How limits are 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 Cocoa and chocolate products (cocoa powder, dark, milk, chips)’s own as-sold 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-sold basis. 5 of 11 analytes carry a firm ceiling; the remaining 6 are governed by mandatory control or the total-metal screen 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 | 200–400 | strictest government ML, set by product form (see derivation) |
| Cadmium (Cd) | Tier 1 | 100–300 | strictest government ML, set by product form (see derivation) |
| Total arsenic (tAs) | Tier 2 | 200–400 | strictest government ML, set by product form (see derivation) |
| Inorganic arsenic (iAs) | Tier 1 | control | mandatory control: no government ML; screened every lot (see note) |
| Mercury, total (tHg) | Tier 1 | 50 | strictest government ML (Vietnam) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material: controlled analyte (see note) |
| Nickel (Ni) | Tier 2 | 2500–15000 | strictest government ML, set by product form (see derivation) |
| Tin (Sn) | Tier 2 | n/m | not material: controlled analyte (see note) |
| Aluminium (Al) | Tier 2 | n/m | not material: controlled analyte (see note) |
| Total chromium (Cr) | Tier 2 | control | mandatory control: no government ML; screened every lot (see note) |
| Hexavalent chromium (Cr-VI) | Tier 2 | control | mandatory control: no government ML; screened every lot (see note) |
Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Ni, Sn, Al, Cr, Cr-VI) are held to the same government limit: tiering sets how the program reacts to an exceedance, not any permission to exceed it. A product is certified only when every analyte is at or below 100% of its published limit; above the limit, on any metal, it is not certified and carries no mark.
Derivation
For Cocoa and chocolate products (cocoa powder, dark, milk, chips), 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.
| Analyte | HMTc | Binding | Basis |
|---|---|---|---|
| Lead (Pb) | 200–400 | by product form (below) | sovereign ML, form-specific |
| Cadmium (Cd) | 100–300 | by product form (below) | sovereign ML, form-specific |
| Total arsenic (tAs) | 200–400 | by product form (below) | sovereign ML, form-specific |
| Inorganic arsenic (iAs) | control | screened every lot | mandatory control: no government ML |
| Mercury, total (tHg) | 50 | Vietnam | direct sovereign ML |
| Methylmercury (MeHg) | n/m | ≤ tHg | not material in this matrix |
| Nickel (Ni) | 2500–15000 | by product form (below) | sovereign ML, form-specific |
| Tin (Sn) | n/m | controlled | not material in this matrix |
| Aluminium (Al) | n/m | controlled | not material in this matrix |
| Total chromium (Cr) | control | screened every lot | mandatory control: no government ML |
| Hexavalent chromium (Cr-VI) | control | screened every lot | mandatory control: no government ML |
Form-specific limits
Where a government sets the maximum by product sub-form, the HMTc column above shows the range and the exact ceiling for each form is listed here. A certified product meets the ceiling for its own form.
| Product form | HMTc (µg/kg) | Binding jurisdiction |
|---|---|---|
| milk chocolate with <30% total dry cocoa solids | 2500 | EU |
| milk chocolate with >=30% total dry cocoa solids, and chocolate | 7000 | EU |
| cocoa powder / fat-reduced cocoa powder (drinking chocolate) | 15000 | EU |
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.
7 studies in the certified-market pool measured lead in Chocolate across 234 certified-market samples. The pooled distribution centres on a median of 46 ppb and reaches 1.3 mg/kg at the 95th percentile. Hands 2024, Burgon 2023, Amjad 2021, FDA 2018, Fechner 2022, Oliveira 2021, Elsheikh 2020.
HMTc sets 200 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 2.1 mg/kg, at or above the government ceiling of 200 ppb, so the government maximum binds. Why lead is limited →
8 studies in the certified-market pool measured cadmium in Chocolate across 554 certified-market samples. The pooled distribution centres on a median of 126 ppb and reaches 1.7 mg/kg at the 95th percentile, with a measured maximum of 2.3 mg/kg. Kataoka 2018, Hands 2024, Burgon 2023, Amjad 2021, Bravo 2024, Marincich 2023, Fechner 2022, Oliveira 2021.
HMTc sets 100 ppb (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 →
2 studies in the corpus measured total arsenic in Chocolate (55 samples reported across those studies): Hands 2024, Burgon 2023. Reported concentrations range from 50 ppb to 200 ppb, with a typical value of 50 ppb.
HMTc sets 200 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 arsenic is limited →
6 studies in the corpus measured total mercury in Chocolate (5502 samples reported across those studies): ANSES 2026, Burgon 2023, FDA 2018, Fechner 2022, Vitola 2016, FSANZ 2011.
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 total mercury is limited →
2 studies in the certified-market pool measured nickel in Chocolate across 520 certified-market samples. The pooled distribution centres on a median of 756 ppb and reaches 7.3 mg/kg at the 95th percentile. BFR 2022, Amjad 2021.
HMTc sets 2.5 mg/kg (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 7.5 mg/kg (provisional), at or above the government ceiling of 2.5 mg/kg, so the government maximum binds. Why nickel is limited →
The corpus holds 6 measurements of aluminium in Chocolate (15602 samples reported across those studies), which the determination below is tested against: Elsheikh 2020, ANSES 2026, Fechner 2019, Stahl 2017, Vitola 2016, FSANZ 2011.
HMTc sets no standalone aluminium limit for Chocolate. Aluminium in cocoa and chocolate is natural mineral content of cocoa, a documented aluminium-accumulating crop; cocoa powder means run ~146-165 mg/kg with origin (not additives) explaining most variance, and chocolate Al scales with cocoa fraction. The pooled ~118 mg/kg fits a cocoa-rich product mix. Even conservative cocoa-consumption scenarios reach only ~15% of the EFSA TWI. No credible regulator sets an aluminium contaminant ML for chocolate/cocoa; dietary Al is TWI-managed with ~0.1-0.3% oral bioavailability. The analyte is controlled by Aluminium managed by intake vs TWI; periodic screen; no per-food contaminant ML, not a standalone number. A not-material determination is a rebuttable presumption; it is tested against the measured evidence above and rests on the chemistry, not on an absence of data. Why aluminium is limited →
Risk Flag
On the published occurrence literature to date, Cocoa and chocolate products (cocoa powder, dark, milk, chips) 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.
Cite this standard
Pendergrass, K. (2026). Cocoa and chocolate products (cocoa powder, dark, milk, chips): HMTc standard. Institute of Contaminant Standards.
© 2026 Institute of Contaminant Standards / Heavy Metal Certified. All rights reserved.
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.