Disinfectants and sanitizers (EPA-registered antimicrobial sprays, wipes, concentrates) — HMTc Standard

How every number on this page is set

What this standard coversEPA-registered antimicrobial products under FIFRA (sprays, wipes, concentrates) - a distinct testing bucket. Metal-based actives (silver, copper) are declared actives, not contaminants, and are outside the HMTc contaminant panel. Organotin is screened per REACH entry 20 given the historical organotin-biocide pathway. No FIFRA/FDA instrument sets a heavy-metal contaminant maximum for the product.

Disinfectants and sanitizers (EPA-registered antimicrobial sprays, wipes, concentrates) are EPA-registered antimicrobial products under FIFRA — a distinct testing bucket. The Confidential Statement of Formula and the antimicrobial active ingredient govern registration; a metal-based active (for example silver or copper) is a declared active, not a contaminant, and is outside the ten-analyte HMTc contaminant panel. No FIFRA or FDA sanitizing-solution instrument sets a heavy-metal contaminant maximum for the product, and household cleaning products are otherwise largely unregulated for heavy-metal content (the disclosure and eco-label regimes set no maximums). The toxic panel is therefore read across from the nearest coherent statutory consumer-chemical regime, China’s mandatory cosmetic trace-metal limits (Safety and Technical Standards for Cosmetics, 2015) — conservative, because a cosmetic is prolonged leave-on skin contact and an antimicrobial spray or wipe is incidental. Every number is in the product’s native basis: total heavy-metal content as placed on the market.

Where no sovereign limit exists but the metal is a real or plausible contaminant, the standard publishes an analytical method and an escalation rule rather than an invented threshold (see Screened by method below); organotin is screened here because antimicrobial products are the one cleaning sub-scope with a plausible organotin-biocide pathway. Inorganic arsenic and methylmercury are bounded by their total-element parents and recorded as not material.

Master Limit Table

Limits in mg/kg of product as placed on the market. Tier 1 (Pb, Cd, iAs, Hg) are zero-tolerance toxics; Tier 2 (tAs, Ni, Al, Cr, Sn) carry a transitional allowance under the program’s Status A–E framework. Analytes with no government limit for this product are listed below the table (screened by method, or not material), so all ten certification analytes are accounted for.

Screened by method — no government limit

No sovereign sets a heavy-metal maximum for these analytes in a household cleaning product, yet each is a real or plausible contaminant of the class. Rather than invent a number, the standard publishes the analytical method and the escalation rule for each: certification measures the analyte and escalates an out-of-band lot to ALARA review, not to a pass/fail against a fabricated threshold. This is an honest control, not a silent gap.

Not material for this product

These analytes carry no ceiling because a species-specific limit is bounded by its published total-element parent, or no source and no pathway exist in the product. Each determination is rebuttable and evidence-tested (recorded in the index register), screened during certification, and recorded here rather than left as a silent gap.

Derivation — every government value, side by side

Each row lists the government value(s) weighed for this analyte in the total-content basis, converted to mg/kg; the HMTc limit is the strictest of them (or the disclosed read-across where no direct sovereign limit exists).

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