Cheese — HMTc Standard

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 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. 8 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. 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

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.

All values µg/kg (ppb), as-sold basis. ² no government regulates this analyte for this exact product form: the value is a disclosed read-across from the nearest applicable government maximum, and the derivation names the instrument it comes from. It is never taken from occurrence data. After publication the standards ratchet may tighten it, using certified-lot results only. ³ not material in this matrix: measured but with no standalone number, controlled by packaging control or by the total-metal screen, not an invented value. &sup5; a toxic species governed by and bounded by its parent total (for example inorganic arsenic ≤ total arsenic): the species can never exceed the total, so the total ceiling is the species ceiling. The total metal is measured on every lot and the species is established at baseline; no separate species ceiling is published. On ongoing lots the species is speciated whenever the total exceeds its limit.

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.

Risk Flag

Where certification is demanding for this subcategory, and why. These carry a natural or process background that runs above the limit — the limit being the strictest government maximum for the product, never a percentile of market data (Method v2.0). A product is not disqualified by this — only its own tested result decides certification, and a well-sourced lot can sit well below the market.

Multipliers are the ratio of the pooled occurrence median to the published limit; occurrence characterises the market only and carries no compliance weight. See the cross-category summary.