Unrecorded alcohol comprises all types of alcohol that is not registered in the jurisdiction where it is consumed. In some countries in Central and Eastern Europe as well as the Balkans, the majority of unrecorded alcohol consumption may derive from the home production of fruit spirits. Some studies found a high prevalence of lead and cadmium in such spirits. This article provides a quantitative comparative risk assessment using the margin of exposure (MOE) methodology for lead and cadmium, compared to ethanol, for unrecorded fruit spirits. For average concentration levels, the lowest MOE (0.8) was calculated for ethanol (alcohol itself). For lead, the MOE was 13 for moderate daily drinking and 0.9 for the worst-case scenario. For cadmium, the MOE was 1982 for moderate daily drinking and 113 for the worst-case scenario. The results of this study are consistent with previous comparative risk assessments stating that ethanol itself comprises by far the highest risk of all compounds in alcoholic beverages. Regarding metal contaminants, the risk of cadmium appears negligible; however, lead may pose an additional health risk in heavy drinking circumstances. Strategies to avoid metal contamination in the artisanal home production of spirits need to be developed.