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Cheese — HMTc Standard

Standard

The Heavy Metal Tested & Certified standard for cheese of all styles, stated as sold. Cheese carries its own government maximum levels, which reflect the concentration of the cheese matrix; every limit is the strictest such sovereign maximum, with a disclosed read-across where none regulates the exact analyte.

UPDATED 2026-08-13
Page snapshot
Analytes limited7 / 11
MethodStrictest government ML
Native basisas-sold
Standard version1.0 (2026-08-13)

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 Cheese’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. 7 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.

AnalyteTierHMTc limitBinding basis
Lead (Pb)Tier 120strictest government ML (Vietnam)
Cadmium (Cd)Tier 1500strictest government ML (Mercosur)
Total arsenic (tAs)Tier 2500strictest government ML (Mercosur)
Inorganic arsenic (iAs)Tier 1n/mnot material — controlled analyte (see note)
Mercury, total (tHg)Tier 150strictest government ML (Vietnam)
Methylmercury (MeHg)Tier 1n/mnot material — controlled analyte (see note)
Nickel (Ni)Tier 2100government read-across (EU)
Tin (Sn)Tier 2n/mnot material — controlled analyte (see note)
Aluminium (Al)Tier 2500government read-across (AU/NZ)
Total chromium (Cr)Tier 2300government read-across (China)
Hexavalent chromium (Cr-VI)Tier 2n/mnot 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, Sn, Al, Cr, Cr-VI) carry a 150% transitional allowance under the program’s Status A–E framework. Inorganic arsenic (iAs) and hexavalent chromium (Cr-VI) operate as reflex speciation screens — total arsenic and total chromium are measured on every lot and bound them. Methylmercury (MeHg) has no bioaccumulation pathway in dairy and is bounded by total mercury. Tin (Sn) is material only for canned product (condensed and evaporated milks), where it migrates from the can; for all other dairy forms it is controlled by screen, not assigned an invented number. Nickel and aluminium carry disclosed read-across limits where no government sets a general-dairy maximum. Dairy has no legislated reconstitution ratio, so every limit is taken at face value in the product's native basis.

Derivation — every government’s number, side by side

The full derivation for Cheese. Each row lists every government maximum level in force worldwide, converted to the as-sold 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.

AnalyteMercosurParaguayVietnamHMTcBinds
Lead (Pb)4004002020Vietnam
Cadmium (Cd)5005001000500Mercosur
Total arsenic (tAs)500500500500Mercosur
Inorganic arsenic (iAs)n/m³controlled
Mercury, total (tHg)5050Vietnam
Methylmercury (MeHg)n/m³controlled
Nickel (Ni)100²read-across
Tin (Sn)n/m³controlled
Aluminium (Al)500²read-across
Total chromium (Cr)300²read-across
Hexavalent chromium (Cr-VI)n/m³controlled

All values µg/kg (ppb), as-sold 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.

2 studies in the corpus measured lead in Cheese (230 samples reported across those studies): Erol 2025, Ibrahim 2024.

2 studies · 230 samples in the corpus

HMTc sets 20 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 →

2 studies in the corpus measured cadmium in Cheese (230 samples reported across those studies): Erol 2025, Ibrahim 2024.

2 studies · 230 samples in the corpus

HMTc sets 500 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 →

Total arsenic

3 studies in the corpus measured total arsenic in Cheese (387 samples reported across those studies): Erol 2025, Ibrahim 2024, Arellano 2023.

3 studies · 387 samples in the corpus

HMTc sets 500 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 →

Total mercury

2 studies in the corpus measured total mercury in Cheese (230 samples reported across those studies): Erol 2025, Ibrahim 2024.

2 studies · 230 samples 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 total mercury is limited →

Nickel

1 study in the corpus measured nickel in Cheese (30 samples reported across those studies): Erol 2025.

1 study · 30 samples in the corpus

HMTc sets 100 ppb by read-across: Conservative sovereign dairy read-across from the EU liquid infant/young-child formula nickel maximum (100 ug/kg) where no general-dairy nickel maximum exists. Why nickel is limited →

Aluminium

1 study in the certified-market pool measured aluminium in Cheese across 30 certified-market samples. The pooled distribution centres on a median of 2.1 mg/kg and reaches 4.2 mg/kg at the 95th percentile. Erol 2025.

1 study · 30 samples · median 2.1 mg/kg · P95 4.2 mg/kg

HMTc sets 500 ppb by read-across: Conservative sovereign dairy read-across from the AU-NZ non-soy infant-formula aluminium maximum (500 ug/kg); no general-dairy aluminium maximum is loaded. Why aluminium is limited →

Cite this standard

Pendergrass, K. “Cheese.” In Heavy Metal Tested & Certified (HMTc) Dairy and Milk Products 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.