How limits are set
Applicability was treated as a real constraint in both directions. Stricter sovereign values that exist but do not reach this form were rejected on the record rather than quietly adopted: the German BVL and Washington State toothpaste lead tiers (500 and 1000 µg/kg) govern a dentifrice that is partly swallowed and belong to Categories 20 and 2, and the EU REACH tattoo and permanent-make-up mixture limits govern a mixture injected into the dermis. Looser sovereign accommodations for mineral-bearing forms (EAEU TR CU 009/2011 natural plant or mineral raw material, Korea MFDS clay-powder carve-out) were named on the mineral rows and rejected on strictness, so the record shows they were evaluated.
The rinse-off use pattern is NOT credited as a dilution factor: the sovereign instruments set their values on the product as placed on market, and HMTc applies them in that basis without inventing a conversion.
Master Limit Table
All values in ppb (µg/kg), as-sold basis. 9 of 11 analytes carry a firm ceiling; the remaining 2 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.
| Analyte | HMTc limit | Binding basis |
|---|---|---|
| Lead (Pb) | 1000 | strictest government ML (US-WA) |
| Inorganic arsenic (iAs) | bounded | ≤ total tAs, measured every lot (see note) |
| Total arsenic (tAs) | 500 | strictest government ML (DE) |
| Mercury, total (tHg) | 100 | strictest government ML (DE) |
| Methylmercury (MeHg) | bounded | ≤ total tHg, measured every lot (see note) |
| Cadmium (Cd) | 100 | strictest government ML (DE) |
| Hexavalent chromium (Cr-VI) | 5 | government read-across (EU) |
| Nickel (Ni) | 10000 | strictest government ML (KR) |
| Tin (Sn) | 3750000 | government read-across (EU) |
| Aluminium (Al) | 560000 | government read-across (EU) |
| Total chromium (Cr) | 50 | government read-across (AU) |
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.
Derivation
The full derivation for Exfoliants/scrubs (body, facial). 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) | 1000 | US-WA |
| Inorganic arsenic (iAs) | bounded&sup5; | species ≤ tAs |
| Total arsenic (tAs) | 500 | DE |
| Mercury, total (tHg) | 100 | DE |
| Methylmercury (MeHg) | bounded&sup5; | species ≤ tHg |
| Cadmium (Cd) | 100 | DE |
| Hexavalent chromium (Cr-VI) | 5² | read-across |
| Nickel (Ni) | 10000 | KR |
| Tin (Sn) | 3750000² | read-across |
| Aluminium (Al) | 560000² | read-across |
| Total chromium (Cr) | 50² | read-across |
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.
Risk Flag
On the published occurrence literature to date, Exfoliants/scrubs (body, facial) shows no systematic gap between typical market levels and the limit — the limit being the strictest government maximum for the product (Method v2.0). Certification is decided on a product’s own tested result, not on a distribution; an individual lot or supplier can still exceed a limit.
See the cross-category summary of the ingredients that most often struggle.
Cite this standard
Pendergrass, K. (2026). Exfoliants/scrubs (body, facial): HMTc standard (Standard No. 10.83138/hmtc.std.14.exfoliants-scrubs). Institute of Contaminant Standards. https://doi.org/10.83138/hmtc.std.14.exfoliants-scrubs
© 2026 Institute of Contaminant Standards / Heavy Metal Certified. All rights reserved.
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.