Sun/suntan products (including spray, self-tan, airbrush) — HMTc Standard

How limits are set

Five method points govern this category and each is visible in the records.

(1) The credible set is widened because the default set does not write this family. The EU bans these elements as intentional cosmetic ingredients without publishing a numeric trace ceiling, Codex has no cosmetic standard, and FSANZ does not regulate cosmetics; every numeric finished-cosmetic value in the register comes from a national or regional competent authority.

(1a) The instrument status of the binding tier is disclosed, not dressed up. The German BVL 2017 values that bind lead, cadmium, arsenic and mercury across this category are recorded in the register with status ‘guidance impurity limit’: they are orientation values published by the German Federal Office of Consumer Protection and Food Safety for heavy-metal contents considered technically AVOIDABLE under good manufacturing practice, operating against the EU Article 17 requirement that traces be technically unavoidable, rather than a maximum level written into a statute.

HMTc adopts them because they are the strictest applicable maximum published by a national competent authority for this exact product family, and because Category 15 already rests on the same instrument. A hostile reader should be told two further things rather than discover them.

First, the STATUTORY floor in this family sits well above the adopted value: China NMPA 2015 and Taiwan MOHW 2024 (lead 10000, cadmium 5000, arsenic 2000-3000, mercury 1000 ug/kg) and the US FDA 21 CFR 700.13 mercury adulteration rule (1000) are binding instruments, and every product meeting an HMTc cell in this category satisfies all of them by construction, so certification never depends on the guidance status of the German table. Second, the nickel cells rest on Korea MFDS, which IS a statutory instrument.

Adopting a guidance value that is stricter than every statute in the family moves the standard toward more protection, never less, so the status question affects how the value is described and never whether a certified product is lawful.

(2) Where a taxonomy row bundles forms that a government instrument splits, the row binds at the strictest value applicable to ANY form in it, so a published ceiling is never looser than the government value for a product certified against it. That is why the makeup, body-paint and eye-makeup rows bind lead at the German general 2000 ug/kg rather than the higher 5000 make-up branch: liquid foundation, mascara, brow products, primers and fixatives are not in the higher branch and take the general value.

Where EVERY form in a row falls inside a government split, the split’s value binds instead — traditional eye cosmetics, whose forms are the ‘kajal’ the German instrument names at 5000, and the Korean nickel tiers. Over-compliance created by row aggregation is disclosed in the affected cell, never presented as a government requirement.

(3) Read-across is reached only when the exact cell is unregulated, so it is used nowhere in this category: every form here has a directly applicable general-cosmetic instrument. In particular the German dentifrice tier (lead 500 ug/kg) is NOT read across onto lip products, even though lip products are partly ingested and that is the dentifrice tier’s own rationale, because the exact cell is already regulated by the general branch and stretching a toothpaste value onto a non-toothpaste form is the conflation this method forbids. The absence of any sovereign lip-specific ceiling is recorded as a standards gap.

(4) Aluminium, tin and total chromium have no sovereign cosmetic maximum in any jurisdiction checked, and inorganic arsenic and Cr(VI) have none for any form except tattoo mixtures. All are controls: testing is mandatory, escalation rules are published, and no ceiling is invented. Total chromium is the mandatory screen that governs the Cr(VI) reflex, and is not a protective standalone ceiling because cosmetic total chromium is dominated by benign Cr(III) pigments.

Methylmercury is the category’s only speciation-bounded not-material determination, bounded by the published total-mercury cell and reopened by reflex for any marine-, fish- or algal-derived ingredient.

Cr(VI) is deliberately NOT treated as a method artifact: the EU legislated a Cr(VI) limit for tattoo mixtures precisely because the species occurs in inorganic pigments.

(5) Intentional-use allowances are permissions, not ceilings, and none is adopted: the mercurial eye-preservative carve-outs (Hong Kong and India 70 ppm, South Africa 65 ppm, New Zealand 0.007 percent), the Australian lead-acetate hair-treatment exception, and the aluminium active permission in antiperspirants.

Prohibitions are enforced alongside the numbers rather than converted into them: the United States does not permit kohl as a colour additive and revoked the lead-acetate hair-dye listing, so a product with an unlawful composition in a target market cannot be certified whatever its measured values.

Master Limit Table

All values in ppb (µg/kg), as-consumed basis. 9 of 11 analytes carry a firm ceiling; the remaining 2 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.

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 Sun/suntan products (including spray, self-tan, airbrush). 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.

All values µg/kg (ppb), as-consumed 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.

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.

Risk Flag

On the published occurrence literature to date, Sun/suntan products (including spray, self-tan, airbrush) 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.