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-sold basis. 1 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 | 2000 | government read-across (Hong Kong) |
| Inorganic arsenic (iAs) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Total arsenic (tAs) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Mercury, total (tHg) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Cadmium (Cd) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Hexavalent chromium (Cr-VI) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| Nickel (Ni) | Tier 2 | control | mandatory control — no government ML; screened every lot (see note) |
| 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 Herbal/botanical infusions. 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) | 2000² | read-across |
| Inorganic arsenic (iAs) | control&sup4; | screened |
| Total arsenic (tAs) | control&sup4; | screened |
| Mercury, total (tHg) | control&sup4; | screened |
| Methylmercury (MeHg) | n/m³ | controlled |
| Cadmium (Cd) | control&sup4; | screened |
| Hexavalent chromium (Cr-VI) | control&sup4; | screened |
| Nickel (Ni) | control&sup4; | screened |
| 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.
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.
9 studies in the corpus measured lead in Herbal/botanical infusions (1304 samples reported across those studies): Bandara 2025, Feszterova 2025, Kowalski 2024, Marinescu 2020, Deoliveira 2018, Kocevar-Glavac 2017, Miroslawski 2017, Santos 2017 and 1 more.
HMTc sets 2 mg/kg by read-across: No credible sovereign has written a general lead maximum level for dried herbal or botanical infusion material. Hong Kong Cap 132V is the only credible instrument that reaches this commodity class at all, and it does so through two named botanicals: Broadleaf Holly leaves at 2000 ug/kg and Dried chrysanthemum at 5000 ug/kg, both as sold. The stricter of the two named infusion-botanical cells (2000 ug/kg) is adopted by disclosed read-across as the row ceiling. Why lead is limited →
The corpus holds 9 measurements of cadmium in Herbal/botanical infusions (1289 samples reported across those studies), which the determination below is tested against: Bandara 2025, Kowalski 2024, Njinga 2022, Marinescu 2020, Deoliveira 2018, Kocevar-Glavac 2017, Miroslawski 2017, Santos 2017 and 1 more.
HMTc sets no standalone cadmium limit for Herbal/botanical infusions. No credible sovereign sets a cadmium maximum level for dried herbal or botanical infusion material. Hong Kong Cap 132V, the only credible instrument that names infusion botanicals at all, sets lead values for them but no cadmium value; EU 2023/915, Codex CXS 193, FSANZ Schedule 19 and Health Canada set no cadmium cell for herbal infusions or for tea. Two EU cells reach the nearest commodities and both were considered and rejected: the leaf-vegetable cadmium cell (100 ug/kg, eu2023_cd_leaf_vegetables_100) and the spinaches, similar leaves, mustard seedlings and fresh herbs cell (200 ug/kg, eu2023_cd_spinach_herbs_200), which is the closest sovereign cadmium cell to this commodity that exists. Both are fresh-weight edible-portion values for a plant eaten whole while fresh, and carrying either onto a dried botanical sold as sold would require an invented drying factor of roughly an order of magnitude; the register records both on a wet-weight basis and this row's basis guard refuses them for that reason. 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 →
The corpus holds 3 measurements of aluminium in Herbal/botanical infusions (98 samples reported across those studies), which the determination below is tested against: Bandara 2025, Fogarasi 2019, Deoliveira 2018.
HMTc sets no standalone aluminium limit for Herbal/botanical infusions. No credible sovereign sets an aluminium maximum level for dried herbal or botanical infusion material, and no near-neighbour read-across is supportable: the only sovereign aluminium values are packaged-drinking-water quality standards written in a litre-of-water basis (Category 8) and the FSANZ infant-formula limits (Category 1). Applying a water-basis value to a dry commodity would be a basis conflation of roughly three orders of magnitude. Aluminium is a live cell for this row and is not treated as a formality: several infusion botanicals are aluminium accumulators, and no credible sovereign has set a ceiling, so the analyte is reported on every certified lot and the gap is disclosed on the certificate rather than papered over with a number HMTc would have had to invent. The analyte is controlled by Total aluminium by ICP-MS on every certified lot, reported on the certificate in the as-sold dry basis. A result that departs materially from the applicant's own documented origin and process baseline escalates to a soil, cultivar and processing-aid investigation. This is a process-control tripwire, not a numeric standard: no ceiling is published because no credible sovereign maximum exists for this cell, not a standalone number. Why aluminium is limited →
Cite this standard
Pendergrass, K. “Herbal/botanical infusions.” 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.