Alkaloids in lupins 2026: what producers and processors must control

Key data

Producers, processors and importers of lupins have a clear signal from the European Commission on the table: quinolizidine alkaloids in these products are under regulatory scrutiny. The Recommendation (EU) 2026/1241, published on 15 June 2026 and in force since 11 June, does not impose direct sanctions, but establishes the technical bases that Member States will use in their inspections. Ignoring it means assuming an avoidable operational and commercial risk.

Lupins are a legume with growing presence in the food industry: flours, plant-based beverages, snacks and gluten-free products incorporate them as an ingredient. Precisely this growth has put on the EU's radar the need to control the alkaloid levels they naturally contain.

What does this regulation establish?

Recommendation (EU) 2026/1241 addresses three main axes:

• Object of control: presence of quinolizidine alkaloids in fresh, dried, processed lupins and in all foods containing them as an ingredient.
• Sampling and analysis methods: the recommendation sets technical guidance on how samples should be taken and what analytical methods should be used to assess product compliance.
• Reference levels: establishes reference values to determine whether a product is compliant. These levels are the tool that official inspectors from Member States will use to assess whether a batch complies or not.

The non-binding nature of a European recommendation should not be confused with irrelevance. In EU regulatory practice, recommendations typically precede mandatory regulations. Furthermore, national official controls can already be based on these reference levels to withdraw products from the market or require corrections.

Quinolizidine alkaloids are nitrogen-containing compounds naturally present in lupins. In high quantities, they can cause acute toxicity in humans and animals, with symptoms ranging from nausea and tachycardia to more serious conditions. "Sweet" varieties of lupin have low concentrations, but improper processing or mixing with bitter varieties can raise levels to dangerous ranges.

Economic and operational impact

The immediate impact is not a direct fine, but an operational adaptation cost and a commercial risk if official controls detect non-compliance. Companies should consider:

• Cost of analysis and sampling: implementing control protocols for quinolizidine alkaloids involves investing in accredited laboratory testing. The cost varies depending on production volume and required sampling frequency.
• Risk of product withdrawal: if a batch exceeds reference levels in an official control, it can be withdrawn from the market, with the economic and reputational cost that entails.
• Pressure in the supply chain: distributors and retailers will increasingly demand certifications or analytical results from their lupin and derivative suppliers, especially if they operate in markets with frequent inspections.
• Anticipation of binding regulation: companies that adapt their processes now will avoid urgent adaptation costs when the recommendation becomes a mandatory regulation.

Who does it affect?

• Agricultural producers of lupins, especially those working with varieties not certified as "sweet".
• Processing industry that produces flours, proteins, plant-based beverages, snacks, pasta or any product that incorporates lupin as an ingredient.
• Importers of lupins or derivatives from third countries, where controls at origin may be less strict.
• Distributors and food chain operators that market these products in the European market.
• Manufacturers of gluten-free foods and plant-based products, segments where lupin has a growing presence as a protein substitute.

Practical example

A Spanish company that manufactures lupin plant-based beverages and distributes them in supermarkets receives an official inspection from the regional food authority. The inspector applies the sampling methods and reference levels established in Recommendation (EU) 2026/1241. If the analyzed product exceeds the reference level for quinolizidine alkaloids, the authority can order the withdrawal of the batch from the market and require a review of the production process.

If that same company had previously implemented an internal analytical control protocol based on the recommendation, it would have detected the problem before commercialization, avoiding the withdrawal, reputational cost and possible alert in the EU RASFF food safety alert system.

What should companies do now?

1. Review quality control processes: identify at which points in the production chain lupins are incorporated and whether there are analytical controls for quinolizidine alkaloids.
2. Consult the sampling and analysis methods established in the recommendation and verify whether the laboratories the company works with are accredited to perform these tests.
3. Know the reference levels set in Recommendation (EU) 2026/1241 and compare them with current analytical results of the products.
4. Require documentation from suppliers: if lupins or derivatives are purchased from third parties, request analytical results that prove compliance with reference levels.
5. Update the traceability system to be able to quickly identify and withdraw any batch that could exceed the established levels.
6. Monitor regulatory developments: this recommendation anticipates possible binding regulation. Being prepared now reduces the cost of future adaptation.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601241