How every number on this page is set
What this standard coversCovers the diaper and its structural components: nonwoven topsheet and backsheet, the absorbent core, elastics, adhesives, and closures/fasteners. It does NOT cover baby or diaper wipes, or diaper creams, which are leave-on skin-cleansing and skin-care products certified under Category 2 (Infant and Child Personal Care), rows Baby wipes and Diaper cream.
Diapers and diaper components is a contact product, not a food. Its heavy-metal limits are extractable-metal limits for the skin-contact textile and elastic components (EU REACH Annex XVII entry 72). Entry 72 excludes disposable textiles, so the limits bind reusable-cloth components directly and are read across as the benchmark for disposable-diaper skin-contact components; the absorbent core has no metal-migration pathway — not dietary maximum levels. The standard for each analyte is the strictest limit set by any credible government regulator for this product in its own basis: a lookup of sovereign law, with the measured quantity stated on every row. Where no instrument directly governs the exact product form — a pacifier is excluded from the Toy Safety Directive, a disposable diaper from the REACH textile restriction — the limit is read across from the nearest applicable sovereign limit and labelled as a read-across, never asserted as direct governance. Migration limits (what leaves the article into saliva or food) and total-content limits (how much metal the article contains) are different quantities measured by different methods; they are published as separate ceilings and never combined into one number. A certified product meets every applicable limit at once, each on a like-for-like basis.
Inorganic arsenic and methylmercury are not published for this category: they are ingestion-and-bioaccumulation speciation forms with no migration counterpart in a contact article, and the total-element ceilings (total arsenic, total mercury) bound them. Where a cell is marked not material, no regulator sets a limit and no exposure pathway exists; the determination is recorded, not left blank.
Master Limit Table
Limits in mg/kg, in the basis named on each row. “ND” means not detectable at the regulation’s stated detection limit — the strictest possible ceiling. Sub-rows (↳) are companion ceilings in a different basis that also apply. Tier 1 (Pb, Cd, iAs, Hg) are zero-tolerance toxics; Tier 2 (tAs, Ni, Al, Cr-VI, Sn) carry a transitional allowance under the program’s Status A–E framework. Antimony is regulated in the toy-migration instruments and screened, but is not one of the ten HMTc certification analytes.
| Analyte | Tier | HMTc limit | Basis | Strictest government | Rationale |
|---|---|---|---|---|---|
| Lead (Pb) | Tier 1 | 1 | homogeneous material after extraction; source unit mg/kg | European Union (read-across) | regulatory-alignment |
| Arsenic, total (tAs) | Tier 2 | 1 | homogeneous material after extraction; source unit mg/kg | European Union (read-across) | regulatory-alignment |
| Cadmium (Cd) | Tier 1 | 1 | homogeneous material after extraction; source unit mg/kg | European Union (read-across) | regulatory-alignment |
| Nickel (Ni) | Tier 2 | 0.5 µg/cm²/week | nickel release, direct and prolonged skin contact (EN 1811) | EU | regulatory-alignment |
| Chromium VI (Cr-VI) | Tier 2 | 1 | homogeneous material after extraction; source unit mg/kg | European Union (read-across) | regulatory-alignment |
| Tin (Sn) | Tier 2 | 1000 | organotin content as tin, skin-contact article (REACH Annex XVII entry 20; 0.1% = 1000 mg/kg). Reflex organotin speciation on a total-tin detection; ratchets toward the TDI-anchored voluntary levels (Smajgl 2015: up to 23 mg/kg total Sn, 20-100% of the organotin TDI) | European Union | regulatory-alignment |
Screened, not limited
All ten HMTc certification analytes, plus a total-chromium screen, are accounted for. The analytes below carry no published ceiling for this product because no exposure pathway and no government limit exist; each determination is recorded here rather than left as a silent gap. They are screened during certification, not certified against a number.
| Analyte | Why it carries no ceiling for this product |
|---|---|
| Inorganic arsenic (iAs) | REACH textile limits regulate total arsenic; no inorganic-arsenic limit. Bounded by the tAs extraction ceiling. |
| Mercury, total (tHg) | No mercury source or migration pathway in absorbent-hygiene materials (cellulose fluff, super-absorbent polymer, PE/PP nonwoven). No jurisdiction sets a diaper mercury limit. |
| Methylmercury (MeHg) | No methylmercury pathway in a diaper. |
| Aluminium (Al) | No aluminium source or migration pathway in absorbent-hygiene materials. |
| Chromium, total (Cr) | EU REACH Annex XVII entry 72 regulates extractable hexavalent chromium in skin-contact textiles (Cr-VI, 1 mg/kg after extraction); no jurisdiction sets a total-chromium extraction limit for skin-contact textile or absorbent-hygiene materials, so no sovereign total-Cr row applies to the diaper form. Total chromium is screened, not assigned a published limit; any detectable total chromium reflexes to Cr-VI extraction, which binds at the entry-72 limit read across per the disposable-textile exclusion. |
Derivation — every government value, side by side
Each row lists every government limit weighed for this analyte in the governing basis, converted to mg/kg; the HMTc limit is the strictest of them. Companion total-content ceilings appear in the Master Limit Table above, not here, because they are a different measured quantity.
| Analyte | Government limits considered (mg/kg) | HMTc | Binds |
|---|---|---|---|
| Lead (Pb) | European Union 1 (read-across) | 1 | European Union (read-across) |
| Arsenic, total (tAs) | European Union 1 (read-across) | 1 | European Union (read-across) |
| Cadmium (Cd) | European Union 1 (read-across) | 1 | European Union (read-across) |
| Nickel (Ni) | 0.5 µg/cm²/week | EU | |
| Chromium, total (Cr) | — | ||
| Chromium VI (Cr-VI) | European Union 1 (read-across) | 1 | European Union (read-across) |
| Tin (Sn) | European Union 1000 · European Union 1000 | 1000 | European Union |
Cite this standard
Pendergrass, K. “Diapers and diaper components.” In Heavy Metal Tested & Certified (HMTc) Infant and Child Contact Products standard, version 1.0 (2026-08-10). Institute of Contaminant Standards (ICS), 2026.
The evidence each limit is applied to lives on the independent Heavy Metal Index; HMTc cites it one way and never the reverse. HMTc standards are living, versioned documents; this page reflects 1.0 (2026-08-10).
Source regulations
Every government regulation weighed to set this standard, evaluated against each other in the correct basis. The strictest applicable limit binds each analyte; basis is never conflated across families.
| # | Regulation | Instrument | Basis | Role in this standard |
|---|---|---|---|---|
| 1 | EU REACH entry 72 (metals in consumer textiles) | Extraction limit | skin-contact extraction | Binds one or more migration/extraction limits |
| 2 | European Commission | Content limit | total content | Companion total-content ceiling |