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Marine non-predatory fish (sardine, anchovy, salmon, cod, herring, mackerel): HMTc Standard

Standard

The Heavy Metal Tested & Certified standard for marine non-predatory fish, sardine, anchovy, salmon, cod, herring, mackerel, as fillet or muscle meat, fresh or frozen, stated as consumed. These lower-trophic species carry the lower government mercury ceiling; every limit is the strictest maximum level any credible government sets for the product.

How limits are set

The standard for each analyte is the strictest maximum level set by any credible government regulator, among them the European Union, Codex Alimentarius, the US FDA, Australia/New Zealand, the Gulf states (GSO), and the national authorities of every jurisdiction that regulates the product, converted into Marine non-predatory fish (sardine, anchovy, salmon, cod, herring, mackerel)’s own as-consumed basis. It is a lookup of sovereign law, carrying at most one disclosed basis conversion where the law is written in another basis, and an explicit read-across where no government regulates the exact product. A certified product sits at or below every applicable sovereign limit at once.

Where no government regulates the exact product for an analyte, the standard does not go blank or invent a number: the limit is read across from the nearest government value for an analogous product, so a certified product still sits at or below a real sovereign limit. The ratchet tightens these after publication as surveillance warrants.

Master Limit Table

All values in ppb (µg/kg), as-consumed basis. 10 of 11 analytes carry a firm ceiling; the remaining 1 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.

AnalyteTierHMTc limitBinding basis
Lead (Pb)Tier 1200strictest government ML (Fiji)
Inorganic arsenic (iAs)Tier 1100strictest government ML (EU)
Total arsenic (tAs)Tier 21000strictest government ML (Paraguay)
Mercury, total (tHg)Tier 1300strictest government ML (EU)
Methylmercury (MeHg)Tier 1bounded≤ total tHg, measured every lot (see note)
Cadmium (Cd)Tier 150strictest government ML (GSO)
Nickel (Ni)Tier 22000government read-across (EU)
Total chromium (Cr)Tier 21000strictest government ML (Hong Kong)
Hexavalent chromium (Cr-VI)Tier 210government read-across (US-CA)
Tin (Sn)Tier 2200000government read-across (EU)
Aluminium (Al)Tier 2100000government read-across (China)

Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Ni, Cr, Cr-VI, Sn, Al) are held to the same government limit: tiering sets how the program reacts to an exceedance, not any permission to exceed it. A product is certified only when every analyte is at or below 100% of its published limit; above the limit, on any metal, it is not certified and carries no mark. Mercury is limited in both forms: total mercury (tHg) and methylmercury (MeHg) are separate ceilings that must both be met, set to the species-specific tier each government assigns (predatory fish carry the higher methylmercury ceiling, lower-trophic species the lower; where the total-mercury ceiling is stricter, methylmercury is bounded by it). Total arsenic (tAs) operates as a reflex screen to inorganic-arsenic (iAs) speciation, since most arsenic in seafood is non-toxic organic arsenobetaine. Every panel analyte carries a limit of record; where no government regulates the exact product (nickel, hexavalent chromium, aluminium, and non-canned tin), the ceiling is a disclosed read-across to the nearest applicable sovereign instrument named in the derivation, never an occurrence-derived number. Tin migrates from the can, so for non-canned seafood the read-across is a packaging-migration baseline that clean product clears.

Derivation

The full derivation for Marine non-predatory fish (sardine, anchovy, salmon, cod, herring, mackerel). 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.

AnalyteEUAU/NZGSOIndiaMercosurCosta RicaFijiGuyanaIsraelMexicoPanamaPhilippinesParaguaySingaporeThailandTrinidad & TobagoUruguayVietnamHong KongHMTcBinds
Lead (Pb)3005003003003003002003003005003003003003002000300300200Fiji
Inorganic arsenic (iAs)100100100EU
Total arsenic (tAs)2000760001000100010001000Paraguay
Mercury, total (tHg)3005001000500500500500500500500500500500300EU
Methylmercury (MeHg)bounded&sup5;species ≤ tHg
Cadmium (Cd)503005050505050500505010005010050GSO
Nickel (Ni)2000²read-across
Total chromium (Cr)1200010001000Hong Kong
Hexavalent chromium (Cr-VI)10²read-across
Tin (Sn)200000²read-across
Aluminium (Al)100000²read-across

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: 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.

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.

1 study in the certified-market pool measured lead in Fish: marine, non-predatory across 207 certified-market samples. The pooled distribution centres on a median of 19 ppb and reaches 673 ppb at the 95th percentile. Singhato 2025.

1 study · 207 samples · median 19 ppb · P95 673 ppb

HMTc sets 200 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 760 ppb, at or above the government ceiling of 200 ppb, so the government maximum binds. Why lead is limited →

Inorganic arsenic

3 studies in the certified-market pool measured inorganic arsenic in Fish: marine, non-predatory across 8 certified-market samples. The pooled distribution centres on a median of 72 ppb and reaches 122 ppb at the 95th percentile. Norin 1985, Park 2005, Munoz 1999.

3 studies · 8 samples · median 72 ppb · P95 122 ppb

HMTc sets 100 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 122 ppb, at or above the government ceiling of 100 ppb, so the government maximum binds. Why inorganic arsenic is limited →

Total arsenic

1 study in the certified-market pool measured total arsenic in Fish: marine, non-predatory across 16 certified-market samples. The pooled distribution centres on a median of 2.8 mg/kg and reaches 78.8 mg/kg at the 95th percentile. Singhato 2025.

1 study · 16 samples · median 2.8 mg/kg · P95 78.8 mg/kg

HMTc sets 1 mg/kg (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 82.6 mg/kg, at or above the government ceiling of 1 mg/kg, so the government maximum binds. Why total arsenic is limited →

Total mercury

4 studies in the certified-market pool measured total mercury in Fish: marine, non-predatory across 909 certified-market samples. The pooled distribution centres on a median of 70 ppb and reaches 467 ppb at the 95th percentile, with a measured maximum of 1.8 mg/kg. Garofalo 2025, Singhato 2025, Brodziak-Dopierala 2023, Helcom 2017.

4 studies · 909 samples · median 70 ppb · P95 467 ppb

HMTc sets 300 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 534 ppb, at or above the government ceiling of 300 ppb, so the government maximum binds. Why total mercury is limited →

Methylmercury

No citable primary occurrence measurement is routed to this cell in the corpus.

HMTc sets no standalone methylmercury limit for Fish: marine, non-predatory. MeHg is a component of tHg and bounded by it (MeHg <= tHg), so the tHg ceiling is the MeHg ceiling; no separate MeHg number is published. tHg is measured on every lot, and MeHg is speciated only when tHg exceeds its limit. Why methylmercury is limited →

1 study in the certified-market pool measured cadmium in Fish: marine, non-predatory across 15 certified-market samples. The pooled distribution centres on a median of 65 ppb and reaches 274 ppb at the 95th percentile. Singhato 2025.

1 study · 15 samples · median 65 ppb · P95 274 ppb

HMTc sets 50 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. The certified-market pool's P97 is 277 ppb (provisional), at or above the government ceiling of 50 ppb, so the government maximum binds. Why cadmium is limited →

Nickel

1 study in the certified-market pool measured nickel in Fish: marine, non-predatory across 57 certified-market samples. The pooled distribution centres on a median of 286 ppb and reaches 563 ppb at the 95th percentile. Yap-Almutairi 2022.

1 study · 57 samples · median 286 ppb · P95 563 ppb

HMTc sets 2 mg/kg by read-across: No government sets a nickel ML for animal seafood (EU 2024/1987 nickel covers plant foods and seaweed only). Read-across to the nearest whole-food nickel ceiling (EU 2024/1987 husked rice, 2000) that accommodates observed seafood nickel occurrence; clean product passes, grossly nickel-elevated product fails. Why nickel is limited →

Tin

10 studies in the corpus measured tin in Marine non-predatory fish (3562 samples reported across those studies): Jiang 2026, Uc-Peraza 2022, Wickramaarachchige 2022, Chung 2020, Lee 2016, Ho 2014, Olmedo 2013, Hu 2006 and 2 more.

10 studies · 3562 samples in the corpus

HMTc sets 200 mg/kg by read-across: Tin is a can-migration analyte; no government sets a tin ML for non-canned seafood (every seafood tin ML is canned/tinplate-only). Read-across to the EU 2023/915 general canned-food inorganic-tin ML (200000) as a packaging-migration baseline; fresh/frozen fin-fish has no tin source and passes. Canned product is certified under the canned-seafood subcategory. Why tin is limited →

Risk Flag

On the published occurrence literature to date, Marine non-predatory fish (sardine, anchovy, salmon, cod, herring, mackerel) 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.

Source regulations

Every published government regulation weighed to set this standard, evaluated against each other. The strictest applicable maximum level binds each analyte; the rest are comparators, and where no government regulates the exact product the value is read across from the nearest government limit. Follow a reference for the source document and its per-analyte limits: the Derivation table above shows every value side by side.

#RegulationYearInstrumentRole in this standard
1Commission Regulation (EU) 2023/915 and (EU) 2025/18912023Maximum levelsBinds inorganic arsenic, total mercury; Read-across for nickel, tin; Comparator for lead
2GSO 193: Gulf Technical Regulation2021Maximum levelsBinds cadmium; Comparator for lead, total mercury
3Fiji Food Safety Regulations2009Maximum levelsBinds lead; Comparator for total mercury, cadmium
4Paraguay Decreto 1335/20192019Maximum levelsBinds total arsenic; Comparator for lead, total mercury, cadmium
5GB 2762: National Food Safety Standard2022Maximum levelsRead-across for aluminium
6FSSAI (Contaminants, Toxins and Residues) Regulations2011Maximum levelsComparator for lead, total arsenic, cadmium, total chromium
7FSANZ Food Standards Code: Schedule 192015Maximum levelsComparator for lead, total arsenic, total mercury
8Costa Rica RTCR 409:2008: Reglamento de límites de contaminantes2008Maximum levelsComparator for lead, total mercury, cadmium
9Guyana Fisheries Products Regulations2023Maximum levelsComparator for lead, total mercury, cadmium
10Israel Food Contaminants Standard (FCS)2016Maximum levelsComparator for lead, total arsenic, total mercury, cadmium
11MERCOSUR GMC Resolución 12/20112011Maximum levelsComparator for lead, total arsenic, total mercury, cadmium
12Mexico NOM-242-SSA1-20092009Maximum levelsComparator for lead, cadmium
13Panama Resolución 368/20092009Maximum levelsComparator for lead, total mercury, cadmium
14Philippines PNS/BAFS 194:20172017Maximum levelsComparator for lead
15Singapore Food Regulations2023Maximum levelsComparator for total mercury
16Thailand MOPH Notification No. 4142020Maximum levelsComparator for lead, cadmium
17Trinidad & Tobago Food and Drugs Regulations2007Maximum levelsComparator for lead
18Uruguay Reglamento Bromatológico Nacional1994Maximum levelsComparator for total mercury
19Vietnam QCVN 8-2:2011/BYT2011Maximum levelsComparator for lead, total mercury, cadmium

Cite this standard

Pendergrass, K. (2026). Marine non-predatory fish (sardine, anchovy, salmon, cod, herring, mackerel): HMTc standard (Standard No. 10.83138/hmtc.std.6.fish-marine-non-predatory). Institute of Contaminant Standards. https://doi.org/10.83138/hmtc.std.6.fish-marine-non-predatory

© 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.

Version history

The dated editions of this standard. Each is kept at a stable permalink, so a regulator or brand can reconstruct exactly what the standard required on any date: the edition record, not an editorial commit trail. Version-pinned DOIs link here once each edition is deposited.

VersionDateStatusWhat changed
v1.02026-08-07currentInitial publication. Government-limit standard (Method v2.0) for lower-trophic marine fish, as-consumed. Mercury bound to the EU lower-mercury ceiling (tHg 300, MeHg 500). Every cell verified against the strictest sovereign maximum by adversarial audit.