How limits are set
The standard for each analyte is the strictest maximum level set by any credible government regulator, the European Union, the United Kingdom, Codex Alimentarius, Health Canada, China, India, Brazil, the Gulf states (GSO), Australia/New Zealand, and the US FDA, converted into Mixed meals (meat & grain combinations)’s own as-consumed basis. It is a lookup of sovereign law, carrying at most one disclosed basis conversion where the law is written in another basis, and an explicit read-across where no government regulates the exact product. A certified product sits at or below every applicable sovereign limit at once.
Where no government regulates the exact product for an analyte, the standard does not go blank or invent a number: the limit is read across from the nearest government value for an analogous product, so a certified product still sits at or below a real sovereign limit. The ratchet tightens these after publication as surveillance warrants.
Master Limit Table
All values in ppb (µg/kg), as-consumed basis. Every analyte carries a firm ceiling. A brand meeting every value on a like-for-like basis qualifies for the mark.
| Analyte | Tier | HMTc limit | Binding basis |
|---|---|---|---|
| Lead (Pb) | Tier 1 | 10 | strictest government ML (Brazil) |
| Inorganic arsenic (iAs) | Tier 1 | 20 | strictest government ML (EU) |
| Total arsenic (tAs) | Tier 2 | 50 | strictest government ML (India) |
| Mercury (tHg) | Tier 1 | 8 | strictest government ML (IL) |
| Cadmium (Cd) | Tier 1 | 40 | strictest government ML (EU) |
| Total chromium (Cr) | Tier 2 | 500 | strictest government ML (HK) |
| Nickel (Ni) | Tier 2 | 500 | strictest government ML (EU) |
| Tin (Sn) | Tier 2 | 5000 | strictest government ML (India) |
| Aluminium (Al) | Tier 2 | 500 | government read-across (AU-NZ Schedule 19 infant-formula Al 500, the only government aluminium ML in any jurisdiction) applied at face value; the 8:1 reconstitution factor is formula-specific and is not applied to a non-formula product. |
Tier 1 (Pb, Cd, iAs, Hg) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Ni, Al, Sn, Cr) are held to the same government limit: tiering sets how the program reacts to an exceedance, not any permission to exceed it. A product is certified only when every analyte is at or below 100% of its published limit; above the limit, on any metal, it is not certified and carries no mark. Arsenic is limited in both forms: total arsenic (tAs) and inorganic arsenic (iAs) are separate ceilings that must both be met, and the species result never replaces the parent total. Total chromium is limited as shown; hexavalent chromium is controlled through it: mandatory Cr-VI speciation on any total-chromium result above 100 ppb, and any quantifiable Cr-VI fails.
Derivation
The full derivation for Mixed meals (meat & grain combinations). Each row lists every government maximum level in force worldwide, converted to the as-consumed 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 | EU | UK | Codex | China | India | Brazil | GSO | HMTc | Binds |
|---|---|---|---|---|---|---|---|---|---|
| Lead (Pb) | — | — | 20¹ | — | 200¹ | 10 | — | 10 | Brazil |
| Inorganic arsenic (iAs) | 20¹ | — | — | 200¹ | — | 150¹ | — | 20 | EU |
| Total arsenic (tAs) | — | — | — | — | 50¹ | — | — | 50 | India |
| Mercury (tHg) | — | — | — | — | — | — | — | 8 | IL |
| Cadmium (Cd) | 40¹ | 40¹ | — | 60¹ | 100¹ | 50¹ | 40¹ | 40 | EU |
| Total chromium (Cr) | — | — | — | — | — | — | — | 500 | HK |
| Nickel (Ni) | 500¹ | — | — | — | — | — | — | 500 | EU |
| Tin (Sn) | — | — | — | — | 5000¹ | — | — | 5000 | India |
| Aluminium (Al) | — | — | — | — | — | — | — | 500² | read-across |
All values µg/kg (ppb), as-consumed basis. ¹ basis-converted at the 8:1 powder-to-liquid ratio: the only such ratio a government legislates (China GB 2762 footnote c). ² read-across: no government sets this analyte for this exact product; the value is read across from the nearest government value for an analogous product. ³ not material in this matrix: measured but with no standalone number, controlled by the total-metal screen, not an invented value.
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.
2 studies in the certified-market pool measured lead in Mixed Meals, Non-Rice across 108 certified-market samples. The pooled distribution centres on a median of 0.2 ppb and reaches 3.9 ppb at the 95th percentile, with a measured maximum of 13 ppb. FDA 2024, Starska 2011.
HMTc sets 10 ppb (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 7.6 ppb (provisional), against a government ceiling of 10 ppb. Why lead is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 20 ppb (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 31 ppb, at or above the government ceiling of 20 ppb, so the government maximum binds. Why inorganic arsenic is limited →
2 studies in the corpus measured total arsenic in Mixed Meals, Non-Rice (561 samples reported across those studies): Starska 2011, FDA 2024. Reported concentrations range from 0 ppb to 14 ppb, with a typical value of 3 ppb.
HMTc sets 50 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why total arsenic is limited →
2 studies in the corpus measured total mercury in Mixed Meals, Non-Rice (519 samples reported across those studies): FDA 2024, Starska 2011. Reported concentrations range from 0 ppb to 0.4 ppb, with a typical value of 0 ppb.
HMTc sets 8 ppb (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why total mercury is limited →
3 studies in the certified-market pool measured cadmium in Mixed Meals, Non-Rice across 1045 certified-market samples. The pooled distribution centres on a median of 0.9 ppb and reaches 4.3 ppb at the 95th percentile, with a measured maximum of 44 ppb. Starska 2011, FDA 2024, Collado-Lopez 2025.
HMTc sets 40 ppb (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 5.1 ppb, against a government ceiling of 40 ppb. Why cadmium is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 500 ppb (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 180 ppb, against a government ceiling of 500 ppb. Why nickel is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 5 mg/kg (regulatory-alignment): the strictest applicable government maximum level for this product form, adopted under Method v2.0 as the default certification standard. Why tin is limited →
3 studies in the corpus measured aluminium in Mixed meals (meat & grain combos), non-rice (2068 samples reported across those studies): Ibrahim 2025, Stahl 2017, Sipahi 2014.
HMTc sets 500 ppb by read-across: government read-across (AU-NZ Schedule 19 infant-formula Al 500, the only government aluminium ML in any jurisdiction) applied at face value; the 8:1 reconstitution factor is formula-specific and is not applied to a non-formula product. Why aluminium is limited →
Risk Flag
On the published occurrence literature to date, Mixed meals (meat & grain combinations) 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.
Source regulations
Every published government regulation weighed to set this standard, evaluated against each other. The strictest applicable maximum level binds each analyte; the rest are comparators, and where no government regulates the exact product the value is read across from the nearest government limit. Follow a reference for the source document and its per-analyte limits: the Derivation table above shows every value side by side.
| # | Regulation | Year | Instrument | Role in this standard |
|---|---|---|---|---|
| 1 | Commission Regulation (EU) 2023/915 | 2023 | Maximum levels | Binds inorganic arsenic, cadmium, nickel |
| 2 | FSSAI (Contaminants, Toxins and Residues) Regulations | 2011 | Maximum levels | Binds tin; Comparator for lead, cadmium |
| 3 | ANVISA RDC: Inorganic Contaminant Limits | 2022 | Maximum levels | Binds lead; Comparator for inorganic arsenic, cadmium |
| 4 | Israel Food Contaminants Standard (FCS) | 2016 | Maximum levels | Binds total mercury; Comparator for lead, inorganic arsenic, cadmium |
| 5 | FSANZ Food Standards Code: Schedule 19 | 2015 | Maximum levels | Read-across for aluminium |
| 6 | Contaminants in Food (retained Reg. 1881/2006) | 2006 | Maximum levels | Comparator for cadmium |
| 7 | Codex General Standard CXS 193-1995 | 1995 | Codex standard | Comparator for lead |
| 8 | GB 2762, National Food Safety Standard | 2022 | Maximum levels | Comparator for inorganic arsenic, cadmium |
| 9 | GSO 193, Gulf Technical Regulation | 2021 | Maximum levels | Comparator for cadmium |
| 10 | Singapore Food Regulations | 2023 | Maximum levels | Comparator for lead |
Cite this standard
Pendergrass, K. (2026). Mixed meals (meat & grain combinations): HMTc standard (Standard No. 10.83138/hmtc.std.1.mixed-meals). Institute of Contaminant Standards. https://doi.org/10.83138/hmtc.std.1.mixed-meals
© 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.
Version history
The dated editions of this standard. Each is kept at a stable permalink, so a regulator or brand can reconstruct exactly what the standard required on any date: the edition record, not an editorial commit trail. Version-pinned DOIs link here once each edition is deposited.
| Version | Date | Status | What changed |
|---|---|---|---|
| v1.1 | 2026-08-06 | current | Register-completeness correction. Mercury tightened 20→8 (Israel FCS-2016 baby-food ML). Compiler hardened (multilingual canned-gating, powder-scoped reconstitution, read-across as comparator) against a 7× expanded government register. |
| v1.0 | 2026-08-06 | superseded | Initial publication. Government-limit standard (Method v2.0): each analyte is the strictest sovereign maximum by lookup, converted to the as-consumed basis; a disclosed read-across from the nearest government value where no government regulates the exact product; total chromium controlled via reflex Cr-VI speciation where not a material toxic in the matrix. |