regular mepiquat, whose levels were not analytically verified, however, given the measurement uncertainty of 50%. In 2022 there was another such case (tomatoes from Spain that contained the substance tetramethrin), but in 2021 there were no such organic samples.

 

The rate of violations in this reporting year for organic fruit was 0.9% (2.4% in 2023; 3.4% in 2022; 0% in 2021; 3.0% in 2020; and 2.4% in 2019) and for organic vegetables 1.1% (0.8% in 2023; 0.7% in 2022; 0% in 2021; 2.2% in 2020; and 1.0% in 2019). The rate of violations for all organic fresh foods over the last 14 years has stayed well under 5%, while the rates before 2011 were significantly higher, with some averages as high as 8.5%.

 

For the category of fresh foods (fruits, vegetables including potatoes and starchy plants, and mushrooms), the rate of violations in this reporting year amounted to 1.3% (compared to 1.9% in 2023; 1.8% in 2022; 0% in 2021 and 2.4% in 2020). As in past years, there was neither any accumulation of violations for organic fruits, nor any other irregularities in single cultures detected. Intermittent anomalies existed in the years before 2009, however: herbicides in broccoli and carrots from Italy, the fungicidal substance fosetyl in cucumbers from different countries, surface treatment substances and acaricides in citrus fruits, and sprout inhibitors in potatoes.

 

Average Quantity of Pesticides in Fresh Foods

Evidence for the sheer presence of plant protection substances can be seen by the average amounts of pesticide found in the samples, as the following tables show.

 

* excluding surface treatment substances or preservatives such as phosphonic acid and bromide
** excluding phosphonic acid and bromide

 

The average amount of pesticide residues detected in all analyzed organic fruit samples this reporting year was 0.006 mg/kg, and for all analyzed organic vegetable samples, 0.005 mg/kg, when all organically labelled samples, also those with fraudulent organic labeling, were included in the calculation. The averages dropped to 0.003 and 0.002 mg/kg respectively, when samples were excluded from the calculation because they were suspected of being conventional products, of having been mixed with conventional products, or not conforming to organic farming regulations as evidenced by the pesticide residue situation. The average amounts have remained low over the last years, with very little variation (see table). The significantly deviating value for organic fruit in 2024 came from a non-compliant organic lemon with residues typical for conventional citric fruits.

 

Conventionally produced fruit contained an average of 0.55 mg/kg plant protector residues (excluding surface treatment substances, phosphonic acid and bromide) and vegetables 0.65 mg/kg (excluding phosphonic acid and bromide). The reason for this level of pesticides is due to the application of synthetic plant protection substances that are authorized for conventional cultivation. An extensive body of regulations ensures that these residues do not pose any health risk to consumers.

 

Since the use of synthetic pesticides is not permitted in organic cultivation, very few samples if any tend to have residues over 0.01 mg/kg. The organic products thus differ significantly from conventional goods in terms of contamination from pesticide residues, which the organic monitoring program has clearly demonstrated over the past 23 years.

 

Processed Plant-based Foods

The rate of violations (due to false organic labeling) among processed foods in this reporting year was 3.7%, about three times higher than the rate of 1.3% for fresh organic ware, but still at the constant lows of previous years (3.6% in 2023; 2.2% in 2022; 3.1% in 2021; 2.4% in 2020; and 2.6% in 2019). The rate for processed foods has remained between 2.2% and 7.0% over the last 14 years, whereas before 2011 it was generally higher than 8%.

 

It must be considered, however, that investigations into processed organic products carry a different focus from year to year, with the addition of targeted, short-term projects. Due to the availability of new products, this food group has only come into sharper focus in the past few years. The comparability of violation rates from year to year and over the entire course of the organic monitoring program is therefore limited.

 

Individual anomalies (in single food groups) among the processed foods analyzed in 2024 were found in oilseeds, frozen fruits, cereal products, spices, and plant-based nutritional supplements. These involved one sample each of chia seeds (unknown origin) with residues of the herbicide glufosinate; sesame (unknown origin) with the insecticide, rodenticide and fumigant phosphine; moringa powder (unknown origin) with residues of the fungicide dithiocarbamates; psyllium husks (India) with the fungicide carbendazim; oats (Germany) with the growth regulator chlormequat; cumin (Turkey) with the insecticide methidathion; and frozen black berries (Serbia) with residues of the fungicide boscalid.

 

In this reporting year, as in the past few years, there was no accumulation of violations (from false organic labeling) in a particular food category.

 

In the previous year there were five violatory samples: sunflower seeds (Germany) with residues of the herbicide prosulfocarb; mushroom-based nutritional supplements (cordyceps, unknown origin) with residues of the growth regulators chlormequat and mepiquat; moringa tea (Spain) with residues of the fungicide dithiocarbamate; frozen dill (Germany) with the fungicide and preservative ortho-phenylphenol and the herbicide chloridazon or its degradation product chloridazon-desphenyl; as well as frozen chives (unknown origin) with residues of the herbicide chloridazon/chloridazon-desphenyl.

 

In 2022 there were four such cases: dried pineapple (Ghana) with residues of the herbicide haloxyfop; linseed (Kazakhstan) containing the herbicide diquat; and two samples of chia seeds (Paraguay and unknown origin) with residues of the herbicide paraquat and the post-harvest/storage protector/insecticide pirimiphos-methyl.

 

Violations also occurred among five samples in 2021. These included frozen chives (unknown origin) due to high levels of the herbicide chloridazon and chloridazon-desphenyl; almonds (USA) with residues of the herbicide glufosinate; dried goji berries (China) with residues of the insecticide flonicamid; dried figs (Turkey) with the insecticide/acaricide chlorpyrifos-methyl; and dried pineapple (Ghana) with the herbicide haloxyfop.

 

In 2020 were three such samples: frozen dill and frozen parsley due to high levels of chloridazon/chloridazon-desphenyl, as well as barley grass powder with residues of the growth regulator dikegulac.

 

Finally, in 2019 there were four incompliant samples: two of frozen herbs, also due to chloridazon/chloridazon-desphenyl, and two of dried herbs (bay leaves with the insecticide acetamiprid, and oregano with the fungicide tebuconanzole).

 

One can also refer to the chapter on "Special Findings", where results and data for special substances, projects, and food groups that are excluded from these explanations are given separate attention. These require a separate observation either because of their particularities in occurrence, application, possible modes of entry and analytics, or because they present new or separate problems.

 

When making a judgment regarding the amounts of residues in processed foods, drying and processing factors for the specific substances must be considered because the processing of the original product can lead to an increase or decrease of residues (see the following Info Box).

 

In this reporting year, two samples (1.1%) exceeded the valid maximum residue levels (MRL), analytically verified, taking processing factors into consideration. These included two samples of moringa powder: one with dithiocarbamate (unknown origin) and the second with chlorantraniliprole and lambda-cyhalothrin (India). Two further samples also exceeded the limit, but the findings were not analytically verified. These involved chia seeds with glufosinate (unknown origin) and cumin with methidathion (Turkey).

 

In 2023 two samples (1.4%) also exceeded the valid MRLs, analytically verified, under consideration of processing factors. These involved frozen dill with ortho-phenylphenol (Germany) and moringa tea with dithiocarbamates (Spain).

 

Three further samples exceeded the maximum level without analytical verification: sunflower seeds with prosulfocarb (Germany), dried pineapple with haloxyfop (Ghana), and prepared fruit for babies and young children with pyrimethanil (unknown origin).

 

In 2022 two samples (1.0%) exceeded the valid limit, analytically verified: dried pineapple with haloxyfop (Ghana) and chia seeds with paraquat (Paraguay). Another sample of chia seeds (Bolivia) exceeded the legal limit for haloxyfop, but this was not analytically verified.

 

In 2021 three samples (1.9%) were found to have exceeded valid maximum levels, analytically verified: dried figs with chlorpyrifos-methyl, dried pineapple with haloxyfop, and dried moringa leaf powder with chlorantraniliprole and lambda-cyhalothrin.

 

 

Overview of Violations

The following table gives an overview of violations for organic samples analyzed over the last several years. Fortunately, this rate has decreased in general, and has been consistently < 5% over the last seven years (2018 to 2024).

 

 

The following table gives an overview of all organic samples analyzed in 2024 for residues of plant protector substances and their rate of violations, itemized by food group (matrix).

 

Substances that are allowed in organic farming and those with different modes of entry are excluded here (see section on "Special Investigations"). Processing factors are taken into consideration for processed products. No percentage is given for sample sizes < 51) Only samples analytically verified to contain amounts above the orientation value of 0.01 mg/kg for organic foods are included.2) Maximum residue levels established by Regulation (EC) No. 396/2005 (exceedances with and without analytical verification); excluded are formal objections due to substances in the section "Special Investigations".3) Processing factors are considered for the respective processed products. The separately listed substances found in the section "Special Investigations" and the substances authorized for use in organic farming were not considered.

 

 

Special Investigations

Residue data and results from special substances and food groups or projects that have been excluded from the observations thus far are presented in the following section. They require individual consideration, either due to unique characteristics regarding their existence, applications, possible modes of entry and analysis, or because they present new or special problems.

 

Nicotine

In 2024 all 502 samples from organic production were analyzed for residues of nicotine.

 

A refined method for analyzing the parameters of nicotine in plant-based matrices including a preliminary screening step was already established several years ago by CVUA Stuttgart. Due to findings of low levels (under 0.01 mg/kg) of nicotine in plant-based foods, a model trial was carried out in 2017 to determine to what extent the consumption of tobacco products would cause nicotine to transfer from hands onto food (see here the Organic Monitoring report from 2017, pg. 17; CVUA Stuttgart | Report on the Organic Monitoring Program of the Year 2017). These investigations showed that nicotine could indeed be transferred to fruit and vegetables in measurable amounts when a smoker touched these foods shortly after having smoked a cigarette. The transfer of nicotine was even higher for wet foods, such that the detected amounts reached the low-set legal maximum levels in some cases.

 

CVUA Stuttgart reports on possible contaminants and sources of contamination. Since the mode of entry and/or the cause of detected nicotine residues is not usually known, however, the "organic" labeling of such foods is not judged to be fraudulent. Nevertheless, an indication is made in the report that a documented, intentional application of nicotine containing plant protection substances would constitute such an offence.

 

Regardless of its mode of entry, however, nicotine is subject to the MRL established by Regulation (EC) No. 396/2005. Routine analyses of nicotine residues will continue in 2025.

 

In reporting year 2024, 8 out of 502 samples (1.6%) contained nicotine > 0.01 mg/kg, under partial consideration of drying and processing factors (compared to 0.9% in 2023; 0.9% in 2022; 2.4% in 2021; 1.8% in 2020; 3.6% in 2019; 2.5% in 2018; and 5.9% in 2017). The rate of 1.6% for 2024 thus constitutes a low percentage, in line with those of previous years.

 

One sample from 2024 (organic garden cress from Germany) was in violation for an exceedance of the maximum level, analytically verified (0.2%). A sample analyzed the year before was also found to be above the maximum level (0.3%). No violations were found in 2021 and 2022. In 2020 one sample (0.3%) was in violation, in 2019 again no samples, while in 2018 one sample (0.3%) and in 2017 four samples (1.2%) were violatory.

 

Three samples from 2024 (0.6%) exceeded the legal maximum level of 0.01 mg/kg under consideration of possible processing factors and measurement uncertainty (arugula and kale from Germany and ashwagandha powder from an unknown origin), albeit not analytically verified. The cases were highlighted in a report drawing attention to the increased residue levels. In 2023 there was one such sample (0.3%), in 2022 were two samples (0.5%), in 2021 three samples (0.8%), in 2020 one sample (0.3%) and in 2018 and 2019 two samples (0.6% each) that were conspicuous.

 

Among the other four samples with nicotine (ashwagandha powder and psyllium husks from India, green tea of unknown origin and rosemary from Germany), the residue levels were under the valid maximum amounts, but high enough to warrant being highlighted in a report.

 

It is important to note here that nicotine residues can have various paths of entry that are to be considered and discussed (see Info Box).

 

Trimethylsulfonium-Cation (Trimesium)

In 2024 all 502 samples of organic produce were analyzed for residues of the substance trimethlysulfonium cation (trimesium).

 

Trimethlysulfonium cation is listed in Regulation (EC) No. 396/2005 as a substance that forms as a result of the use of glyphosate. Trimesium does not form as a result of an application; it exists in plant-protection substances as an anti-ion to glyphosate, in an already completed formulation. Such types of pesticides are still authorized for use in non-EU states, but no longer within the EU. Due to its particular properties, this substance cannot be integrated into the investigative spectrum of the QuEChERS multi-method; it requires its own processing and analytical method.

 

There are indications, however, that among teas and other dried or processed foods, trimesium is formed during the drying process or as a result of heat exposure, thereby causing contamination of such foods. Analytical results also show that higher levels of trimesium are mostly found in dried samples. Further investigations and process controls are needed in order to clarify whether the formation of trimesium during the drying process can be reduced by means of appropriate processing procedures. Enforcement measures in Baden-Württemberg are currently suspended until a final clarification can be made.

 

Residues of trimesium were detected in 23 samples (4.6%), compared to 1.4% in 2023; 2.6% in 2022; 4.3% in 2021; 4.7% in 2020; 3.1% in 2019; 1.7% in 2018; and 8.6% in 2017. Two of these (0.4%) were analytically verified to have exceeded the maximum residue level (under consideration of drying factors). This involved hibiscus blossoms (dried, milled) from Egypt and moringa powder of unknown origin. The legal maximum level for both of these samples and matrices lies at 0.05 mg/kg.

 

The previous year (2023) saw conspicuous findings for 1 sample (0.3%); 2022 had 2 such samples (0.5%), 2021 saw 3 (0.8%), and 2020 had 6 (1.7%) samples, although no analytically verified exceedances of the maximum level were found. In contrast, no samples were notable in 2019 and 2018, but formal objections against fully 10 samples (3.1%) were filed in 2017.

 

There were no nominal, analytically unverified exceedances of the valid maximum level in this reporting year.

 

Reports on these particular matrices suggest possible paths of entry and formation of the substance. Normally, however, neither the pathway nor the source of these detected residues are known to the experts (as with the case of nicotine), so an organic label won't be judged as fraudulent. Nevertheless, an indication is made that a provable, intentional application of a glyphosate containing plant protection substance would constitute such an offence. In this reporting year, however, none of the analyzed samples were detected with residues of glyphosate.

 

Regardless of the path of entry into the specific food, trimethlysulfonium cation, as well as the aforementioned nicotine, falls under the applications area in Regulation (EC) No. 396/2005 and is subject to the maximum residue limits provided therein. Investigations into trimesium residues will continue in 2025.

 

Phosphonic Acid, Phosphonates, and Fosetyl

In this reporting year all of the 502 samples from organic culture were analyzed for the fungicidal substances fosetyl and phosphonic acid. In Regulation (EC) No. 396/2005 these substances are registered as sum parameters of fosetyl (sum of fosetyl and phosphonic acid and their salts, expressed as fosetyl). This residue definition has been discussed at the EU level for quite some time, however, and is expected to be changed to include only phosphonic acid ((phosphonic acid and their salts (phosphonates), expressed as phosphonic acid)). In the meantime, this change has taken effect and has been valid since the end of April 2025.

 

It is important to note, however, that residues from phosphonic acid can have various causes and therewith various (possible) paths of entry (see Info Box). Residues can thus stem from applications that don't serve as plant protection.

 

Neither of these substances is integrated into the investigative spectrum of the QuEChERS multi-method due to their particular properties; they require their own processing and analytical methods.

 

 

In 2024 a total of 122 of the 502 samples (24%) contained detectable residues. After a period of 10 years, during which a considerable reduction had been observed, the quantities found in this reporting year were again at the significantly higher value from 2013: (2.3% in 2023; 4.0% in 2022 and 2021; 6.7% in 2020; 5.9% in 2019; 8.7% in 2018; 8.3% in 2017; 14% in 2016; 15% in 2015; 19% in 2014; and 24% in 2013).

 

This increase in findings is primarily due to the new, substantially more sensitive analysis and measurement method that has been implemented for the determination of phosphonic acid and fosetyl residues since this reporting year of 2024. This accredited procedure is characterized by much lower limits of determination compared with previous, also accredited, methods of determination. Almost two-thirds of the detected residues of phosphonic acid (80 samples) from 2024 were in this newly possible realm of determination.

 

What has not changed in comparison with previous years is the fact that residues occur in a variety of different matrices from diverse countries of origin, and thus cannot be limited to single types of food or individual countries.

 

There was a wide range of phosphonic acid levels detected, from amounts of 0.010 mg/kg up to peak values of 1.1 mg/kg for a sample of chamomile tea (unknown origin), 1.6 mg/kg each for a sample of red wine grapes (Germany) and grapefruit (Spain), and as high as 39 mg/kg for a sample of black pepper (Vietnam). Values above 10 mg/kg have only appeared in individual cases in recent years.

 

It is also interesting to note that, in all of the analyzed samples, only residues of phosphonic acid were detected, whereas no residues of fosetyl per se were detectable. This points to the possible application of a phosphonate-containing fertilizer, which was also the case in previous years.

 

Because the source of phosphonic acid residues can't be determined in a laboratory (see Info Box), a total of 23 reports (compared to 7 in 2023; 17 in 2022; 10 in 2021; 22 in 2020; 13 in 2019; 22 in 2018; 21 in 2017; and 43 in 2016) were submitted for samples containing residue amounts > 0.1 mg/kg (under consideration of processing factors). The intention is to highlight this issue among the producers so that they attempt to identify and ultimately minimize the possible paths of entry.

 

None of the 502 analyzed samples (0% in 2023; 0.25% in 2022; 0% in 2021; 0.3% in 2020 and 0.6% in 2019) exceeded the valid maximum sum levels for fosetyl (sum of fosetyl and phosphonic acid and their salts, expressed as fosetyl) as stipulated in Regulation (EC) No. 396/2005.

 

It was also observed that the highest levels found for the sum of fosetyl was very wide, ranging from values of 2 mg/kg for many foods such as apricots, peaches, plums, passion fruit, bananas, mangos, carrots, beans, fennel, rhubarb and mushrooms, up to values as high as 400 mg/kg in pepper and 1,500 mg/kg for almonds and even as high as 2,000 mg/kg (!) in hops and some herbal teas.

 

Chlorate and Perchlorate

In 2024 all 502 samples from organic cultivation were also analyzed for residues of chlorate and the environmental contaminant perchlorate (see Info Boxes on chlorate and perchlorate).

 

As is the case for nicotine, fosetyl and phosphonic acid, the unique properties of these two substances preclude their integration in the investigative spectrum of substances analyzed by the QuEChERS multi-method, thus requiring their own processing and analytical methods.

 

Since 1 July 2020 there are new, valid, legal maximum levels for chlorate of between 0.05 and 0.7 mg/kg (excluding food for babies and young children, whose levels are 0.01 mg/kg) and (for the first time, legally binding) for perchlorate of between 0.05 and 0.75 mg/kg for matrices other than food for babies and young children (0.01 and 0.02 mg/kg, respectively).

 

Background Information

Before the above-mentioned time frame there had been a default maximum level of 0.01 mg/kg for chlorate and various reference values for perchlorate, depending on the matrix. Though not legally binding, these were supposed to guarantee the marketability of the products.

 

Perchlorate was detected in 114 of the 502 analyzed organic samples (23%). This compares with 16% in 2023; 18% in 2022; 16% in 2021; 20% in 2020; 17% in 2019; 22% in 2018; 23% in 2017; 17% in 2016; 20% in 2015; 31% in 2014; and 19% in 2013). Chlorate residues were found in 53 samples (11%). Previous years saw 15% in 2023; 16% in 2022; 11% in 2021; 14% in 2020; 13% in 2019; 11% in 2018; 16% in 2017; 12% in 2016; 16% in 2015; 20% in 2014; and 26% in 2013.

 

Analogous to phosphonic acid, these findings were also widely dispersed among different matrices and diverse countries of origin, and cannot therefore be reduced to individual food types or country of origin in terms of their occurrence.

 

The results of our analyses will be explained and considered in the following section.

 

Among the food for babies and young children that were analyzed, for which significantly lower maximum residue levels for both substances are valid (see above), 2 of the 13 samples exhibited residues from one of these two substances. These involved a sample of prepared vegetables with 0.006 mg/kg of chlorate and a sample of porridge (to be prepared with milk or water) whose amount of chlorate in the prepared, ready-to-eat food also lay under 0.01 mg/kg, however.

 

In the previous year 1 of the 9 analyzed samples of prepared fruit was detected with slightly elevated levels of chlorate and the maximum level of 0.01 mg/kg for chlorate was exceeded, albeit analytically unverified. This value was referenced in a report. In 2022 none of the 16 samples contained either of these two substances. In 2021, 1 of 17 analyzed samples contained chlorate in spelt cereal porridge (to be prepared with milk or water) whose amount found in the finished prepared product lay nevertheless under 0.01 mg/kg.

 

Chlorate and perchlorate have been routinely analyzed within the scope of the organic monitoring program since 2013. These substances will continue to be investigated in 2025.

 

Perchlorate

In this reporting year all of the 502 analyzed samples were evaluated in accordance with the new legal maximum levels for perchlorate established by the EU contaminants ordinance (Regulation (EC) No. 2023/915), valid since July 2020. One sample of kale from Germany (0.2%) significantly exceeded this level, at 0.22 mg/kg; the legal maximum level is 0.10 mg/kg.

 

In the previous year one of the 355 samples (0.3%) was very conspicuous: a sample of moringa tea of unknown origin. The residue amount of 4.2 mg/kg was so high that, in addition to exceeding the maximum level, even the toxicological reference dose was exhausted, so the sample was judged to be an unsafe food. In 2022 none of the samples exceeded the legal level. However, in 2021 one of the 371 (0.3%) analyzed samples did exceed the maximum: dried alaria brown algae in powder form.

 

In 2020 two samples of moringa leaf powder (0.6%) would have also exceeded the maximum levels. However, these samples were collected and analyzed well before the date of validity for these new levels, so they were assessed based on the then valid EU reference value. These reference values were not legally binding, but were intended to ensure the marketability of the products.

 

CVUA Stuttgart addressed the issue of perchlorate as many as ten years ago. In the meantime, the levels of residues found in plant-based foods have declined due to a reduction in the use of perchlorate containing fertilizers. Nevertheless, the German Federal Institute for Risk Assessment (BfR) recommends a further reduction due to toxicological concerns (bfr.bund.de).

 

These new EU-wide valid maximum levels, now established and legally binding for a good four years, represent an important step and great success for consumer and health protection. Through its work and analyses, CVUA Stuttgart has played a significant role in the introduction of these maximum levels.

 

 

Chlroate

A total of 38 of the 502 analyzed samples (7.6%) contained chlorate residues > 0.01 mg/kg, compared to 9.9% in 2023, 12% in 2022, 7.8% in 2021, 7.6% in 2020, 7% in 2019, 3.9% in 2018, 6.8% in 2017, 6.2% in 2016, 11% in 2015, and 16% in 2014. Although possible paths of entry are known, it cannot be said with absolute certainty where the residues in a particular sample came from (see Info Box on chlorate). Until the end of 2019, samples with analytically verified MRL exceedances (chlorate values > 0.02 mg/kg under consideration of processing and drying factors) were officially reported to be in violation.

 

At the beginning of 2020, however, the new maximum levels that would only become valid in July of that year were already being applied. These lay between 0.05 and 0.7 mg/kg, with the exception of food for babies and young children (0.01 mg/kg).

 

In reporting year 2024 one sample of pureed tomatoes was conspicuous, although the exceeded valid maximum level was not analytically verified. This was indicated in an official report. In the previous year one sample of moringa tea (the same sample that contained perchlorate) exceeded the maximum level, analytically verified, and a formal objection was filed. This was not the case for any of the analyzed samples in 2022.

 

In 2021 two samples did present residues above the maximum level, but these were not analytically verified (1x sesame and 1x chlorella algae in powder form, both from unknown origins). For comparison, one sample of chia seeds (unknown origin) was in violation for a verified exceedance in 2020.

 

There have been newly derived toxicological assessments regarding chlorate residues in food (acute reference dose of 0.036 mg/kg bodyweight and day) since 2015, provided by the European Food Safety Authority (EFSA). Based on these assessments, none of the samples analyzed in 2024 exceeded these health-based reference values. That means no samples exhausted the values by more than 100%, and posed thereby no chronic or acute health problems.

 

 

Other notable and interesting findings from reporting year 2024

The following section highlights results from special substances that, due to particularities in their occurrence and application or in response to special questions posed, require a separate analysis. It is usually necessary to utilize single methods for such processing and analysis. The extra effort also provides more consumer protection, however. When available, individual samples that are not commonplace, as well as special cases and interesting findings are also presented here.

 

Melamine

Melamine is a contaminant, for which a general maximum level of 2.5 mg/kg in food has been established, in accordance with the EU contaminant ordinance, Regulation (EC) No. 2023/915. Melamine is included in the routine analytical spectrum of substances investigated at CVUA Stuttgart, so every sample is also analyzed for it.

 

Melamine was detectable in 32 of the 502 organic samples (6.4%) analyzed in 2024, at levels above 0.01 mg/kg (compared to 6.8% in 2023; 6.1% in 2022; 4.9% in 2021; 5.8% in 2020; and 9.5% in 2019). Seven of these samples (1.4%) contained amounts > 0.10 mg/kg (1.1% in 2023; 0.7% in 2022; 0.3% in 2021; 1.2% in 2020; and 3.9% in 2019). This involved two samples of cucumbers with 0.25 mg/kg and 0.20 mg/kg respectively, one sample each of oranges with 0.35 mg/kg, dried mug wort with 0.15 mg/kg, moringa powder with 0.55 mg/kg, barley grass powder with 0.87 mg/kg, and dried Spirulina algae with 0.15 mg/kg.

 

The previous year had one sample each of oranges (0.16 mg/kg), lemons (0.13 mg/kg), iceberg lettuce (0.12 mg/kg), and new potatoes (0.18 mg/kg).

 

In 2022 there were 3 samples: linseed with 0.36 mg/kg, cucumber with 0.47 mg/kg, and king oyster mushrooms with 1.0 mg/kg. In 2021 there was only one sample of cucumber with 0.47 mg/kg, and 2020 had two samples of moringa powder with 0.24 mg/kg and 0.26 mg/kg, respectively, one sample of garlic with 0.17 mg/kg, and one sample of arugula with 0.20 mg/kg.

 

As in the previous four years, there were no cases of MRL exceedance for melamine in this reporting year. The only case with a violation thus far has been a sample of organic potatoes from Germany detected in 2019, with residue levels of 6.3 mg/kg; the exceedance of the above mentioned maximum level was analytically verified.

 

Melamine can end up in food via, among others, fertilizers that release calcium cyanimide or which themselves contain melamine. It can also conceivably come from an application of the insecticide cyromazine, which forms melamine as a byproduct. Such fertilizers and cyromazine are not authorized for use in organic cultivation, however.

 

Chloridazon-desphenyl in frozen herbs and frozen vegetables

In this reporting year a total of 7 of the 502 analyzed samples (1.4%) were found to contain detectable residues of chloridazon-desphenyl, the main degradation product of the herbicide chloridazon. This compares with 3.7% in 2023; 0% in 2022, 1.1% in 2021, 1.5% in 2020, and 0.8% in 2019. This value is significantly lower than the average for 2023 and is similar to the years leading up to 2022. This year, as in 2023, special attention was given to frozen goods (herbs and vegetables), which have occasionally exhibited irregularities in the past.

 

The 7 samples included frozen herbs (3x), frozen spinach (2x), frozen beans (1x), and fresh cantaloupe melon (1x). None of these cases exceeded the maximum level set by Regulation (EC) No. 396/2005 or the orientation value for organic goods of 0.01 mg/kg. The use of synthetic pesticides (such as chloridazon) in organic farming is not authorized in general.

 

The previous year also had no exceedance of the maximum level stipulated in Regulation (EC) No. 396/2005. The detected residue amount for two of these samples (frozen dill and frozen chives) lay, analytically verified, above the orientation value of 0.01 mg/kg for organic foods, however. Both of these samples were therefore judged to be fraudulent in view of their organic labeling. An additional 6 samples (2x frozen beans, 3x frozen herbs, 1x pumpkin) also exceeded the orientation value, but this was not analytically verified; the slightly elevated quantity was referenced in a report. The remaining samples contained quantities under 0.01 mg/kg.

 

The previous year (2022) saw no problematic samples regarding residues of chloridazon (-desphenyl).

 

In 2021 one sample of frozen herbs (chives), two samples of frozen spinach, and one sample of frozen peas all from organic cultivation were detected with the degradation product of the herbicide chloridazon. None of these cases exceeded the maximum level set by Regulation (EC) No. 396/2005. The amount of residues detected in the chives sample was significantly and analytically verifiable above the orientation value of 0.01 mg/kg for organic foods, however, and thusly judged to be fraudulent in view of its organic labeling. One of the two frozen spinach samples exceeded the orientation value, not verified; the slightly elevated value was highlighted in a report. Both of the other two samples had quantities below 0.01 mg/kg.

 

In 2020 two samples of frozen herbs (parsley and dill), two samples of frozen spinach and one sample of frozen green beans from organic cultivation were detected with residues of chloridazon-desphenyl. The maximum level set by Regulation (EC) No. 396/2005 was not exceeded in these cases. However, the frozen dill and parsley samples contained analytically verified residue levels above the orientation value of 0.01 mg/kg for organic foods and were therefore judged to be fraudulent due to the organic labeling. The three remaining samples all lay just under 0.01 mg/kg.

 

Even as recently as 2019 there were detectable amounts of chloridazon-desphenyl found in three samples of frozen herbs (dill and chives). In light of the misleading organic labeling, two of the samples were reported for being fraudulent; the third sample was highlighted for slightly elevated quantities.

 

The substance chloridazon is no longer authorized for use in the EU. However, the country of origin is often not indicated on frozen foods, so it is possible that the herbs and vegetables stem from third countries.

 

Inorganic Bromide

Bromide (degradation product of the fumigant methyl bromide) can be found, sometimes in higher levels, in our analyzed samples, both organic and conventional. A fast and effective fumigant, methyl bromide was widely used for a long time. However, it is very damaging to the ozone layer. Therefore, 175 countries made an international contract in 1987 (the Montreal Protocol) in which they pledged to significantly limit the use of methyl bromide as a fumigant and to apply alternative methods by 2015. Since 2015 the application of methyl bromide has been extremely restricted worldwide. A continuing reductionary trend in bromide residue amounts is therewith to be expected in the coming years. Bromide can also occur naturally in soil, however, and there is indication that the naturally occurring quantities of bromide can be higher near the sea or in former marine areas. Italy and other countries often refer to this as a possible source of bromide.

 

Taking this fact into account, residue amounts of up to 5 mg/kg (orientation or threshold value) in fresh organic products are accepted as having come from natural sources.

 

In this reporting year 10 of the 502 analyzed samples (2.0%) presented with amounts of > 5 mg/kg (compared to 1.4% in 2023; 1.2% in 2022; 4.0% in 2021; and 4.4% in 2020). These included 2 samples of baby spinach (both from Italy), and 1 sample each of Hokkaido pumpkin (Germany), millet flakes (Ukraine), linseed (India), black pepper (unknown origin), cumin (Turkey), hibiscus flower tea (Egypt), spinach powder (Germany), and moringa powder (unknown origin).

 

In their reports, CVUA Stuttgart draws attention to bromide residues detected in organic samples that exceed 10 mg/kg (analytically verified exceedances of the orientation value, considering processing/drying factors). Among the 10 samples with determinable residues of bromide > 5 mg/kg, 4 contained levels above 10 mg/kg (2x baby spinach, Hokkaido pumpkin, and cumin).

 

In the previous year 5 samples had levels above 10 mg/kg; 2021 had 11 such cases, and in 2020 there were 4. An exceptional year was 2023, when all sample amounts lay under this value.

 

Hydrogen Phosphide (Phosphine)

These days food is imported to Germany from all over the world. In some cases the goods will have traveled a very long way in ships or other transporters before they arrive. In order to protect the goods from storage pests during transport in sea containers, hydrogen phosphide is often used in the form of its phosphide salts as a fumigant. The salts contained in dispensers in solid form react with moisture in the air, creating hydrogen phosphide which, when released, kills the pests. Phosphine is also used in storage rooms, where dry or dried goods are stored.

 

Phosphine or hydrogen phosphide is not authorized for use in organic cultivation, so residues are not to be expected. To date, there is no knowledge of any evidence documenting naturally occurring contamination from phosphine. There are discussions, however, regarding the possibility of (cross) contamination from residual dust of previously stored and treated or gassed goods that clings to the inner walls of containers or storage halls and which, when not properly cleaned, can be transferred to untreated goods.

 

In this reporting year CVUA Stuttgart focused its analyses on residues of the fumigant phosphine in 25 organic samples (sesame, linseed, chia seeds, buckwheat, rice, legumes, and spices). Between 2017 and 2020 phosphine residues were found mainly in dried legumes (lentils) and cereals (rice). In this reporting year CVUA Stuttgart focused its analyses on residues of the fumigant phosphine in 25 organic samples (sesame, linseed, chia seeds, buckwheat, rice, legumes, and spices). Between 2017 and 2020 phosphine residues were found mainly in dried legumes (lentils) and cereals (rice).

 

Five of the analyzed samples (20%) contained residues of phosphine (compared to 14% in 2023; 0% in 2022; 38% in 2021; 32% in 2020; 33% in 2019; 14% in 2018; and 12% in 2017). These included 2x sesame (Egypt and unknown origin), 2x chia seeds (Bolivia and unknown origin), and 1 sample of linseed (Kazakhstan). One of the samples (sesame of unknown origin) was conspicuous for containing phosphine residues at levels of 26 g/kg (0.026 mg/kg). Although this level undercut the valid maximum level of 50 g/kg (0.05 mg/kg) set by Regulation (EC) No. 396/2005, it significantly exceeded the orientation value for organic food of 0.01 mg/kg. An objection was filed for this sample, therefore, in view of its fraudulent "organic" label. The other 4 samples lay substantially under 0.01 mg/kg (10 g/kg), even considerably under 0.005 mg/kg (5 g/kg).

 

In previous years with the exception of 2022, individual cases have been occasionally recorded, but with levels of residues that were usually very low, less than 5 g/kg (0.005 mg/kg). The lowest maximum level for phosphine (10 g/kg) established by Regulation (EC) No. 396/2005 was thereby significantly undercut in each case.

 

In 2023 as well as in the 3 previous years there were no violations for organically grown samples, either due to an MRL exceedance or to fraudulent organic labeling. In 2019, however, an official objection was filed due to a sample of lentils from Turkey.

 

Conventional products were also investigated for phosphine in 2024. A total of 25 samples were analyzed, including legumes, rice, buckwheat, sesame, linseed, chia seeds, and spices. Residues were detected in 9 samples (38%), 6 of which contained levels < 0.01 mg/kg (10  g/kg). These involved chick peas from Mexico (2x) and from Lebanon, red lentils of unknown origin, and cardamom from Guatemala and India. The 3 further samples contained levels above the legal maximum for phosphine according to Regulation (EC) No. 396/2005. Here it was one sample each of chick peas from Turkey (0.017 mg/kg), chick peas from Mexico (0.076 mg/kg), and sesame of unknown origin (0.23 mg/kg).

 

As early as 2012 CVUA Stuttgart published a report (in German) on the internet website ua-bw.de with background information on the subject of residues from the fumigant hydrogen phosphide in arid, plant-based foods.

 

Ethylene Oxide and 2-Chloroethanol

Investigations, results and background information on this topic can be found in reports published by CVUA Stuttgart in the years 2020 and 2021 (10 Dec. 2020, 28 July 2021 and 17 Aug. 2021) at the following website link: ua-bw.de.

 

In this reporting year a total of 25 samples of organic production were analyzed for residues of ethylene oxide and its degradation product 2-chloroethanol. No ethylene oxide or 2-chloroethanol (0%) was detectable in any samples, compared with 10% (3 of 30 samples) in 2023; 2.3% (1 of 43 samples) in 2022; and 6.7% (9 of 134 samples) in 2021.

 

As Comparison:

In the previous year a total of 30 organic samples were analyzed for residues of ethylene oxide and its degradation product 2-chloroethanol. Here there were 3 samples (10%) with detectable residues of 2-chloroethanol, but none with residues of ethylene oxide. These involved 3 capsules of powder-based nutritional supplements of organic moringa, organic cordyceps, and organic triphala, containing 3.8 mg/kg, 4.0 mg/kg and 366 mg/kg respectively. This equates to 2.1 mg/kg, 2.2 mg/kg and 200 mg/kg when calculated as ethylene oxide. There are no valid maximum levels for NS listed in Regulation (EC) No. 396/2005. Nevertheless, toxicological reference values were either completely exhausted or exceeded here, so all 3 samples were judged to be unsafe, hazardous foods.

 

In 2022 a total of 43 samples of organic produce were analyzed for residues of ethylene oxide and its degradation product 2-chloroethanol. Here there were residues of 2-chlorethanol detectable in one sample (2.3%), but none for ethylene oxide. The sample was freeze-dried acai berries in powder form, with an amount of 0.38 mg/kg (0.21 mg/kg when calculated as ethylene oxide). Factoring in drying factors, the valid maximum level of 0.02 mg/kg set by Regulation (EC) No. 396/2005 was exceeded by this sample, albeit not analytically verified. Toxicological reference values were neither exhausted nor exceeded. However, since the orientation value of 0.01 mg/kg for organic products was exceeded and this substance is not authorized for use in organic farming, the organic labeling was reported as fraudulent.

 

The year 2021 presented with 9 organic samples with determinable residues, arrayed as follows: vegan soy-based sausage substitute, barley grass powder, milk thistle powder, turmeric powder, red maca powder and moringa oleifera leaf powder (4x). The detected amounts of 2-chloroethanol ranged from 0.065 mg/kg in a vegan soy-based sausage substitute to peak values of 410 mg/kg, 733 mg/kg and 1,030 mg/kg in moringa oleifera leaf powders. Ethylene oxide itself was not detectable in any samples. Five of these samples exceeded, analytically verified, the valid legal maximum levels according to Regulation (EC) No. 396/2005. They were all judged to be unsafe foods due to the exhaustion of the toxicological reference values (4 cases were judged to be a health hazard and 1 was deemed unsuitable for consumption). The samples involved included 4 samples of moringa oleifera leaf powder and 1 sample of barley grass powder.

 

Authors

Marc Wieland, Kathi Hacker and Ellen Scherbaum, CVUA Stuttgart

 

Translator

Catherine Leiblein

 

 

Report published on 04.08.2026