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Pesticides and CBD flower: the MRLs a lab must check

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9 min readUpdated on

A maximum residue level, or MRL, is set substance by substance and food by food by Regulation (EC) No 396/2005. When a substance is not named, a default value of 0.01 mg/kg applies, according to the European Commission page devoted to that legislation. On a certificate, four elements make the "pesticides" page verifiable: the list of substances, the limit of quantification, the method and the laboratory's scope of accreditation.

Get to the essentials
Pesticides and CBD flower: the MRLs a lab must check
Contents
  1. 011. What an MRL is, and where it comes from
  2. 022. Where to read an MRL: the Commission database
  3. 033. The method: LC-MS/MS, limit of quantification and identification
  4. 044. Accreditation and its scope
  5. 055. Reading the "pesticides" page of a certificate
  6. 066. What official control measures at European scale
  7. 07Frequently asked questions
  8. 08Sources

The words "pesticide free" appear on plenty of product pages. They only become information from the moment a test report names what was looked for, down to what concentration, with which instrument and under which accreditation. This article describes that framework from the European texts and technical documents, without inventing their values.

> Key points > > - Regulation (EC) No 396/2005 sets the legal residue limits in food and feed. > - Default MRL: 0.01 mg/kg where the substance is not specifically named (European Commission). > - MRLs cover 315 products and around 1 100 pesticides. > - The reference method in official laboratories is tandem mass spectrometry, LC-MS/MS or GC-MS/MS. > - An official control laboratory must be ISO/IEC 17025 accredited, article 37 of Regulation (EU) 2017/625.

1. What an MRL is, and where it comes from

An MRL is the highest quantity of a pesticide residue legally tolerated in or on a food when the product has been used correctly. It is therefore not a health threshold: it is an agronomic ceiling, checked afterwards against consumer exposure.

Regulation (EC) No 396/2005 carries those limits for the whole Union and contains the provisions on official controls, as the European Food Safety Authority points out. The Commission page devoted to that legislation gives three useful orders of magnitude: MRLs apply to 315 fresh products and to the same products once processed, after correcting for dilution or concentration; the legislation covers around 1 100 pesticides used today or in the past in agriculture, inside the Union or outside it; and a default MRL of 0.01 mg/kg applies where a pesticide is not specifically mentioned.

That last sentence is the most important one for anyone reading a certificate. The absence of a dedicated line does not mean the absence of a rule: it points back to the default value, which sits at the lowest level analysis can measure reliably.

2. Where to read an MRL: the Commission database

The Commission publishes a pesticides database that lets you search for an active substance, or a food product, and obtain the corresponding MRLs. The same page warns that this database is made available for information only and has no legal force: the enforceable reference remains publication in the Official Journal of the European Union.

That database moves constantly. For the year 2025 alone, the Commission's legislation page lists about ten regulations amending annexes II, III, IV or V of Regulation 396/2005, for substances such as acetamiprid, deltamethrin or chlorpropham. A certificate dated 2024 was therefore not read against the same grid as a certificate dated 2026, which makes the test date as important as the result.

3. The method: LC-MS/MS, limit of quantification and identification

Official control laboratories work within document SANTE/11312/2021, in its version applicable from 1 January 2026, which sets method validation and analytical quality control. Three requirements are given as figures there, and they turn up at the foot of any serious test report.

CriterionSANTE/11312/2021 requirement
Mean recovery at validation70 to 120% for every substance in the method
Precision, repeatability (RSDr)less than or equal to 20%
Within-laboratory precision (RSDwR)less than or equal to 20%
Identification in MS/MS2 product ions, ion ratio within plus or minus 30% of the standards in the same sequence

The limit of quantification, written LOQ, is given a precise definition there: it is the lowest spiking level in the validation that still satisfies those performance criteria. In other words, an LOQ is not a declarative value. It is demonstrated, matrix by matrix.

The document cites liquid chromatography and gas chromatography coupled with tandem mass spectrometry as the techniques used to identify and quantify pesticides in food and feed. LC-MS/MS covers polar and heat-sensitive molecules, GC-MS/MS the volatile ones: a complete panel uses both. On a report, the words "LC-MS/MS" with no number of substances and no LOQ still say nothing.

4. Accreditation and its scope

Article 37 of Regulation (EU) 2017/625 requires laboratories designated for the official control of pesticide residues to be accredited to the ISO/IEC 17025 standard. Article 34 of the same text governs the methods used, which must comply with Union rules or with internationally recognised protocols.

Accreditation is not read like a label: it has a scope, that is a list of method-and-matrix pairs covered. A laboratory accredited for cannabinoids by HPLC is not automatically accredited for a multi-residue pesticide panel on a dry plant matrix. Our article on a laboratory's scope of accreditation sets out where that scope is checked, and the our laboratory page shows how the four blocks of a certificate follow one another: cannabinoids, terpenes, metals, pesticides.

5. Reading the "pesticides" page of a certificate

On one catalogue page, the flower Super Boof, batch PG-26-047F, states 9.6% CBD and 0.2% THC measured by HPLC, from a crop grown without synthetic pesticides. That is exactly the kind of statement a "pesticides" page turns into a verifiable fact, or leaves as a description. Four lines separate the two situations.

  • The list. How many substances were looked for, and which ones. A panel of a few molecules and a multi-residue panel do not answer the same question.
  • The limit of quantification. Expressed in mg/kg, per substance or per group. Without it, a "not detected" result has no scale.
  • The method. LC-MS/MS, GC-MS/MS, or both, with the test date.
  • The scope. The number and extent of the laboratory's accreditation, for this method and this matrix.

The same reasoning holds for resins, which the glossary defines as trichomes separated from the plant then pressed together, on the hashish entry. Neither colour, nor smell, nor price tells you anything about residues. Each reference in the CBD flowers category states its batch, and the Δ⁹-THC threshold applicable in France is set out in our article on the legal 0.30% limit.

6. What official control measures at European scale

The European Food Safety Authority publishes the results of those controls every year. The report released on 5 May 2026, covering 2024 data, rests on more than 125 000 samples collected across Europe.

Programme, 2024 dataSamplesCompliantNo measurable residueExceedances
EU coordinated sampling9 84298.8%43.1%2.4%, of which 1.2% non-compliant
National programmes (MANCP)86 44998.2%58.4%3.3%, of which 1.8% non-compliant

Those figures cover foodstuffs: aubergines, bananas, broccoli, mushrooms, grapefruit, melons, peppers, table grapes, virgin olive oil, wheat, bovine fat and hen eggs for the 2024 coordinated campaign. A CBD flower sold in France is not a foodstuff and appears in none of those plans; it is restricted to adults and is not intended for ingestion. The coordinated programme for 2026, 2027 and 2028 was set by implementing Regulation (EU) 2025/854 of 7 May 2025. Recurring questions on these subjects are gathered in the FAQ.

Frequently asked questions

Does a CBD flower have an MRL of its own?

Regulation 396/2005 sets MRLs for the 315 products on its list, which belongs to food and feed. We were not able to read, in an open and official source, a line naming the hemp flowering top intended for non-food use. That is precisely why a certificate has to name the reference grid it applies, rather than settle for a verdict.

What does 0.01 mg/kg mean on a certificate?

It is the default value the European Commission points to when a substance is not specifically mentioned in the regulation. On a test report, a figure of that order is most often the method's limit of quantification, that is the lowest validated level, and not a content found.

LC-MS/MS or GC-MS/MS: what is the difference?

Both couple a chromatographic separation with tandem mass spectrometry. The liquid route suits polar molecules or those with little heat stability, the gas route suits volatile molecules. Document SANTE/11312/2021 cites both, and a broad panel uses them together.

Does an accredited laboratory necessarily cover pesticides?

No. ISO/IEC 17025 accreditation bears on a list of methods and matrices, not on the laboratory as a block. You have to check that the method-and-matrix pair concerned really does appear in the published scope, and that the batch number on the report matches the one on the product bought.

Sources

Written by the Phytogrammes team

Every article in this journal draws on primary sources (ANSM, EFSA, EUR-Lex, peer-reviewed publications) and on the lab's own practice: batch-by-batch HPLC analyses, measured cannabinoid profiles. Our approach.

Article published on . CBD is not a medicine.