Fabric refresher products — HMTc Standard

How every number on this page is set

No sovereign government sets a heavy-metal maximum level for a laundry or fabric-care product. The regimes that actually govern this sector — Green Seal GS-48 and GS-51 for laundry care products, the EPA Safer Choice programme and its Design for the Environment standard, the EU Ecolabel for detergents and cleaning products (Commission Decisions (EU) 2017/1214 to 2017/1219 and the 2024 user manual, with the JRC 2025 revision in progress), California SB 258 (the Cleaning Product Right to Know Act) and the New York DEC cleansing-product disclosure best-management practice — are eco-label, ingredient-disclosure and biodegradability regimes. They name lead, cadmium, total arsenic, total mercury, hexavalent chromium and nickel as substances of concern for laundry care and set NO numeric contaminant ceiling in the product, so they establish materiality and supply no number. China GB 14930.1-2022 is the only sovereign detergent contaminant standard in the register; its scope is Type A detergents used directly for food cleaning and Type B detergents for tableware and food-contact tools, equipment, packaging and containers, so it does not reach a laundry detergent and still less a fabric softener, and its total-arsenic ceilings of 3.0 and 5.0 mg/kg are looser than the value adopted here in any event. The toxic panel is therefore read across from the nearest applicable coherent sovereign consumer-chemical regime in the same basis. A single coherent sovereign regime is read across per analyte rather than the lowest number picked across regimes, which would build a ceiling no sovereign enforces. China NMPA 2015 Table 2 is the strictest coherent STATUTORY consumer-chemical regime for lead, cadmium, total arsenic and total mercury (Korea MFDS is looser on lead at 20 and on total arsenic at 10 mg/kg; ASEAN, Health Canada and BVL are guidance), and it is already the read-across anchor of the live Category 12 (Household Cleaning and Dishwashing) standard for the identical logical move. Nickel is not regulated by the Chinese instrument at all, so for nickel the nearest applicable sovereign consumer-chemical value is the Korean statutory limit; that is the only regime in the register that sets one, and no number in this row was chosen by comparing outcomes. Reading a cosmetic ceiling across to a fabric-care product is directionally conservative for the rinse-off rows, where the product is diluted in wash water and rinsed rather than applied neat to skin, and directly analogous for the leave-on rows, where the product is deliberately deposited on a textile that is then worn against skin; the sovereign instruments write no rinse-off/leave-on split for these analytes, so none is invented here and the exposure difference is disclosed in each row's scope note instead. EU REACH Annex XVII entry 72 with Appendix 12 restricts lead, cadmium, total arsenic and hexavalent chromium to 1 mg/kg in consumer clothing, related accessories, textiles with skin contact similar to clothing, and footwear. That instrument governs the FABRIC and not the product applied to it, and it is expressed on a homogeneous-material-after-extraction basis rather than on the product-content basis of this category. It is disclosed here as a related but distinct scope and as the downstream constraint a certified product must not cause the treated textile to breach; it is never borrowed as this category's ceiling, and the row's basis_guard makes that borrowing impossible in the compiler. EU REACH Annex XVII entry 75 (Regulation (EU) 2020/2081) sets the strictest sovereign consumer-mixture metal limits in the register (lead 0.7, cadmium 0.5, total arsenic 0.5, mercury 0.5, Cr(VI) 0.5 and nickel 5 mg/kg), but its scope is mixtures for tattooing and permanent make-up, an intradermal-injection route. Reading an injected-mixture ceiling across to a rinse-off or fabric-deposited topical product would conflate exposure routes, and its register basis is a tattoo/permanent-make-up mixture basis that this row's basis_guard excludes. The Germany BVL 2017 values that the audit scan surfaces as stricter are orientation values for technically avoidable trace content, carried in the register with status 'guidance impurity limit' rather than as statutory maximum levels; Method v2.0 selects the strictest applicable MAXIMUM LEVEL set by a credible sovereign government, so a guidance orientation value is not selectable as an anchor. The same reasoning excludes the Health Canada cosmetic impurity limits and the ASEAN, Malaysia and Singapore guidance values. Occurrence, eco-label and disclosure evidence is used only to establish materiality — a not-material determination contradicted by a measurement in the routed corpus would be false and would fail the substantiation gate — and to design each control's reference method and escalation rule. It never selects a number.

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.

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 Fabric refresher products. 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.

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. “Fabric refresher products.” In Heavy Metal Tested & Certified (HMTc) Laundry and Fabric-Contact Home Products 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.