8 of 10 required analytes carry a numeric human-grade limit. Not material in this matrix: Tin (Sn), Hexavalent chromium (Cr-VI). A controlled analyte is measured on every lot with no defensible human-food number to anchor to; regulatory silence does not establish immateriality, and each not-material determination is registered and evidence-tested. This is the honest state of the science for this matrix, not a certification-readiness gap to hide.
How every number on this page is set
Pet food is legally governed by feed law — the EU’s Directive 2002/32 on undesirable substances in animal feed, the US FDA Center for Veterinary Medicine’s guidance, and the AAFCO model regulations, with enforced pet-food maxima in Japan and draft maxima in China. Those feed limits are generally far laxer than the limits the same governments set for human food. Heavy Metal Tested & Certified does not certify to the feed limit. For each analyte, the standard is the strictest maximum level a credible government sets for the nearest human food, adopted voluntarily as a human-grade over-compliance and stated in Milk replacers and specialty pet liquids’s own as consumed basis.
This is an intentional over-compliance, and it is disclosed as one. Every row below shows the feed-law floor the product is legally allowed to meet, and the tighter human-food limit HMTc certifies to instead. That honesty is the point: a certified pet food is held to the maximum levels that govern food for people, not the looser levels that govern feed for animals. Where the nearest human food is itself unregulated for an analyte, the standard does not invent a number: the analyte is a mandatory-tested control, or a registered, evidence-tested not-material determination.
Basis is never conflated. A dry product (kibble, semi-moist, freeze-dried, treats, chews) reads across only from dry human foods as sold; a wet product (canned, raw, broths, milk replacers, fish diets) only from human foods as consumed. No wet-to-dry conversion is performed, and where a human analog is published on a more concentrated basis than the pet product the adopted value is conservative, never loosened.
Master Limit Table
All values in ppb (µg/kg). Every numeric cell is the strictest human-food sovereign maximum for the nearest analog, adopted as the human-grade limit. A brand meeting every value qualifies for the mark.
| Analyte | Tier | HMTc limit | Basis |
|---|---|---|---|
| Lead (Pb) | Tier 1 | 20 | human-grade read-across (India) |
| Cadmium (Cd) | Tier 1 | 50 | human-grade read-across (Paraguay) |
| Total arsenic (tAs) | Tier 2 | 50 | human-grade read-across (Paraguay) |
| Inorganic arsenic (iAs) | Tier 1 | 100 | human-grade read-across (Israel) |
| Mercury, total (tHg) | Tier 1 | 50 | human-grade read-across (Vietnam) |
| Methylmercury (MeHg) | Tier 1 | n/m | not material in this matrix (see note) |
| Nickel (Ni) | Tier 2 | 100 | human-grade read-across (European Union) |
| Tin (Sn) | Tier 2 | n/m | not material in this matrix (see note) |
| Aluminium (Al) | Tier 2 | 500 | human-grade read-across (Australia / New Zealand) |
| Total chromium (Cr) | Tier 2 | 300 | human-grade read-across (China) |
| Hexavalent chromium (Cr-VI) | Tier 2 | n/m | not material in this matrix (see note) |
Tier 1 (Pb, Cd, iAs, mercury) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Ni, Sn, Al, chromium) carry a 150% transitional allowance under the program’s Status A–E framework. Total arsenic and total mercury operate as reflex screens to their toxic species (iAs, MeHg). Hexavalent chromium reduces to Cr(III) in the food matrix and is bounded by total chromium. “control” means measured every lot with no defensible human-food number; “n/m” is a registered not-material determination.
Feed law is the floor. HMTc certifies to human food.
The table below is the whole argument for the mark, stated plainly. The left column is the maximum a pet food is legally allowed to contain under feed law. The right columns are the tighter human-food limit HMTc certifies to instead, and the human food that limit comes from. The gap between them is the voluntary over-compliance a brand earns by certifying.
| Analyte | Feed-law floor (µg/kg) | HMTc human-grade limit | Over-compliance | Nearest human food |
|---|---|---|---|---|
| Lead (Pb) | 5,000 (Japan FAMIC, EU 2002/32, China (draft)) | 20 | 250× tighter | liquid milk and dairy products sold for human consumption |
| Cadmium (Cd) | 2,000 (Japan FAMIC, EU 2002/32, China (draft)) | 50 | 40× tighter | liquid milk and dairy products sold for human consumption |
| Total arsenic (tAs) | 2,000 (EU 2002/32, China (draft)) | 50 | 40× tighter | liquid milk and dairy products sold for human consumption |
| Inorganic arsenic (iAs) | 2,000 (Japan FAMIC, China (draft)) | 100 | 20× tighter | liquid milk and dairy products sold for human consumption |
| Mercury, total (tHg) | 300 (EU 2002/32, China (draft)) | 50 | 6× tighter | liquid milk and dairy products sold for human consumption |
| Nickel (Ni) | no feed limit set | 100 | EU liquid infant/young-child formula nickel maximum | |
| Tin (Sn) | no feed limit set | n/m | not material | |
| Aluminium (Al) | no feed limit set | 500 | AU-NZ non-soy infant-formula aluminium maximum | |
| Total chromium (Cr) | 5,000 (China (draft)) | 300 | 16.7× tighter | China GB 2762 total-chromium maximum for liquid milk |
Feed-law floor is the least strict of the applicable feed maxima (EU Directive 2002/32 complete/compound pet feed; Japan FAMIC pet-food standard; China draft pet-food guidance), stated for the strongest honest contrast. It is disclosed, never used to set the HMTc number. “No feed limit set” means feed law leaves the analyte unregulated, so the human-grade limit is not a reduction from a floor but a limit where feed law has none.
Derivation — where each number comes from
Every cell traces to one named sovereign human-food maximum level (the strictest for the nearest analog), or to an explicit control / not-material determination. No occurrence statistic and no feed limit selects a certification value.
| Analyte | HMTc | Human-food analog / determination |
|---|---|---|
| Lead (Pb) | 20 | India — Secondary milk products (as consumed) |
| Cadmium (Cd) | 50 | Paraguay — fluid milk ready for consumption and dairy products without addition, undiluted and unconcentrated |
| Total arsenic (tAs) | 50 | Paraguay — fluid milk ready for consumption and dairy products without addition, undiluted and unconcentrated |
| Inorganic arsenic (iAs) | 100 | Israel — Dairy products |
| Mercury, total (tHg) | 50 | Vietnam — Fluid milk products |
| Methylmercury (MeHg) | n/m | There is no methylmercury bioaccumulation pathway in dairy; bounded by total mercury, measured on every lot. |
| Nickel (Ni) | 100 | European Union — infant/young-child formula, liquid |
| Tin (Sn) | n/m | Tin is a packaging-migration analyte; non-tin-coated liquid milk replacers have no intrinsic tin pathway. A tin-coated pack is certified under the canned-wet tin read-across. |
| Aluminium (Al) | 500 | Australia / New Zealand — infant formula, follow-on formula, and special medical purpose product for infants other than preterm-infant products |
| Total chromium (Cr) | 300 | China — raw, pasteurized, sterilized, modified and fermented milk (GB 2762-2022 Table 7, section 4.7); total Cr, not Cr-VI |
| Hexavalent chromium (Cr-VI) | n/m | Hexavalent chromium reduces to Cr(III) in the milk matrix; bounded by total chromium, measured on every lot. |
Source instruments
Two legal registers set this page. The human-food maximum levels below are the standards HMTc certifies to; the strictest for the nearest analog binds each analyte. The feed-law floor is disclosed for contrast and never sets a number.
Human-food maximum levels (the certification basis):
| # | Instrument | Type | Role in this standard |
|---|---|---|---|
| 1 | Australia / New Zealand human-food maximum levels | Maximum levels | Binds Aluminium |
| 2 | China human-food maximum levels | Maximum levels | Binds Total chromium |
| 3 | European Union human-food maximum levels | Maximum levels | Binds Nickel |
| 4 | Israel human-food maximum levels | Maximum levels | Binds Inorganic arsenic |
| 5 | India human-food maximum levels | Maximum levels | Binds Lead |
| 6 | Paraguay human-food maximum levels | Maximum levels | Binds Cadmium, Total arsenic |
| 7 | Vietnam human-food maximum levels | Maximum levels | Binds Mercury, total |
Feed-law floor (disclosed, not applied): EU Directive 2002/32/EC on undesirable substances in animal feed (complete and compound pet feed); Japan FAMIC pet-food standard (2021); China draft pet-food guidance. Every value weighed against these is shown in the human-grade table above.
The literature baseline for pet-food occurrence and for each analyte is maintained independently at the Heavy Metal Index. This certification standard applies those findings; the two are kept editorially separate by design.
Cite this standard
Pendergrass, K. “Pet milk replacers & specialty liquids.” In Heavy Metal Tested & Certified (HMTc) Pet Foods standard, version 1.0. Institute of Contaminant Standards (ICS), 2026. DOI: registration pending.
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.
| Version | Date | Status | What changed |
|---|---|---|---|
| v1.0 | 2026-08-13 | current | Initial publication. Human-grade over-compliance (Method v2.0): pet food is legally feed, but every analyte is certified to the strictest human-food sovereign maximum for the nearest analog (as consumed basis), with the feed-law floor disclosed and never used to set a number. 8 of 10 analytes carry a numeric human-grade limit; the remainder are mandatory-tested controls or registered not-material determinations. |