Pesticides in CBD flower: no MRL names the flower
Regulation (EC) No 396/2005 sets maximum residue levels (MRLs) for pesticides, one substance at a time, for the products listed in its Annex I. Hemp is listed twice, for its seeds and its leaves, and the flower appears nowhere. The "pesticides" page on a CBD flower certificate can therefore be checked only if it names the reference grid, the substances tested for, the limit of quantification and the method.

- 01What an MRL is, and where it comes from
- 02Where hemp appears in the list of products
- 03The default value and the date it was read
- 04The method: LC-MS/MS, GC-MS/MS and limit of quantification
- 05Accreditation and its scope
- 06Reading the "pesticides" page of a certificate
- 07What official EU controls measure
- 08Frequently asked questions
Key takeaways
- The EU sets MRLs for 315 products and around 1,100 pesticides, with a value of 0.01 mg/kg wherever no specific limit exists.
- Hemp has two codes: seeds (0401140) and leaves (0632010-045), the latter following the MRLs for strawberry leaves.
- Document SANTE/11312/2021, in the version applicable from 1 January 2026, governs how official laboratories validate their methods.
- Under Article 37 of Regulation (EU) 2017/625, an official control laboratory must hold ISO/IEC 17025 accreditation.
- In 2024, 98.8% of the 9,842 food samples taken under the EU coordinated programme complied with the limits.
What an MRL is, and where it comes from
An MRL is the highest pesticide residue level tolerated in or on a food after correct use of the product. It does not mark the point where toxicity begins: it is a ceiling set from good agricultural practice, then checked against consumer exposure.
Regulation (EC) No 396/2005 sets these limits across the Union. The Commission page on this legislation gives three orders of magnitude. MRLs apply to 315 fresh products, and to the same products after processing, corrected for dilution or concentration. Around 1,100 pesticides are covered, whether used now or in the past, in the Union or elsewhere. When a pesticide is not specifically mentioned, a default MRL of 0.01 mg/kg applies.
Article 18 of the regulation provides this default value. It covers Annex I products that have no specific limit for a given substance. The next question is whether the hemp flower appears in Annex I at all.
Where hemp appears in the list of products
Regulation (EU) 2018/62 rewrote Annex I, and hemp now appears there twice. Hemp seeds have their own code, 0401140, in the oilseeds group. Hemp leaves sit under code 0632010-045, in the group of herbal infusions from leaves and herbs, attached to the main product "strawberry leaves", so they follow the MRLs set for those leaves.
The flower has no entry, either in the group of herbal infusions from flowers or anywhere else in the annex.
The explanation is that Annex I lists food and animal feed. In France, a CBD flower sold in a shop is restricted to adults and is not meant to be eaten, so no MRL is assigned to it by name. A serious certificate therefore has to state the grid it compares its results against: the MRLs for hemp leaves, the default value of 0.01 mg/kg, or another reference.
The default value and the date it was read
The Commission runs a pesticides database in which you can look up an active substance or a product. According to the page, it is for information only and has no legal value; the Official Journal of the European Union remains the reference.
The grid changes over time. For 2025 alone, the Commission's legislation page lists about ten regulations amending the annexes of Regulation 396/2005, among them for acetamiprid, deltamethrin and chlorpropham. A certificate from 2024 was read against a different grid from one issued in 2026, so the test date matters as much as the result.
On a report, 0.01 mg/kg often stands for the method's limit of quantification. Readers easily take it for a level that was found, so it helps when the two figures sit in separate columns.
The method: LC-MS/MS, GC-MS/MS and limit of quantification
Official control laboratories validate their methods according to document SANTE/11312/2021, in its version applicable from 1 January 2026. The document sets four requirements in figures.
| Criterion | Requirement of document SANTE/11312/2021 |
|---|---|
| Mean recovery at validation | 70 to 120% |
| Repeatability (RSDr) | 20% at most |
| Within-laboratory reproducibility (RSDwR) | 20% at most |
| Identification by MS/MS | 2 product ions, ion ratio within 30% of that of the standards in the same sequence |
The document gives the limit of quantification (LOQ) a precise definition: the lowest spiking level in the validation that still meets these criteria. A laboratory has to demonstrate its LOQ, matrix by matrix; declaring one is not enough.
Two techniques do most of the work. Liquid chromatography coupled with tandem mass spectrometry (LC-MS/MS) covers polar or heat-sensitive molecules, and gas chromatography (GC-MS/MS) covers volatile ones. A broad panel combines the two. On a report, the words "LC-MS/MS" with no number of substances and no LOQ still tell you nothing.
Accreditation and its scope
Article 37 of Regulation (EU) 2017/625 sets the rule in paragraph 4, point (e): official laboratories work to the EN ISO/IEC 17025 standard and are accredited against it. Article 34 of the same text requires methods that follow Union rules or recognised performance criteria.
An accreditation has a scope, which is a list of method and matrix pairs, so it never covers everything a laboratory does. A laboratory accredited for cannabinoids by HPLC may hold no accreditation for a pesticide panel on dry plant material. Our guide to a laboratory's scope of accreditation shows where to check it, in five steps.
Reading the "pesticides" page of a certificate
Take one page from the catalogue. The Super Boof flower, batch PG-26-047F, shows a reference profile of 9.6% CBD and 0.2% Δ⁹-THC, with no laboratory certificate published. Its description mentions cold greenhouse growing without synthetic pesticides, which is a statement about a growing practice. Only a "pesticides" page can turn it into a measured fact, and our product pages do not yet display pesticide results. Four lines make the difference, here as at any other shop.
- The list: how many substances were tested for, and which. A panel of ten molecules and a panel of several hundred answer different questions.
- The limit of quantification, in mg/kg, per substance or per group. Without it, "not detected" has no scale.
- The method and the date: LC-MS/MS, GC-MS/MS or both, with the day of the test.
- The reference and the scope: the comparison grid chosen, and whether the laboratory is accredited for this method on this matrix.
The same reasoning holds for resins, which are trichomes separated from the plant and then pressed (see the hashish entry in the glossary). Colour, smell and price say nothing about residues. An "organic" claim is no substitute for the test either; our article on organic CBD flowers explains what the label guarantees. Each product in the CBD flowers category states its batch. For the other family of contaminants, see our article on heavy metals.
What official EU controls measure
Each year, EFSA publishes the results of residue controls in food. Its report released on 5 May 2026, on 2024 data, draws on more than 125,000 samples.
| Programme, 2024 data | Samples | Compliant | No quantifiable residue | Above the MRL |
|---|---|---|---|---|
| EU coordinated programme | 9,842 | 98.8% | 43.1% | 2.4%, of which 1.2% non-compliant |
| National programmes | 86,449 | 98.2% | 58.4% | 3.3%, of which 1.8% non-compliant |
A sample can exceed the MRL and still escape a non-compliance finding, because measurement uncertainty is taken into account before any conclusion. The 2024 coordinated programme covered twelve foods, including aubergines, bananas, table grapes, virgin olive oil, wheat and hen eggs. Implementing Regulation (EU) 2025/854 of 7 May 2025 set the programme for 2026 to 2028. None of these plans covers CBD flower, since it is not a food. For the THC threshold that does apply to it, see our article on the legal 0.30% limit. For the other lines of a certificate, see our guide on how to read a certificate of analysis.
Frequently asked questions
No. Annex I of Regulation 396/2005 names hemp seeds (code 0401140) and hemp leaves (code 0632010-045), and the flower is absent. The certificate therefore has to say which grid it compares its results against.
It is the default MRL that the regulation provides when a substance has no specific limit for a listed product. On a test report, a figure of that order is often also the method's limit of quantification, which is different from a level actually found.
Both pair chromatographic separation with tandem mass spectrometry. The liquid route suits polar or heat-sensitive molecules, and the gas route suits volatile ones. A broad panel combines the two.
No. ISO/IEC 17025 accreditation applies to a list of methods and matrices. Check that the method and matrix pair in question appears in the published scope, and that the batch number on the report matches your product. Measurement methods are described on the laboratory page.
Written by the Phytogrammes team
Each journal article draws on cited primary sources: ANSM, EFSA, EUR-Lex and peer-reviewed publications. Product profiles are distinguished from documented laboratory results. Our approach.
Article published on . CBD is not a medicine.