How every number on this page is 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. 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.
| Analyte | Tier | HMTc limit | Binding basis |
|---|---|---|---|
| Lead (Pb) | Tier 1 | 1000 | strictest government ML (EU) |
| Inorganic arsenic (iAs) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Total arsenic (tAs) | Tier 2 | 1000 | strictest government ML (EU) |
| 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 | 1000 | strictest government ML (EU) |
| Hexavalent chromium (Cr-VI) | Tier 2 | 1000 | strictest government ML (EU) |
| 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 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.
| Analyte | HMTc | Binds |
|---|---|---|
| Lead (Pb) | 1000 | EU |
| Inorganic arsenic (iAs) | n/m³ | controlled |
| Total arsenic (tAs) | 1000 | EU |
| Mercury, total (tHg) | control&sup4; | screened |
| Methylmercury (MeHg) | n/m³ | controlled |
| Cadmium (Cd) | 1000 | EU |
| Hexavalent chromium (Cr-VI) | 1000 | EU |
| 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.
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.
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 →
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.
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 →
The corpus holds 1 measurement of nickel in Clothing (33 samples reported across those studies), which the determination below is tested against: Xiong 2025.
HMTc sets no standalone nickel limit for Clothing. No credible sovereign publishes a nickel CONTENT maximum for infant and toddler clothing. The governing instrument for the actual hazard — allergic contact dermatitis from prolonged skin contact with metal snaps, zip sliders and teeth, rivets, eyelets and decorative metal trim attached to the garment — is the REACH Annex XVII entry 27 nickel-release restriction, which is expressed as an areal release rate (µg/cm² per week) and therefore cannot be expressed in this register's µg/kg content unit; it is not present in the register in any form. The EN 71-3 toy nickel migration values and the EU 10/2011 nickel specific-migration value both sit in leachate bases outside this row's native basis. No number is invented: the cell is held under mandatory analytical control. The analyte is controlled by Mandatory total-nickel content analysis of every accessible metal, plated and alloy component by microwave-assisted acid digestion and ICP-MS, plus EN 1811 nickel-release testing (with EN 12472 wear-and-corrosion pre-treatment for coated or plated parts) on every component in prolonged skin contact, dispositioned against the release criterion in the REACH Annex XVII entry 27 restriction as a companion conformity obligation. That criterion's numeric value is deliberately NOT reproduced here: the restriction is absent from data/evidence/regulatory_limits.csv, and this standard quotes no number that is not carried by a named register row. The criterion is applied from the instrument text at audit and is logged as a register gap for ingest through the verified regulatory-fetch pathway. Any component exceeding the release criterion, or any total-nickel result that is an outlier against the supplier's own qualification data, triggers supplier corrective action under the HMTc control-and-escalation rule, not a standalone number. Why nickel is limited →
Cite this standard
Pendergrass, K. “Clothing (onesies, pajamas, outerwear).” In Heavy Metal Tested & Certified (HMTc) Infant and Child Durable Goods and Textiles (Ages 0-5) 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.