Alkaloid Controls in Lupins 2026: What Producers and Importers Must Do

Key data

Producers, importers and processors of lupins and their derivatives have had a clear signal from the European Commission since 16 October 2026: controls on quinolizidine alkaloids are being intensified. The Recommendation (EU) 2026/2353 does not impose direct fines today, but anyone who does not adapt their processes now risks being excluded from the market when binding regulation arrives.

Quinolizidine alkaloids are natural toxic compounds present in bitter varieties of lupins. They can cause poisoning in both humans and animals, making this ingredient—increasingly used in plant-based food and feed—a priority regulatory focus for the EU.

What does this regulation establish?

Recommendation (EU) 2026/2353 articulates three main mandates directed at Member States and food chain operators:

• Intensification of analytical control: The competent authorities of each Member State—in Spain, the Spanish Food Safety and Nutrition Agency (AESAN) and the autonomous communities—must design specific sampling and analysis programmes to detect quinolizidine alkaloids in lupins intended for human consumption and in derived feeds.
• Reporting of results to the Commission: Data obtained in sampling programmes must be communicated to the European Commission. These results will serve to assess whether the levels of presence pose a significant risk and, if so, activate binding regulation with mandatory maximum limits.
• Strengthening of self-control by operators: Manufacturers of food and feed using lupins or their derivatives must strengthen their self-control and traceability systems to ensure that products do not exceed recommended safety thresholds.

The regulation distinguishes two areas of application with different dynamics:

Economic and operational impact

As it is a recommendation and not a regulation, there are no direct sanctions for non-compliance at this time. However, the operational impact is real and immediate for several reasons:

• Cost of additional analyses: Operators will need to incorporate quinolizidine alkaloid analysis into their self-control protocols. Depending on production volume and number of batches, this represents a recurring analytical cost that was not systematically required until now.
• Investment in traceability: Strengthening traceability systems involves updating records, procedures and, in some cases, batch management software.
• Risk of market exclusion in the short term: If monitoring data reveals significant risks, the Commission can activate mandatory maximum limits with very tight adaptation timelines. Companies that have already implemented controls will be in a position of advantage.
• Pressure from customers and distributors: Large distributors and industrial buyers anticipate binding regulation and may require certifications or analytical results before they are legally mandatory.

Who does it affect?

• Agricultural producers who grow lupin varieties, especially bitter varieties with higher alkaloid concentrations.
• Importers of lupins or derivatives from third countries (Portugal, Australia, Chile and other major world producers).
• Food processors and manufacturers who use lupin flour, lupin protein or other derivatives as an ingredient in products for human consumption (bakery, snacks, gluten-free products, meat substitutes).
• Feed manufacturers who incorporate lupin cake or flour as a protein source in animal feed.
• Wholesale distributors and importers of agricultural raw materials with lupins in their catalogue.
• Spanish competent authorities (AESAN, autonomous communities) that must design and execute sampling programmes and report results to the Commission.

Practical example

A manufacturer of protein snacks that uses lupin flour as the main ingredient in its gluten-free product line must act on two fronts:

First, in self-control: until now its raw material analyses probably did not systematically include quinolizidine alkaloids. Following Recommendation (EU) 2026/2353, it must incorporate this parameter into its supplier control and finished product plan, especially if it works with lupin varieties of non-certified origin as "sweet" (low in alkaloids).

Second, in traceability: it must be able to identify, for each batch of finished product, the origin of the lupins used, the variety and the associated analytical results. If a batch exceeds the recommended safety thresholds, traceability allows for a quick and limited withdrawal, avoiding massive market withdrawals that can cost tens of thousands of euros.

If the company imports lupin flour from an Australian supplier, it must also ensure that the supplier provides it with analytical data on alkaloids, or carry out the analyses at destination before incorporating the raw material into production.

What should companies do now?

1. Review whether lupins are present in your supply chain — as a direct ingredient, as a component of feed or as an imported raw material. If so, this recommendation affects you.
2. Update the self-control plan to include analysis of quinolizidine alkaloids in lupins and derivatives, both in raw materials and in finished products.
3. Contact suppliers to request certifications or analytical results on the alkaloid content in the supplied batches, especially if they come from varieties not certified as "sweet".
4. Strengthen the traceability system to be able to associate each batch of final product with the origin and analytical data of the lupins used.
5. Closely follow the sampling programmes of AESAN and autonomous communities — the results of these programmes will determine whether the Commission activates binding regulation with mandatory maximum limits.
6. Consult with a food safety advisor to assess whether current protocols are sufficient or whether additional investments in laboratory or management software are required.

Official source

Consult full regulation at 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_202602353