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Fermented beverages, non-tea — HMTc Standard

Standard

The Heavy Metal Tested & Certified heavy-metal-safety standard for fermented beverages, non-tea in Beverages, evaluated on ready-to-drink liquid, as consumed (wet weight, single strength); a concentrate or a powder-to-liquid product is assessed as reconstituted to single strength per the manufacturer's own directions, which is the basis EU 2023/915 and Codex CXS 193 write into their juice cells and Hong Kong Cap 132V Note 11 writes into its beverage entries. 4 of 11 panel analytes publish a numeric limit taken from the strictest applicable government maximum; the remainder are held under mandatory control or a substantiated not-material determination.

UPDATED 2026-08-17
Page snapshot
Analytes limited4 / 11
MethodHMTc Method v2.0 (government-limit-only): the strictest applicable sovereign maximum level for this exact beverage form and analyte in the row's declared native basis, with disclosed read-across where the exact cell is unregulated, a substantiated not-material determination where a species is bounded or is a method artifact, and a control where no defensible sovereign number and no supportable near-neighbour exist. Never occurrence-derived. Ready-to-drink and dry-commodity bases are never mixed and no brewing, dilution or reconstitution factor is invented.
Native basisas-consumed
Standard version1.0 (2026-08-17)

How every number on this page is set

Category 5 carries two native bases and the compiler is configured never to mix them. A ready-to-drink beverage is certified in the as-consumed liquid basis at single strength, and a concentrate is assessed as reconstituted to single strength, which is the basis EU 2023/915 and Codex CXS 193 already write into their juice cells and Hong Kong Cap 132V Note 11 writes into its beverage entries. A dry leaf, dry botanical, roasted bean or beverage powder is certified in the as-sold dry-commodity basis, because that is the article the applicant packages and the lot the auditor samples. No brewing, extraction, dilution or reconstitution factor is invented in either direction: the tea-leaf lead maximum level is never applied to a brewed cup, and a ready-to-drink beverage maximum level is never applied to a dry leaf. Where a government instrument writes the product-form split itself, HMTc preserves it rather than collapsing it: Hong Kong Cap 132V sets Tea, Green, Black at 5000 ug/kg as sold against tea beverages made from it at 200 ug/kg as consumed, and coffee beans at 500 ug/kg as sold against coffee beverages at 200 ug/kg as consumed. Two consequences of the method are disclosed rather than engineered away. The rice-based drink row is LOOSER on inorganic arsenic (30 ug/kg, EU 2023/915 section 3.4.1.6) than the juice rows (20 ug/kg, and 10 ug/kg for apple-containing juice), because the EU assessed that exact commodity and set that exact number. And several formulated-beverage rows carry a lead ceiling of 200 ug/kg because Hong Kong Cap 132V is the only credible sovereign that regulates those forms at all, while the flavoured-water row carries 5 ug/kg because the packaged-drinking-water quality standards do reach a product that is water plus flavour. Those spreads are applicability judgements, each recorded on the face of the cell, and only the endogenous Standards Ratchet in Governance Policy section 12 may lower any of them.

Master Limit Table

All values in ppb (µg/kg), as-consumed 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.

AnalyteTierHMTc limitBinding basis
Lead (Pb)Tier 1200government read-across (Hong Kong)
Inorganic arsenic (iAs)Tier 120government read-across (EU)
Total arsenic (tAs)Tier 2controlmandatory control — no government ML; screened every lot (see note)
Mercury, total (tHg)Tier 1controlmandatory control — no government ML; screened every lot (see note)
Methylmercury (MeHg)Tier 1n/mnot material — controlled analyte (see note)
Cadmium (Cd)Tier 1controlmandatory control — no government ML; screened every lot (see note)
Hexavalent chromium (Cr-VI)Tier 2n/mnot material — controlled analyte (see note)
Nickel (Ni)Tier 2250government read-across (EU)
Tin (Sn)Tier 2100000strictest government ML (EU)
Aluminium (Al)Tier 2controlmandatory control — no government ML; screened every lot (see note)
Total chromium (Cr)Tier 2controlmandatory 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 Fermented beverages, non-tea. Each row lists every government maximum level in force worldwide, converted to the as-consumed 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.

AnalyteHMTcBinds
Lead (Pb)200²read-across
Inorganic arsenic (iAs)20²read-across
Total arsenic (tAs)control&sup4;screened
Mercury, total (tHg)control&sup4;screened
Methylmercury (MeHg)n/m³controlled
Cadmium (Cd)control&sup4;screened
Hexavalent chromium (Cr-VI)n/m³controlled
Nickel (Ni)250²read-across
Tin (Sn)100000EU
Aluminium (Al)control&sup4;screened
Total chromium (Cr)control&sup4;screened

All values µg/kg (ppb), as-consumed 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.

Lead

4 studies in the corpus measured lead in Fermented beverages, non-tea-based (71 samples reported across those studies): Bhattacharya 2024, Munilla-Garcia 2023, Durdjic 2021, Bora 2015.

4 studies · 71 samples in the corpus

HMTc sets 200 ppb by read-across: No credible sovereign has written a lead maximum level for a non-tea fermented beverage as a class. Hong Kong Cap 132V's Wine cell (200 ug/kg, as consumed) is the only credible sovereign lead value this register carries for any fermented beverage, and it is adopted by disclosed read-across as the row ceiling for the non-alcoholic and low-alcohol ferments in scope. Wine itself is not certifiable under this row; see the scope note. Why lead is limited →

The corpus holds 2 measurements of cadmium in Fermented beverages, non-tea-based (7 samples reported across those studies), which the determination below is tested against: Bhattacharya 2024, Bora 2015.

2 studies · 7 samples in the corpus

HMTc sets no standalone cadmium limit for Fermented beverages, non-tea-based. No credible sovereign sets a cadmium maximum level for a non-tea fermented beverage. No credible sovereign sets a cadmium maximum level for wine, cider, beer or any other fermented beverage; the only cadmium values for fermented drinks anywhere in the register are non-credible-tier wine cells (MERCOSUR and Paraguay at 10 ug/kg), which sit outside the credible-regulator set and were not used. The absence of a credible cadmium cell for fermented beverages is reported as a regulatory gap. No near-neighbour read-across is supportable, so the fail-safe disposition is a control: cadmium testing is mandatory on every certified lot and no ceiling is invented from occurrence data. The analyte is controlled by Cadmium by ICP-MS on every certified lot, reported on the certificate. A result above 10 ug/kg in a ready-to-drink form, or above 100 ug/kg in a dry form, escalates to an ingredient-origin and process-water investigation and is a Standards Ratchet surveillance input under Governance Policy section 12, not a standalone number. Why cadmium is limited →

Cite this standard

Pendergrass, K. “Fermented beverages, non-tea.” In Heavy Metal Tested & Certified (HMTc) Beverages 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.