Over the past few years, increasing scrutiny of heavy metals in infant formula and baby food, as well as increased frustration with the Federal government, has driven a wave of state legislative activity across the United States. In 2026, states are continuing to actively reshape how baby food and infant formula are tested, labeled, and disclosed to consumers.
From requirements for stricter testing and public disclosure via QR-code labeling to expanded definitions of “baby food,” both pending bills and newly enacted laws signal a clear trend: State regulators are prioritizing safety, transparency, and accountability.
Below is a look at where things stand today, where they are headed, and how baby food and infant formula manufacturers can remain prepared for the changes to come.
A National Trend: Safety, Transparency, and Accountability
Across nearly every state bill introduced or passed in 2026, three key policy pillars appear consistently and reflect growing concerns around contamination in these products:
- Mandatory testing for toxic heavy metals (arsenic, cadmium, lead, mercury)
- Public disclosure of results, typically via manufacturer websites
- Labeling requirements, often including QR codes linking to transparency data
Approved Laws and Pending Legislation
Following 2021 Congressional recommendations and FDA’s response regarding manufacturers and testing baby and toddler foods for heavy metals and publicly disclosing the results, Maryland and California began requiring testing and disclosure of lead, cadmium, arsenic, and mercury levels in these products.
A number of states have also recently enacted similar frameworks into law in 2025 and 2026, including Connecticut, Illinois, and Vermont, which now mandate monthly testing, public disclosure of results, and QR code-enabled labeling, with compliance deadlines ranging from 2026 to 2028. Collectively, these developments reflect a growing nationwide trend toward standardized testing protocols, increased regulatory oversight, and enhanced consumer access to product safety information.
Additionally, states are actively advancing pending legislation and approving new laws focused on the safety of baby food and infant formula, with a strong emphasis on heavy metal testing, consumer transparency, and labeling requirements. Pending bills in states such as California, Michigan, New York, and West Virginia would generally require manufacturers to conduct routine testing for toxic elements (arsenic, cadmium, lead, and mercury), publicly disclose results via company websites, and include QR codes on product labels linking consumers to this information. Several proposals, including those in New York and Michigan, would also prohibit the sale of products exceeding established limits and introduce phased compliance timelines beginning as early as late 2026.
Looking across both pending and enacted legislation, several trends stand out:
- Increasing Push to Move Beyond Federal Standards: Most states use FDA thresholds as a baseline, but are prepared to enforce them independently or even go further.
- Digital Transparency is Becoming Standard: QR codes and online disclosure platforms are quickly becoming non-negotiable requirements, allowing parents instant access to safety data.
- Frequent Testing is the New Normal: A minimum of monthly testing of finished infant formula and baby food products is now the dominant regulatory expectation across states.
What This Means for Industry
Manufacturers of baby food and/or infant formula should remain vigilant as they prepare for expanded compliance obligations across multiple states, which may require adapting to varying regulatory requirements. Companies will also need to continue to invest in testing infrastructure and robust data systems to ensure accurate results, reporting, and compliance. In addition, industry should consider ways to improve consumer-facing transparency, such as public platforms that clearly communicate product information. Importantly, product and label redesign may be necessary to incorporate QR codes, add other disclosures, and remain in compliance
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Final Thoughts
The 2026 legislative landscape shows that baby food and infant formula safety is no longer a niche regulatory issue, but a nationwide priority. While state-by-state variation remains, the direction is clear: more testing, more transparency, and greater oversight.
As more bills advance and existing laws take effect, both regulators and the industry are moving toward a future where parents have unprecedented insight into what’s in their children’s food.
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We hope this proves useful. If you have questions or would like assistance, please contact Kyla Kaplan ([email protected]), Jamie Woodside ([email protected]), and April Bartosch ([email protected]).
