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Clothing (onesies, pajamas, outerwear) — HMTc Standard

Standard

The Heavy Metal Tested & Certified heavy-metal-safety standard for clothing (onesies, pajamas, outerwear) in Infant and Child Durable Goods and Textiles (Ages 0-5), evaluated on extractable element content of the homogeneous textile material after the REACH Annex XVII entry 72 Appendix 12 extraction (mg/kg of homogeneous material) — an extraction basis, not a total-content or toy-migration basis. 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.

How limits are set

Category-specific notes. (1) Species never replace totals: the arsenic values carried by the Australian coating instrument and by REACH Annex XVII entry 72 are unspeciated and are published on tAs, never on iAs; total chromium is reported as a SCREEN because it is dominated by benign Cr(III), with Cr(VI) dispositioned separately.

(2) Where the strictest component limit is stricter than another component's own limit, HMTc applies the strictest article-wide — deliberate over-compliance, disclosed in the component set rather than applied silently.

(3) Sub-national US statutes that are stricter than the adopted anchors (the Washington Children's Safe Product Act at 40 mg/kg cadmium, Minnesota Statutes 325E.3892 at 75 mg/kg cadmium) are disclosed as jurisdiction-specific companion obligations and logged as register gaps: each statute's own covered-product definition is narrower than the CPSIA children's-product definition, and the register's scope text does not establish whether these product forms are inside the covered list, so applicability to the exact cell cannot be resolved and the value cannot be selected.

(4) Nickel is a control on every row in the category because the governing instrument, the REACH Annex XVII entry 27 nickel-release restriction, is expressed as an areal release rate in µg/cm² per week and is not present in the register; EN 1811 testing is required as a companion obligation regardless.

(5) Two instruments named in the taxonomy row's regulatory_anchors cannot supply a number under Method v2.0 and are recorded here so their absence is not read as an oversight.

OEKO-TEX Standard 100 is a private voluntary certification scheme, not a sovereign instrument, so its extractable-metal values cannot anchor an HMTc cell however strict they are; its extraction philosophy is the same one REACH Annex XVII entry 72 Appendix 12 codifies, and entry 72 is the sovereign instrument this category's textile rows are built on.

ASTM F963 is mandatory in the US under CPSIA s.106, but its element limits sit in a SOLUBLE (migrated) basis; its lead, cadmium, arsenic, mercury and total-chromium values are therefore companion conformity obligations for toy and toy-adjacent components and are excluded from every row's anchor set by the basis guard, notwithstanding that several of them are numerically identical to the content values adopted here.

(6) The CPSC durable-infant-or-toddler-product list, also named in the taxonomy row, is a registration and standards-scoping instrument and sets no heavy-metal value; it informs which product forms belong in this category, not what any cell equals.

Master Limit Table

All values in ppb (µg/kg), as-sold basis. 8 of 11 analytes carry a firm ceiling; 2 are toxic species bounded by their parent totals (species ≤ total, measured on every lot), and the remaining 1 are governed by mandatory control or the total-metal screen 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.

AnalyteHMTc limitBinding basis
Lead (Pb)1000strictest government ML (EU)
Inorganic arsenic (iAs)bounded≤ total tAs, measured every lot (see note)
Total arsenic (tAs)1000strictest government ML (EU)
Mercury, total (tHg)1900government read-across (EU)
Methylmercury (MeHg)bounded≤ total tHg, measured every lot (see note)
Cadmium (Cd)1000strictest government ML (EU)
Hexavalent chromium (Cr-VI)1000strictest government ML (EU)
Nickel (Ni)18800government read-across (EU)
Tin (Sn)1000000government read-across (EU)
Aluminium (Al)560000government read-across (EU)
Total chromium (Cr)controlmandatory control — no government ML; screened every lot (see note)

Every claim analyte is equal at the gate. A product is certified only when every analyte is at or below 100% of its published government floor or disclosed read-across; above the limit, on any metal, it is not certified and carries no mark.

Derivation

The full derivation for Clothing (onesies, pajamas, outerwear). 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.

AnalyteHMTcBinds
Lead (Pb)1000EU
Inorganic arsenic (iAs)bounded&sup5;species ≤ tAs
Total arsenic (tAs)1000EU
Mercury, total (tHg)1900²read-across
Methylmercury (MeHg)bounded&sup5;species ≤ tHg
Cadmium (Cd)1000EU
Hexavalent chromium (Cr-VI)1000EU
Nickel (Ni)18800²read-across
Tin (Sn)1000000²read-across
Aluminium (Al)560000²read-across
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: measured but with no standalone number, controlled by packaging control or by the total-metal screen, not an invented value. &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. &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.

Lead

1 study in the certified-market pool measured lead in Clothing across 33 certified-market samples. The pooled distribution centres on a median of 174 ppb and reaches 280 ppb at the 95th percentile. Xiong 2025.

1 study · 33 samples · median 174 ppb · P95 280 ppb

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 310 ppb (provisional), against a government ceiling of 1 mg/kg. Why lead is limited →

Cadmium

1 study in the certified-market pool measured cadmium in Clothing across 33 certified-market samples. The pooled distribution centres on a median of 152 ppb and reaches 187 ppb at the 95th percentile. Xiong 2025.

1 study · 33 samples · median 152 ppb · P95 187 ppb

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 194 ppb, against a government ceiling of 1 mg/kg. Why cadmium is limited →

Nickel

1 study in the certified-market pool measured nickel in Clothing across 33 certified-market samples. The pooled distribution centres on a median of 1.3 mg/kg and reaches 3.5 mg/kg at the 95th percentile. Xiong 2025.

1 study · 33 samples · median 1.3 mg/kg · P95 3.5 mg/kg

HMTc sets 18.8 mg/kg by read-across: Ni 18800 ug/kg: disclosed read-across from EU eu_2009_48_cat2_ni_toy_migration (toys (accessible toy material); pacifiers/soothe). Filled by the completeness sweep; nearest applicable sovereign for this matrix and basis. Why nickel is limited →

Risk Flag

On the published occurrence literature to date, Clothing (onesies, pajamas, outerwear) 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.

Cite this standard

Pendergrass, K. (2026). Clothing (onesies, pajamas, outerwear): HMTc standard. Institute of Contaminant Standards.

© 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.