How every number on this page is set
Feminine-care products contact the vulvovaginal mucosa, which is markedly more permeable and bioavailable than intact skin; the standard is written on a mucosal basis and never on a dermal or dietary basis. The category splits into two instrument families that share this basis but are never conflated. Device forms — tampons, pads, cups, discs, period underwear — are regulated as medical devices for biocompatibility (21 CFR Part 884; EU MDR 2017/745; ISO 10993), but no government sets a numeric heavy-metal content limit for the finished device in any jurisdiction, so every panel analyte resolves to a mandatory analytical control or a substantiated not-material determination, never an invented number.
Cosmetic forms — feminine wipes, deodorants, douches, intimate washes — are cosmetics, so sovereign cosmetic contaminant limits apply, adopted at the strictest mucosal-contact tier a government draws. Lead reads across the German BVL 2017 toothpaste tier (500 µg/kg, stricter than the general-cosmetic 2000 because vaginal mucosa is more permeable than the oral mucosa that limit was written for); cadmium (100), total arsenic (500) and total mercury (100) bind the strictest general-cosmetic value directly; and nickel binds the only sovereign cosmetic nickel content limit (Korea MFDS 2025, 10000). Occurrence establishes materiality — a metal a routed survey measures present cannot be recorded not-material — but never sets the number.
Master Limit Table
All values in ppb (µg/kg), as-sold basis. 5 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 | 500 | German BVL 2017 sovereign mucosal-contact cosmetic tier (toothpaste, 500 ug/kg) |
| Cadmium (Cd) | Tier 1 | 100 | strictest government ML (DE) |
| Total arsenic (tAs) | Tier 2 | 500 | strictest government ML (DE) |
| Inorganic arsenic (iAs) | Tier 1 | control | mandatory control — no government ML; screened every lot (see note) |
| Mercury, total (tHg) | Tier 1 | 100 | strictest government ML (DE) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material — controlled analyte (see note) |
| Nickel (Ni) | Tier 2 | 10000 | strictest government ML (KR) |
| Tin (Sn) | Tier 2 | n/m | not material — controlled analyte (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) |
| Hexavalent chromium (Cr-VI) | 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, Ni, Sn, Al, Cr, Cr-VI) carry a 150% transitional allowance under the program’s Status A–E framework.
Derivation — the binding sovereign limit
For Intimate washes and cleansers, each HMTc limit is the strictest maximum level any credible government sets for the product, named in the Binding column with the count of jurisdictions that concur at that value. Where no government regulates the analyte, the cell is a mandatory control or a not-material determination, never an invented number.
| Analyte | HMTc | Binding | Basis |
|---|---|---|---|
| Lead (Pb) | 500 | DE | disclosed read-across |
| Cadmium (Cd) | 100 | DE | direct sovereign ML |
| Total arsenic (tAs) | 500 | DE | direct sovereign ML |
| Inorganic arsenic (iAs) | control | screened every lot | mandatory control — no government ML |
| Mercury, total (tHg) | 100 | DE | direct sovereign ML |
| Methylmercury (MeHg) | n/m | ≤ tHg | not material in this matrix |
| Nickel (Ni) | 10000 | KR | direct sovereign ML |
| Tin (Sn) | n/m | controlled | not material in this matrix |
| Aluminium (Al) | control | screened every lot | mandatory control — no government ML |
| Total chromium (Cr) | control | screened every lot | mandatory control — no government ML |
| Hexavalent chromium (Cr-VI) | control | screened every lot | mandatory control — no government ML |
Cite this standard
Pendergrass, K. “Intimate washes and cleansers.” In Heavy Metal Tested & Certified (HMTc) Feminine Care 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.