Plant-based meat alternatives (burgers, sausages, nuggets; pea/soy/wheat-protein base) — HMTc Standard

How limits are set

Category-specific method notes. (1) MUSCLE MEAT vs OFFAL. Every credible instrument writes separate and materially looser maximum levels for edible offal, because lead and cadmium concentrate in liver and kidney.

Every row here is scoped to muscle meat and attached edible fat; offal of the same species is a separately-tested sub-lot assessed against that species' offal maximum levels, and no offal value anchors a muscle-meat row. The taxonomy boundary rule places offal inside the animal's own subcategory, which is honoured by sub-lot testing rather than by publishing an offal-derived ceiling.

(2) THE CATEGORY 1 BOUNDARY. Products marketed for ages 0-5 route to Category 1 (mixed meals), so the infant and baby-food action levels and maximum levels that would otherwise be the strictest values in the register are excluded by applicability from every row here, and are excluded explicitly in each row's audit_exclude_scope.

(3) GAME AND LEAD AMMUNITION. Fragmenting lead projectiles are a documented, mechanical lead pathway in wild-harvested game. That evidence drives mandatory radiographic fragment screening before grinding and priority surveillance on the game row; it does not and cannot move the number, which remains a disclosed read-across from the domestic-mammal muscle-meat maximum level.

(4) BASIS TREATMENT ON THE THREE COMPOSITE ROWS, DISCLOSED IN THE DIRECTION IT CUTS. On the processed-meat, canned-meat and analogue rows the component maximum level is applied to the finished product as sold, with no invented conversion factor. This config does NOT claim that treatment is conservative, because it is not: a formulation that is part water, brine, starch or rusk can carry a higher concentration in its meat or protein fraction than the component maximum level itself allows.

The gap is closed by a second, independent obligation rather than by a conversion factor. Certification of those three rows requires documented compliance of the raw material or source commodity against the same named component maximum levels, in their own basis, IN ADDITION to finished-product compliance against the published ceiling; neither test substitutes for the other.

The eggs row runs the opposite way and is treated accordingly: dried and powdered egg is concentrated relative to whole egg, so applying the whole-egg maximum level to the powder as sold is the STRICTER treatment, and it is applied without being reversed.

(5) REGISTER GAPS ARE DISCLOSED, NOT FILLED. The EU 2023/915 and Codex CXS 193 lead rows for meat and offal, the EU and Codex cadmium offal rows, and the FSANZ cadmium meat and offal rows are absent from this register. They are recorded as register gaps for ingestion through the verified regulatory-fetch pathway and are NOT written into this config from memory. No absent row is assigned a remembered value anywhere in this config.

Because the method selects the strictest applicable value, ingesting a missing row can only lower a published cell or leave it unchanged, never raise it; every affected cell must be re-derived when the missing rows land.

Master Limit Table

All values in ppb (µg/kg), as-sold basis. 5 of 11 analytes carry a firm ceiling; the remaining 5 are governed by mandatory control or the total-metal screen 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.

Every claim analyte is equal at the gate. A product is certified only when every analyte is at or below 100% of its published government floor or disclosed read-across; above the limit, on any metal, it is not certified and carries no mark.

Derivation

The full derivation for Plant-based meat alternatives (burgers, sausages, nuggets; pea/soy/wheat-protein base). 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.

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. &sup4; no sovereign maximum exists for this analyte in this product, but a credible exposure pathway does — it is screened on every lot under ALARA against the tightest analogous reference, not assigned an invented number.

Risk Flag

On the published occurrence literature to date, Plant-based meat alternatives (burgers, sausages, nuggets; pea/soy/wheat-protein base) 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.