Contaminants maturity · Regulation (EU) 2023/915 · Chemical risks
Your control of chemical contaminants, measured against Regulation 2023/915 and turned into an action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Contaminants maturity · Regulation (EU) 2023/915 · Chemical risks
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Commission Regulation (EU) 2023/915 of 25 April 2023 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism (a level, the level above, and the action linking the two) is what turns a finding into a trajectory.
Is the contaminant surveillance plan based on a documented and reviewed risk analysis?
- N1
No formalised contaminant risk analysis. Analyses are carried out at a customer’s request or following an incident.
- N2
An analytical plan exists, but its rationale is not written down. Frequencies are carried over year after year without review.
- N3
The risk analysis is documented by material/product pairing and justifies the contaminants selected and the frequencies. It is reviewed annually.
- N4
The review systematically incorporates the year’s analytical results, changes in origin and regulatory developments. Decisions to amend the plan are recorded and approved.
- N5
The risk analysis draws on multi-year trends, sector data and external alerts. Frequencies are adjusted by proven risk level, with documented tracking of reviews.
Action to move from L2 to L3
Formalise the contaminant risk analysis by material/product pairing, drawing on origin, process and analytical history from the last three campaigns, use it to derive the surveillance plan frequencies, and put its review on the agenda of the annual quality review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2023/915 sets the maximum levels applicable to certain contaminants in food. It came into application on 25 May 2023 and repealed Regulation (EC) No 1881/2006, whose structure it retains while clarifying it. Annex I covers, among others, metals (lead, cadmium, mercury, inorganic arsenic, inorganic tin), mycotoxins, processing contaminants such as polycyclic aromatic hydrocarbons, acrylamide or 3-MCPD and its esters, nitrates, dioxins and PCBs, erucic acid, and tropane, pyrrolizidine and opium alkaloids. It works alongside Regulation (EEC) No 315/93, which sets out the ALARA principle and prohibits placing food with an unacceptable contaminant level on the market.
In practice, the difficulty is not knowing the maximum levels: they are published. It is demonstrating, material by material and batch by batch, that the control system genuinely covers the scope. Is the analytical surveillance plan built on a documented risk analysis, or carried over year after year out of habit? Do supplier specifications reflect the levels applicable to the finished product, or only a general mention of regulatory compliance? What exactly happens when a result exceeds the internal alert threshold without reaching the maximum level? Who decides, within what timeframe, and with what record.
One confusion recurs often: the maximum levels in Regulation 2023/915 do not add up with the maximum residue limits for pesticides under Regulation (EC) No 396/2005, nor with veterinary medicine limits. These are three separate systems, each with its own sampling plans, methods and interpretation rules. Another point of vigilance: the regulation is regularly amended by implementing acts that lower existing levels or introduce new ones. Regulatory monitoring, incorporating updates into specifications, and requalifying the materials concerned are as much part of the system as the analysis itself.
A compliance audit ends with a binary finding: the level is met or it is not, the record exists or it is missing. The maturity assessment asks a different question: what level of control has the organisation reached, and what precise action moves it to the next level. A site may have no exceedances and still rest on a fragile system, dependent on one person or a single laboratory. The assessment makes that fragility visible before a non-conforming result reveals it.
In Datamensio, the framework is ready to use and adaptable. The AI adjusts the themes, questions and levels to your sector, dairy products, cereals, seafood, oils or infant food, or builds a variant from your control plans and specifications. Assessments carried out across multiple sites can be compared with each other and over time.
Reference standard: Commission Regulation (EU) 2023/915 of 25 April 2023
The themes assessed
Contaminant risk analysis
Identification of relevant contaminants by material/product pairing, consideration of geographic origin, process and historical data, formalisation and review frequency.
Surveillance and sampling plan
Construction of the analytical plan, frequencies, representativeness of sampling, compliance with applicable sampling rules, coverage of raw materials, finished products and process stages.
Supplier and raw material control
Contractual specifications reflecting applicable levels, certificates of analysis, supplier approval and evaluation, goods-in checks, management of at-risk origins.
Laboratories and analytical methods
Laboratory accreditation, suitability of quantification limits against regulatory levels, method performance criteria, taking measurement uncertainty into account in decision-making.
Processing contaminants
Control of acrylamide, PAHs, 3-MCPD and its esters, glycidyl esters, cooking, refining and smoking parameters, mitigation measures and verification of their effectiveness.
Result interpretation and decision-making
Internal alert thresholds, decision rules when a level is exceeded, batch hold and release, recall and withdrawal, notification of competent authorities.
Regulatory monitoring and updates
Tracking acts amending the annexes, time taken to incorporate them into specifications and control plans, management of transitional provisions and affected stock.
Traceability and documentation
Linking analytical results to batches, record retention, upstream and downstream traceback capability, evidence available for an official inspection.
Skills and responsibilities
Defined roles for release decisions, training of quality and production teams, dependency on a key person, cover arrangements.
Continuous improvement and the ALARA principle
Use of analytical trends, actions to reduce levels beyond strict threshold compliance, lessons learned, comparison between sites and over time.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does the assessment issue a certificate of compliance with Regulation 2023/915?
No. Datamensio measures the level of control and prepares for inspection. Compliance with the regulation is a matter for the competent authorities under the official controls set out in Regulation (EU) 2017/625, and where applicable for certification bodies for private standards.
What is the difference between this assessment and a compliance audit?
The audit checks that maximum levels are met and that records exist, then concludes with a gap or a compliance finding. The assessment places your practices on a progressive scale and identifies the action that moves you up a level. The two complement each other: the assessment prepares for the audit, the audit validates.
How long does the assessment take?
The short version can be completed in 20 to 30 minutes by a quality manager. The full version, run collaboratively with quality, procurement and the laboratory, typically spans one to two weeks, most of the time being spent gathering control plans and analytical results.
Does the framework also cover mycotoxins?
Mycotoxins appear in Annex I of Regulation 2023/915 and are addressed in this assessment as part of the risk analysis and surveillance plan. A dedicated framework exists for organisations wanting to go deeper specifically into this area, with its own sampling rules and upstream prevention measures.
Can the framework be adapted to our sector?
Yes. The questions, levels and themes can be modified, and the AI generates a variant adapted to your sector or product categories from your control plans and specifications. You retain ownership of the framework.
How can several production sites be compared?
Assessments carried out across multiple business units can be compared by theme and over time. The gap to the target level generates the action plan, which the AI groups into a prioritised roadmap, and a cross-site roadmap consolidates actions common to several sites.
Is analytical expertise needed to answer?
The questions address how the system is organised, not analytical chemistry. Some require input from the laboratory manager or procurement: the collaborative mode allows these questions to be assigned to the right person.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.