“In addition, the use of lead-based printing inks on candy wrapper may subject a firm to regulatory action of the U.S. Consumer Product Safety Commission under the Federal Hazardous Substances Act.” (FDA Guidance for Industry). Producers should review their product packaging and particularly the certification and registration obligations under the CPSIA.
The FDA has previously issued its own guidance for Industry for maximum levels of lead in candy frequently consumed by small children and enforcement policy. The guidance sets a do-not-exceed limit of 0.1 ppm “because such levels are achievable under good manufacturing practices and would not pose a significant risk to small children for adverse effects.”