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 Milk powders — whole, skim, and specialty’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.
| Analyte | Tier | HMTc limit | Binding basis |
|---|---|---|---|
| Lead (Pb) | Tier 1 | 20 | government read-across (Israel) |
| Cadmium (Cd) | Tier 1 | 1000 | strictest government ML (Vietnam) |
| Total arsenic (tAs) | Tier 2 | 500 | strictest government ML (China) |
| Inorganic arsenic (iAs) | Tier 1 | n/m | not material — controlled analyte (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 | 250 | government read-across (EU) |
| Tin (Sn) | Tier 2 | n/m | not material — controlled analyte (see note) |
| Aluminium (Al) | Tier 2 | 500 | government read-across (AU/NZ) |
| Total chromium (Cr) | Tier 2 | 2000 | strictest government ML (China) |
| Hexavalent chromium (Cr-VI) | 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, 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 Milk powders — whole, skim, and specialty. 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.
| Analyte | China | Vietnam | HMTc | Binds |
|---|---|---|---|---|
| Lead (Pb) | — | — | 20² | read-across |
| Cadmium (Cd) | — | 1000 | 1000 | Vietnam |
| Total arsenic (tAs) | 500 | 500 | 500 | China |
| Inorganic arsenic (iAs) | — | — | n/m³ | controlled |
| Mercury, total (tHg) | — | 50 | 50 | Vietnam |
| Methylmercury (MeHg) | — | — | n/m³ | controlled |
| Nickel (Ni) | — | — | 250² | read-across |
| Tin (Sn) | — | — | n/m³ | controlled |
| Aluminium (Al) | — | — | 500² | read-across |
| Total chromium (Cr) | 2000 | — | 2000 | China |
| Hexavalent chromium (Cr-VI) | — | — | n/m³ | controlled |
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.
Cite this standard
Pendergrass, K. “Milk powders — whole, skim, and specialty.” 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.