How every number on this page is set
Category-specific method notes. (1) MUSCLE MEAT vs OFFAL. Every credible instrument writes separate and materially looser maximum levels for edible offal, because lead and cadmium concentrate in liver and kidney. Every row here is scoped to muscle meat and attached edible fat; offal of the same species is a separately-tested sub-lot assessed against that species' offal maximum levels, and no offal value anchors a muscle-meat row. The taxonomy boundary rule places offal inside the animal's own subcategory, which is honoured by sub-lot testing rather than by publishing an offal-derived ceiling. (2) THE CATEGORY 1 BOUNDARY. Products marketed for ages 0-5 route to Category 1 (mixed meals), so the infant and baby-food action levels and maximum levels that would otherwise be the strictest values in the register are excluded by applicability from every row here, and are excluded explicitly in each row's audit_exclude_scope. (3) GAME AND LEAD AMMUNITION. Fragmenting lead projectiles are a documented, mechanical lead pathway in wild-harvested game. That evidence drives mandatory radiographic fragment screening before grinding and priority surveillance on the game row; it does not and cannot move the number, which remains a disclosed read-across from the domestic-mammal muscle-meat maximum level. (4) BASIS TREATMENT ON THE THREE COMPOSITE ROWS, DISCLOSED IN THE DIRECTION IT CUTS. On the processed-meat, canned-meat and analogue rows the component maximum level is applied to the finished product as sold, with no invented conversion factor. This config does NOT claim that treatment is conservative, because it is not: a formulation that is part water, brine, starch or rusk can carry a higher concentration in its meat or protein fraction than the component maximum level itself allows. The gap is closed by a second, independent obligation rather than by a conversion factor. Certification of those three rows requires documented compliance of the raw material or source commodity against the same named component maximum levels, in their own basis, IN ADDITION to finished-product compliance against the published ceiling; neither test substitutes for the other. The eggs row runs the opposite way and is treated accordingly: dried and powdered egg is concentrated relative to whole egg, so applying the whole-egg maximum level to the powder as sold is the STRICTER treatment, and it is applied without being reversed. (5) REGISTER GAPS ARE DISCLOSED, NOT FILLED. The EU 2023/915 and Codex CXS 193 lead rows for meat and offal, the EU and Codex cadmium offal rows, and the FSANZ cadmium meat and offal rows are absent from this register. They are recorded as register gaps for ingestion through the verified regulatory-fetch pathway and are NOT written into this config from memory. No absent row is assigned a remembered value anywhere in this config. Because the method selects the strictest applicable value, ingesting a missing row can only lower a published cell or leave it unchanged, never raise it; every affected cell must be re-derived when the missing rows land.
Master Limit Table
All values in ppb (µg/kg), as-sold basis. 4 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 | 200 | strictest government ML (Hong Kong) |
| Inorganic arsenic (iAs) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Total arsenic (tAs) | Tier 2 | 500 | government read-across (Hong Kong) |
| Mercury, total (tHg) | Tier 1 | 50 | strictest government ML (Hong Kong) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Cadmium (Cd) | Tier 1 | 50 | government read-across (Hong Kong) |
| Hexavalent chromium (Cr-VI) | Tier 2 | n/m | not material — controlled analyte (see note) |
| Nickel (Ni) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Tin (Sn) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Aluminium (Al) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Total chromium (Cr) | Tier 2 | screen | screening ceiling — Cr(VI) is the binding health control (see note) |
Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Cr-VI, Ni, Sn, Al, Cr) carry a 150% transitional allowance under the program’s Status A–E framework.
Derivation — every government’s number, side by side
The full derivation for Eggs. 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 | HMTc | Binds |
|---|---|---|
| Lead (Pb) | 200 | Hong Kong |
| Inorganic arsenic (iAs) | control&sup4; | screened |
| Total arsenic (tAs) | 500² | read-across |
| Mercury, total (tHg) | 50 | Hong Kong |
| Methylmercury (MeHg) | n/m³ | controlled |
| Cadmium (Cd) | 50² | read-across |
| Hexavalent chromium (Cr-VI) | n/m³ | controlled |
| Nickel (Ni) | control&sup4; | screened |
| Tin (Sn) | control&sup4; | screened |
| Aluminium (Al) | control&sup4; | screened |
| Total chromium (Cr) | 1000 | undefined |
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: controlled by reflex speciation or packaging control, not a standalone number. &sup4; no sovereign maximum exists for this analyte in this product, but a credible exposure pathway does — it is screened on every lot under ALARA against the tightest analogous reference, not assigned an invented 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.
The corpus holds 1 measurement of inorganic arsenic in Eggs (3312 samples reported across those studies), which the determination below is tested against: FERA 2015.
HMTc sets no standalone inorganic arsenic limit for Eggs. No credible sovereign government sets an inorganic-arsenic maximum level for eggs or egg products. Every credible inorganic-arsenic instrument on the register is scoped elsewhere: EU 2023/915 and EU 2025/1891 to rice, rice products, fruit juices, infant food and seafood; UK, Health Canada and US FDA to rice-based and juice matrices; Hong Kong Cap. 132V to rice and aquatic animals. A NOT-MATERIAL determination is deliberately REJECTED for this cell rather than adopted for convenience: organoarsenical feed additives (roxarsone, nitarsone, arsanilic acid, carbarsone) were lawfully administered to poultry and swine in major producing markets within living memory and are documented to leave arsenic residues in edible tissue, so the programme will not make the affirmative claim that no inorganic-arsenic pathway exists in terrestrial animal food. For the ruminant rows, where no equivalent additive history applies, the absence of that pathway does not by itself substantiate a not-material determination either, because neither a sovereign number nor a supportable near-neighbour analogue exists for the cell in any case. Because no sovereign number governs the cell and no near-neighbour cell is a supportable analogue (a rice or seafood inorganic-arsenic maximum level describes a different contamination mechanism entirely), the cell is a control: testing is mandatory and no ceiling is invented. The analyte is controlled by Inorganic arsenic by anion-exchange HPLC-ICP-MS speciation. Speciation is reflex-triggered on every lot whose total-arsenic screen is quantifiable above the method limit of quantitation, and unconditionally on the first lot from any new supplier, slaughter establishment, or country of origin. Any quantifiable inorganic arsenic is escalated to the certification committee together with the feed-additive and origin declaration; the lot cannot be released on an inorganic-arsenic result while the escalation is open, and a total-arsenic result at or above the binding total-arsenic maximum level is a hard stop irrespective of speciation, not a standalone number. Why inorganic arsenic is limited →
The corpus holds 1 measurement of tin in Eggs (3312 samples reported across those studies), which the determination below is tested against: FERA 2015.
HMTc sets no standalone tin limit for Eggs. Inorganic tin in food is a tinplate-packaging pathway: tin migrates into the food from the internal surface of an unlacquered or damaged tinplate can, which is why every credible sovereign tin maximum level on the register is written against canned food rather than against the food itself. Shell eggs, liquid egg and dried egg in carton, tub or bag packaging is not packed in tinplate, so the pathway that the canned-food maximum levels exist to control is absent and no sovereign number governs the cell. A lot of this product form that is retorted or packed in a metal can is not certified against this row at all: it is certified against the canned-meats row, whose tin cell carries the binding canned-foods maximum level. No tin ceiling is invented for the non-canned form. The analyte is controlled by Total tin by ICP-MS on every certified lot. Any quantifiable tin in a lot declared as non-metal-packed triggers a packaging and contact-surface investigation (can or closure liner, tinned equipment, solder) before release, and re-routes the lot to the canned-meats row if metal packaging is found, not a standalone number. Why tin is limited →
The corpus holds 1 measurement of aluminium in Eggs (3312 samples reported across those studies), which the determination below is tested against: FERA 2015.
HMTc sets no standalone aluminium limit for Eggs. No credible sovereign government sets an aluminium maximum level for meat, poultry, game or eggs. The credible aluminium values on the register are drinking- and bottled-water statutory limits (EU 2020/2184, US FDA 21 CFR 165.110, Health Canada), a food-contact specific-migration limit (EU 10/2011), toy element-migration limits, and the FSANZ Schedule 19 aluminium maximum levels for infant formula. None can anchor this row: the water and migration values are in a different basis, and an adult food must not borrow an infant-formula maximum level (products marketed for ages 0-5 route to Category 1 by the taxonomy boundary rule). No read-across is supportable and no ceiling is invented. The analyte is controlled by Total aluminium by ICP-MS on every certified lot, trended per SKU. Escalation is triggered by a result above the SKU's established rolling upper control limit or by an increasing trend across three consecutive lots, and directs the investigation to aluminium contact surfaces and packaging (foil, trays, aluminium cookware, aluminium-containing processing aids). No numeric ceiling is published because no sovereign instrument compels one, not a standalone number. Why aluminium is limited →
Cite this standard
Pendergrass, K. “Eggs.” In Heavy Metal Tested & Certified (HMTc) Meat, Poultry, and Eggs 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.