How limits are set
The standard for each analyte is the strictest maximum level set by any credible government regulator, among them the European Union, Codex Alimentarius, the US FDA, Australia/New Zealand, the Gulf states (GSO), and the national authorities of every jurisdiction that regulates the product, converted into Pasta: wheat-based’s own as-sold 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-sold basis. 8 of 11 analytes carry a firm ceiling; the remaining 3 are toxic species bounded by their parent totals (species ≤ total, measured on every lot), so every analyte carries an enforceable 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 | 100 | strictest government ML (CU) |
| Inorganic arsenic (iAs) | Tier 1 | bounded | ≤ total tAs, measured every lot (see note) |
| Total arsenic (tAs) | Tier 2 | 200 | strictest government ML (Paraguay) |
| Mercury, total (tHg) | Tier 1 | 20 | strictest government ML (Hong Kong) |
| Methylmercury (MeHg) | Tier 1 | bounded | ≤ total tHg, measured every lot (see note) |
| Cadmium (Cd) | Tier 1 | 100 | strictest government ML (EU) |
| Total chromium (Cr) | Tier 2 | 1000 | strictest government ML (China) |
| Hexavalent chromium (Cr-VI) | Tier 2 | bounded | ≤ total Cr, measured every lot (see note) |
| Nickel (Ni) | Tier 2 | 800 | strictest government ML (EU) |
| Tin (Sn) | Tier 2 | 250000 | government read-across (Singapore) |
| Aluminium (Al) | Tier 2 | 200000 | government read-across (China) |
Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Cr, Cr-VI, Ni, Sn, Al) carry a 150% transitional allowance under the program’s Status A–E framework. Inorganic arsenic (iAs) is the arsenic species that binds on rice: rice hyperaccumulates arsenic, and every government that regulates it does so by product form (milled 150, parboiled/husked/rice-flour 250, rice products 300, rice drinks 30). Non-rice cereals do not hyperaccumulate arsenic, so iAs is not-material there and total arsenic (tAs) carries the government cereal ceiling instead. Mercury is limited as total mercury (tHg); methylmercury (MeHg), which no government regulates in grain, is bounded by the total-mercury ceiling. Hexavalent chromium (Cr-VI) is controlled by reflex speciation on total chromium, not an invented number. Tin (Sn) is material only for canned product, which routes to the canned-goods category. Aluminium (Al) has no government grain maximum in any jurisdiction.
Derivation
The full derivation for Pasta: wheat-based. 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 | EU | AU/NZ | GSO | China | India | Mercosur | Israel | Panama | Philippines | Paraguay | Thailand | Vietnam | CU | Hong Kong | CO | HMTc | Binds |
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Lead (Pb) | — | — | 200 | — | 200 | 200 | 200 | 200 | 200 | 200 | 200 | 200 | 100 | 200 | — | 100 | CU |
| Inorganic arsenic (iAs) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | bounded&sup5; | species ≤ tAs |
| Total arsenic (tAs) | — | 1000 | — | — | — | 200 | 1000 | — | — | 200 | — | — | — | 500 | — | 200 | Paraguay |
| Mercury, total (tHg) | — | — | — | — | — | — | — | — | — | — | — | — | — | 20 | — | 20 | Hong Kong |
| Methylmercury (MeHg) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | bounded&sup5; | species ≤ tHg |
| Cadmium (Cd) | 100 | 100 | 100 | — | 100 | 100 | 100 | — | 100 | 100 | 100 | 100 | 100 | 100 | 100 | 100 | EU |
| Total chromium (Cr) | — | — | — | 1000 | — | — | — | — | — | — | — | — | — | — | — | 1000 | China |
| Hexavalent chromium (Cr-VI) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | bounded&sup5; | species ≤ Cr |
| Nickel (Ni) | 800 | — | — | — | — | — | — | — | — | — | — | — | — | — | — | 800 | EU |
| Tin (Sn) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | 250000² | read-across |
| Aluminium (Al) | — | — | — | — | — | — | — | — | — | — | — | — | — | — | — | 200000² | read-across |
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. &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.
Risk Flag
On the published occurrence literature to date, Pasta, wheat-based 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 (as amended by (EU) 2023/465 for rice drinks) and (EU) 2024/1987 for nickel | 2023 | Maximum levels | Binds cadmium, nickel |
| 2 | GB 2762: National Food Safety Standard | 2022 | Maximum levels | Binds total chromium; Read-across for aluminium |
| 3 | Paraguay Decreto 1335/2019 | 2019 | Maximum levels | Binds total arsenic; Comparator for lead, cadmium |
| 4 | Singapore Food Regulations | 2023 | Maximum levels | Read-across for tin |
| 5 | FSSAI (Contaminants, Toxins and Residues) Regulations | 2011 | Maximum levels | Comparator for lead, cadmium |
| 6 | GSO 193, Gulf Technical Regulation | 2021 | Maximum levels | Comparator for lead, cadmium |
| 7 | FSANZ Food Standards Code, Schedule 19 | 2015 | Maximum levels | Comparator for total arsenic, cadmium |
| 8 | Israel Food Contaminants Standard (FCS) | 2016 | Maximum levels | Comparator for lead, total arsenic, cadmium |
| 9 | MERCOSUR GMC Resolución 12/2011 | 2011 | Maximum levels | Comparator for lead, total arsenic, cadmium |
| 10 | Panama Resolución 368/2009 | 2009 | Maximum levels | Comparator for lead |
| 11 | Philippines PNS/BAFS 194:2017 | 2017 | Maximum levels | Comparator for lead, cadmium |
| 12 | Thailand MOPH Notification No. 414 | 2020 | Maximum levels | Comparator for lead, cadmium |
| 13 | Vietnam QCVN 8-2:2011/BYT | 2011 | Maximum levels | Comparator for lead, cadmium |
Cite this standard
Pendergrass, K. “Pasta: wheat-based.” In Heavy Metal Tested & Certified (HMTc) Grains, Cereals, and Rice Products 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.