How every number on this page is set
The standard for each analyte is the strictest maximum level set by any credible government regulator — among them the European Union, Codex Alimentarius, the US FDA, Australia/New Zealand, the Gulf states (GSO), and the national authorities of every jurisdiction that regulates the product — converted into Cephalopods (octopus, squid, cuttlefish)’s own as-consumed basis. It is a lookup of sovereign law, carrying at most one disclosed basis conversion where the law is written in another basis, and an explicit read-across where no government regulates the exact product. A certified product sits at or below every applicable sovereign limit at once.
Where no government regulates the exact product for an analyte, the standard does not go blank or invent a number: the limit is read across from the nearest government value for an analogous product, so a certified product still sits at or below a real sovereign limit. The ratchet tightens these after publication as surveillance warrants.
Master Limit Table
All values in ppb (µg/kg), as-consumed basis. 6 of 11 analytes carry a firm ceiling; the remainder are governed by mandatory control or reflex-speciation screening with no standalone number, itemised in the derivation below. A brand meeting every firm value on a like-for-like basis, and passing every control, qualifies for the mark.
| Analyte | Tier | HMTc limit | Binding basis |
|---|---|---|---|
| Lead (Pb) | Tier 1 | 300 | strictest government ML (EU) |
| Inorganic arsenic (iAs) | Tier 1 | 50 | strictest government ML (EU) |
| Total arsenic (tAs) | Tier 2 | 1000 | strictest government ML (AU/NZ) |
| Mercury, total (tHg) | Tier 1 | 300 | strictest government ML (EU) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Cadmium (Cd) | Tier 1 | 1000 | strictest government ML (EU) |
| Nickel (Ni) | Tier 2 | n/m | not material — controlled analyte (see note) |
| Total chromium (Cr) | Tier 2 | 12000 | strictest government ML (India) |
| Hexavalent chromium (Cr-VI) | Tier 2 | n/m | not material — controlled analyte (see note) |
| Tin (Sn) | Tier 2 | n/m | not material — controlled analyte (see note) |
| Aluminium (Al) | Tier 2 | n/m | not material — controlled analyte (see note) |
Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Ni, Cr, Cr-VI, Sn, Al) carry a 150% transitional allowance under the program’s Status A–E framework. Mercury is limited in both forms: total mercury (tHg) and methylmercury (MeHg) are separate ceilings that must both be met. Total arsenic (tAs) operates as a reflex screen to inorganic-arsenic (iAs) speciation, since most arsenic in seafood is non-toxic organic arsenobetaine. Tin (Sn) is material only for canned product, where it migrates from the can; for non-canned seafood it is controlled by screen, not limited.
Derivation — every government’s number, side by side
The full derivation for Cephalopods (octopus, squid, cuttlefish). Each row lists every government maximum level in force worldwide, converted to the as-consumed basis; the HMTc limit is the strictest of them, and the last column names which sovereign law binds. A blank cell means that government sets no limit for this analyte in this product.
| Analyte | EU | AU/NZ | GSO | India | Mercosur | Costa Rica | Fiji | Guyana | Israel | Mexico | Panama | Philippines | Paraguay | Singapore | Thailand | Vietnam | HK | HMTc | Binds |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Lead (Pb) | 300 | — | 1000 | 1000 | 1000 | 1000 | 1000 | 1000 | 300 | — | 1000 | — | 1000 | — | — | 1000 | — | 300 | EU |
| Inorganic arsenic (iAs) | 50 | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | 50 | EU |
| Total arsenic (tAs) | — | 1000 | — | 86000 | 1000 | — | — | — | — | 80000 | — | — | 1000 | 1000 | — | — | — | 1000 | AU/NZ |
| Mercury, total (tHg) | 300 | — | — | 500 | 500 | 500 | — | 500 | — | — | — | — | 500 | — | — | — | — | 300 | EU |
| Methylmercury (MeHg) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | n/m³ | controlled |
| Cadmium (Cd) | 1000 | — | 2000 | 2000 | 2000 | 1000 | 1000 | 1000 | 1000 | — | — | 2000 | 2000 | — | 2000 | 2000 | 2000 | 1000 | EU |
| Nickel (Ni) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | n/m³ | controlled |
| Total chromium (Cr) | — | — | — | 12000 | — | — | — | — | — | — | — | — | — | — | — | — | — | 12000 | India |
| Hexavalent chromium (Cr-VI) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | n/m³ | controlled |
| Tin (Sn) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | n/m³ | controlled |
| Aluminium (Al) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | n/m³ | controlled |
All values µg/kg (ppb), as-consumed basis. ² no government sets this analyte for this exact product form: the value is read across from the nearest government limit for an analogous product, or — where the Binds column reads occurrence or precautionary — taken from measured occurrence data or set as a precautionary near-neighbour value; the ratchet tightens it as surveillance warrants. ³ not material in this matrix: controlled by reflex speciation or packaging control, not a standalone number.
Occurrence and derivation rationale
For each analyte on the panel: what the peer-reviewed and survey literature measured in this category, cited one way to the Heavy Metal Index, and the Method v2.0 reasoning behind the certification limit — including, where no government sets a number, why the program sets one anyway. Occurrence figures are literature findings; the derivation is the certifier's.
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 300 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why lead is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 50 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why inorganic arsenic is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 1 mg/kg (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why total arsenic is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 300 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why total mercury is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets no standalone methylmercury limit for Cephalopods. Methylmercury is the organomercury speciation of total mercury and is arithmetically bounded by it (MeHg <= tHg). The binding total-mercury ceiling for this subcategory (300) is equal to or stricter than the lowest applicable sovereign methylmercury ML for this product, so passing the total-mercury limit guarantees methylmercury compliance and no separate methylmercury ceiling is published. Audit-affirmed. The analyte is controlled by Total-mercury screen; reflex MeHg speciation is optional and cannot exceed the tHg ceiling, not a standalone number. Why methylmercury is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 1 mg/kg (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why cadmium is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets no standalone tin limit for Cephalopods. Fresh/frozen seafood has no tinplate contact; inorganic tin is a can-migration analyte. A full register Sn sweep shows every seafood tin ML is canned/tinplate-migration scope; no sovereign sets a non-canned seafood tin matrix limit. Canned product is certified under the canned-seafood subcategory tin limit. The analyte is controlled by ICP-MS per EN 15763 / AOAC 2015.01; applies only if canned, not a standalone number. Why tin is limited →
Source regulations
Every published government regulation weighed to set this standard, evaluated against each other. The strictest applicable maximum level binds each analyte; the rest are comparators, and where no government regulates the exact product the value is read across from the nearest government limit. Follow a reference for the source document and its per-analyte limits — the Derivation table above shows every value side by side.
| # | Regulation | Year | Instrument | Role in this standard |
|---|---|---|---|---|
| 1 | Commission Regulation (EU) 2023/915 and (EU) 2025/1891 | 2023 | Maximum levels | Binds lead, inorganic arsenic, total mercury, cadmium |
| 2 | FSSAI (Contaminants, Toxins and Residues) Regulations | 2011 | Maximum levels | Binds total chromium; Comparator for lead, total arsenic, total mercury, cadmium |
| 3 | FSANZ Food Standards Code — Schedule 19 | 2015 | Maximum levels | Binds total arsenic |
| 4 | GSO 193 — Gulf Technical Regulation | 2021 | Maximum levels | Comparator for lead, cadmium |
| 5 | Costa Rica RTCR 409:2008 — Reglamento de límites de contaminantes | 2008 | Maximum levels | Comparator for lead, total mercury, cadmium |
| 6 | Fiji Food Safety Regulations | 2009 | Maximum levels | Comparator for lead, cadmium |
| 7 | Guyana Fisheries Products Regulations | 2023 | Maximum levels | Comparator for lead, total mercury, cadmium |
| 8 | Israel Food Contaminants Standard (FCS) | 2016 | Maximum levels | Comparator for lead, cadmium |
| 9 | MERCOSUR GMC Resolución 12/2011 | 2011 | Maximum levels | Comparator for lead, total arsenic, total mercury, cadmium |
| 10 | Mexico NOM-242-SSA1-2009 | 2009 | Maximum levels | Comparator for total arsenic |
| 11 | Panama Resolución 368/2009 | 2009 | Maximum levels | Comparator for lead |
| 12 | Philippines PNS/BAFS 194:2017 | 2017 | Maximum levels | Comparator for cadmium |
| 13 | Paraguay Decreto 1335/2019 | 2019 | Maximum levels | Comparator for lead, total arsenic, total mercury, cadmium |
| 14 | Singapore Food Regulations | 2023 | Maximum levels | Comparator for total arsenic |
| 15 | Thailand MOPH Notification No. 414 | 2020 | Maximum levels | Comparator for cadmium |
| 16 | Vietnam QCVN 8-2:2011/BYT | 2011 | Maximum levels | Comparator for lead, cadmium |
Cite this standard
Pendergrass, K. “Cephalopods (octopus, squid, cuttlefish).” In Heavy Metal Tested & Certified (HMTc) Seafood standard, version 1.0. Institute of Contaminant Standards (ICS), 2026. DOI: registration pending.
The literature baseline for every analyte is maintained independently at the Heavy Metal Index. This certification standard applies those findings; the two are kept editorially separate by design.
Version history
The dated editions of this standard. Each is kept at a stable permalink, so a regulator or brand can reconstruct exactly what the standard required on any date — the edition record, not an editorial commit trail. Version-pinned DOIs link here once each edition is deposited.
| Version | Date | Status | What changed |
|---|---|---|---|
| v1.0 | 2026-08-07 | current | Initial publication. New subcategory created after adversarial audit found octopus/squid/cuttlefish fell between the fish and shellfish subcategories. Government-limit standard (Method v2.0), as-consumed: inorganic arsenic 50 (EU 2025/1891 — the strictest iAs in all of seafood), methylmercury by disclosed read-across from the non-predatory fishery value. |