How every number on this page is 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. 5 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 | 1000 | strictest government ML (US-WA) |
| Inorganic arsenic (iAs) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Total arsenic (tAs) | Tier 2 | 500 | strictest government ML (DE) |
| Mercury, total (tHg) | Tier 1 | 100 | strictest government ML (DE) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Cadmium (Cd) | Tier 1 | 100 | strictest government ML (DE) |
| Hexavalent chromium (Cr-VI) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Nickel (Ni) | Tier 2 | 10000 | strictest government ML (KR) |
| 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 | control | mandatory control — no government ML; screened every lot (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 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) | control&sup4; | screened |
| Total arsenic (tAs) | 500 | DE |
| Mercury, total (tHg) | 100 | DE |
| Methylmercury (MeHg) | n/m³ | controlled |
| Cadmium (Cd) | 100 | DE |
| Hexavalent chromium (Cr-VI) | control&sup4; | screened |
| Nickel (Ni) | 10000 | KR |
| Tin (Sn) | control&sup4; | screened |
| Aluminium (Al) | control&sup4; | screened |
| Total chromium (Cr) | control&sup4; | screened |
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.
Cite this standard
Pendergrass, K. “Exfoliants/scrubs (body, facial).” In Heavy Metal Tested & Certified (HMTc) Cosmetics and Personal Care — Rinse-off 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.