Inorganic arsenic (sum of As(III) and As(V)) in fish and seafood: maximum levels from 0.050 mg/kg for cephalopods to 1.5 mg/kg for langoustine and rock lobster; determination requires speciation, most often HPLC-ICP-MS
Commission Regulation (EU) 2025/1891, published on 18 September 2025, adds to Regulation (EU) 2023/915 maximum levels of inorganic arsenic in fish meat, crustaceans, bivalve molluscs and cephalopods (mg/kg wet weight). Food lawfully placed on the market before 8 October 2025 may remain on the market until its date of minimum durability or use-by date.
- Levels (mg/kg wet weight): fish meat — 0.10, and for anglerfish, monkfish and giant stargazer (Lophius; Kathetostoma giganteum), flatfishes (Pleuronectiformes), haddock, herring (Clupea), rays and sharks 0.50 (fish intended to be eaten whole — the whole fish); crustaceans — crabs, crab-like crustaceans, prawns and shrimps 0.10, langoustine and rock lobster 1.5, others 0.20 (muscle meat from appendages and abdomen, excluding the cephalothorax); scallops 0.10 (for great scallop only the adductor muscle and gonad), other bivalve molluscs 0.50; cephalopods 0.050 (without viscera).
- The levels apply to inorganic arsenic, i.e. the sum of As(III) and As(V); the limit for total arsenic in salt (0.50 mg/kg) remains, moved to point 3.4.9. For dried, diluted, processed and compound foods Article 3(1) and (2) of Regulation 2023/915 applies. Until now inorganic arsenic levels covered foods of terrestrial origin (Regulations 2015/1006 and 2023/465).
- Methods according to EFSA’s 2023 opinion: total arsenic is determined after mineralisation by HG-AAS or ICP-MS; inorganic arsenic requires speciation — extraction (methanol, water or a mixture, mildly acidic, or microwave-assisted alkaline solubilisation in which arsenite is oxidised to arsenate), separation on an anion-exchange HPLC column and ICP-MS detection. Arsenic has a single isotope, so isotope dilution cannot be used; ICP-MS/MS with oxygen in the reaction cell is increasingly used, shifting As⁺ from mass 75 to 91 (⁷⁵As¹⁶O⁺).
- Justification (recitals of the act): in its opinion adopted on 28 November 2023 EFSA used a BMDL05 of 0.06 µg/kg body weight per day; margins of exposure for adults were 2–0.4 for average consumers and 0.9–0.2 for the 95th percentile, which EFSA considered a health concern. EFSA’s 2021 report indicated that in some countries fish and other seafood are among the likely sources of adult exposure to inorganic arsenic.