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. 0 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 | control | mandatory control — no government ML; screened every lot (see note) |
| Cadmium (Cd) | 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) |
| Inorganic arsenic (iAs) | Tier 1 | 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) |
| 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) |
| 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 — mandatory control, no sovereign limit
No government sets a heavy-metal content limit for Menstrual pads and liners. Every analyte on the panel is held under mandatory control — measured on every lot and escalated against route-appropriate toxicological anchors — or, where the chemistry rules it out of the matrix, recorded as a substantiated not-material determination. No number is invented.
| Analyte | HMTc | Binding | Basis |
|---|---|---|---|
| Lead (Pb) | control | screened every lot | mandatory control — no government ML |
| Cadmium (Cd) | control | screened every lot | mandatory control — no government ML |
| Total arsenic (tAs) | control | screened every lot | mandatory control — no government ML |
| Inorganic arsenic (iAs) | control | screened every lot | mandatory control — no government ML |
| Mercury, total (tHg) | control | screened every lot | mandatory control — no government ML |
| Methylmercury (MeHg) | n/m | ≤ tHg | not material in this matrix |
| Nickel (Ni) | control | screened every lot | mandatory control — no government ML |
| Tin (Sn) | control | screened every lot | mandatory control — no government ML |
| 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. “Menstrual pads and liners.” 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.