What Rudy’s Law requires
Maryland House Bill 97, known as Rudy’s Law, applies to manufacturers of baby food sold or distributed in Maryland. It is summarized here for orientation; this page is not legal advice, and a brand should confirm its obligations with its own counsel and against the enacted text.
As the law is written, a covered manufacturer must:
- Test a representative sample of each production aggregate of its final baby food product for four toxic elements, arsenic, cadmium, lead, and mercury, at least once a month, beginning January 1, 2025.
- From January 1, 2026, make the results publicly available on its website for each baby food product offered for sale in Maryland: the name and level of each toxic heavy metal found in the final product, enough information to let a consumer identify the product (such as the product name, universal product code, or lot or batch number), and a link to the FDA guidance on the health effects of toxic heavy metals in children.
- Include a scannable QR code on the label of a product that is subject to an actionable heavy-metal limit, linking to that information.
Maryland’s law phases in: the testing obligation began in 2025, and the public website disclosure begins in 2026. As with California, Rudy’s Law settles what is tested and disclosed by statute. The testing happens and the results are disclosed; what remains open is what a brand does with the results.
What Rudy’s Law does not cover
“Baby food” under Rudy’s Law means food packaged in a jar, pouch, tub, or box, sold specifically for babies and children under two years of age. Infant formula is explicitly excluded, following the federal definition. A formula brand is not covered by this law and should not treat this page as if it were.
Coverage is specific to Maryland. A brand selling nationally faces Maryland’s obligation for its Maryland distribution and California’s separate AB 899 obligation for its California distribution, on top of the broader regulatory and litigation environment everywhere else. The two state laws are closely aligned in substance, which is why one control program can serve both, but each is its own legal duty.
What HMTc adds, and what it does not replace
Rudy’s Law mandates the monthly testing and the disclosure. It does not tell a brand how to bring a result down, how to verify that a correction held, or how to turn a compliant result into a claim a retailer or a consumer can check. That is the gap Heavy Metal Tested & Certified is built to close.
- The monthly, per-aggregate testing Rudy’s Law requires is close to the per-lot testing HMTc certification relies on, so a brand meeting the law is already generating much of the data a certification uses.
- When a result does not meet a limit, the readiness and corrective-action pathways turn it into a defined investigation, a root-cause correction, and a verified retest.
- Certification produces an independently verified, product-specific claim against a published limit, on top of the disclosure the law already requires.
The boundary is firm. HMTc certification does not satisfy, replace, or discharge the Rudy’s Law obligation. A covered brand remains responsible for its own statutory testing, its website disclosure, and its label QR code where required. HMTc is not legal advice and does not determine a brand’s reporting, disclosure, recall, or contractual obligations. The program is a way to turn mandated data into correction and a verified claim, not a substitute for compliance.
A widening state patchwork
Maryland and California now both require baby-food heavy-metal testing and disclosure, and other states are moving. For a brand selling nationally, the practical consequence is that the testing and disclosure obligations are arriving one jurisdiction at a time, with aligned but separate rules. A single control and verification program is one way to meet the shared substance of those obligations without rebuilding for each state, though it never removes the duty to comply with each on its own terms.
Begin by finding the standard that applies to your product. No company name is required to look one up.