Cannabis tinctures and sublingual oils — HMTc Standard

How limits are set

Cannabis has no uniform federal contaminant limit. Its heavy-metal ceilings are the route-split action levels of the credible sovereign cannabis programs — California (DCC 2026), Colorado (2022), Massachusetts (2020), Maryland (2025), Nevada (2020), and Israel (IMC-GMP 152, 2016). For each analyte the HMTc limit is the strictest maximum any of these governments sets for the product's administration route. The route basis is never conflated: the strict inhaled arsenic and cadmium action levels are never applied to an edible or a topical, and a permissive topical lead level is never applied to inhaled flower. It is a lookup, not a computation; occurrence never selects a value.

Four analytes bind directly to a sovereign action level — lead, cadmium, total arsenic, and total mercury. Total chromium is recorded as a screening ceiling rather than a health limit: it is dominated by benign trivalent chromium while the health-relevant species is hexavalent chromium, so the total-chromium action level is non-protective as a ceiling and any quantifiable Cr(VI) fails certification. Nickel, tin, and aluminium, which no cannabis program regulates for content, are held under mandatory analytical control; inorganic arsenic, methylmercury, and hexavalent chromium are enforced by reflex speciation against their measured total. Certification is heavy-metal safety only and does not endorse the efficacy or the legality of these products.

Master Limit Table

All values in ppb (µg/kg), as-sold basis. 7 of 11 analytes carry a firm ceiling; the remaining 3 are toxic species bounded by their parent totals (species ≤ total, measured on every lot), so every analyte carries an enforceable ceiling. A brand meeting every value on a like-for-like basis qualifies for the mark.

Every claim analyte is equal at the gate. A product is certified only when every analyte is at or below 100% of its published government floor or disclosed read-across; above the limit, on any metal, it is not certified and carries no mark.

Derivation

For Cannabis tinctures and sublingual oils, each HMTc limit is the strictest maximum level any credible government sets for the product, named in the Binding column with the count of jurisdictions that concur at that value. Where no government regulates the analyte, the cell is a mandatory control or a not-material determination, never an invented number.

Risk Flag

On the published occurrence literature to date, Cannabis tinctures and sublingual oils shows no systematic gap between typical market levels and the limit — the limit being the strictest government maximum for the product (Method v2.0). Certification is decided on a product’s own tested result, not on a distribution; an individual lot or supplier can still exceed a limit.

See the cross-category summary of the ingredients that most often struggle.