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 Teething biscuits & finger snacks’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. Every analyte carries a firm ceiling. A brand meeting every value on a like-for-like basis qualifies for the mark.
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 Teething biscuits & finger snacks. 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 | UK | Codex | Canada | China | India | Brazil | GSO | AU/NZ | FDA | HMTc | Binds |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| Lead (Pb) | 20¹ | 50¹ | 20¹ | — | — | 200¹ | 20¹ | — | — | 20¹ | 20 | EU |
| Inorganic arsenic (iAs) | 20 | — | — | 100¹ | 200¹ | — | 150¹ | 100¹ | — | — | 20² | read-across |
| Total arsenic (tAs) | — | — | — | — | — | 50¹ | — | — | — | — | 50 | India |
| Mercury (tHg) | — | — | — | — | — | — | — | — | — | — | 8² | read-across |
| Cadmium (Cd) | 40¹ | 40¹ | — | — | 60¹ | 100¹ | 50¹ | 40¹ | 100¹ | — | 40 | EU |
| Total chromium (Cr) | — | — | — | — | — | — | — | — | — | — | 1000² | read-across |
| Nickel (Ni) | 3000¹ | — | — | — | — | — | — | — | — | — | 3000 | EU |
| Tin (Sn) | — | — | — | — | — | 5000¹ | — | — | — | — | 5000 | India |
| Aluminium (Al) | — | — | — | — | 200000¹ | — | — | — | — | — | 500² | read-across |
All values µg/kg (ppb), as-sold 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. Variants on this page: rice-based and non-rice. Where a cell differs between them the Master Limit Table shows both; the derivation above is for rice-based.
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.
3 studies in the corpus measured lead in Teething & Snacks (8 samples reported across those studies): US-House-Subcommittee 2021, FDA 2024, Collado-Lopez 2025. Reported concentrations range from 0 ppb to 6.5 ppb, with a typical value of 0 ppb.
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. Why lead is limited →
2 studies in the certified-market pool measured inorganic arsenic in Teething & Snacks across 21 certified-market samples. The pooled distribution centres on a median of 156 ppb and reaches 228 ppb at the 95th percentile, with a measured maximum of 273 ppb. Signes-Pastor 2016, Jung 2017.
HMTc sets 20 ppb by read-across: Held to the strictest sovereign infant inorganic-arsenic ceiling: EU baby-food iAs 20 (Regulation (EU) 2023/915 point 3.4.3), adopted as a protective read-across across the HMTc Infant and Child Foods category (ages 0-5). EU's 'baby food' term is drafted narrowly (Directive 2006/125/EC excludes processed cereal-based food, and the limit is set for infants up to 24 months); HMTc applies the tightest sovereign inorganic-arsenic number to every food in this 0-5 category. Total arsenic is separately capped at 50 (India FSSAI); iAs <= tAs. Why inorganic arsenic is limited →
2 studies in the certified-market pool measured total arsenic in Teething & Snacks across 3 certified-market samples. The pooled distribution centres on a median of 111 ppb and reaches 151 ppb at the 95th percentile, with a measured maximum of 171 ppb. Collado-Lopez 2025, FDA 2024.
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. The certified-market pool's P97 is 153 ppb, at or above the government ceiling of 50 ppb, so the government maximum binds. Why total arsenic is limited →
5 studies in the corpus measured total mercury in Teething biscuits & finger snacks (2218 samples reported across those studies): Barber 2025, Zmudzinska 2022, Houlihan 2019, Brombach 2017, Mania 2015.
HMTc sets 8 ppb by read-across: government read-across: Israel FCS-2016 porridges & other foods for infants and toddlers, total-Hg 8 (the strictest applicable baby-food mercury ML; supersedes the looser China canned-complementary 20). Why total mercury is limited →
2 studies in the corpus measured cadmium in Teething & Snacks (3 samples reported across those studies): Collado-Lopez 2025, FDA 2024. Reported concentrations range from 0 ppb to 3.5 ppb, with a typical value of 0 ppb.
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. Why cadmium is limited →
No citable primary occurrence measurement is routed to this cell in the corpus.
HMTc sets 3 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 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 →
No citable primary occurrence measurement is routed to this cell in the corpus.
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
Where certification is demanding for this subcategory, and why. These carry a natural or process background that runs above the limit: the limit being the strictest government maximum for the product, never a percentile of market data (Method v2.0). A product is not disqualified by this: only its own tested result decides certification, and a well-sourced lot can sit well below the market.
Inorganic arsenic
Inorganic arsenic is taken up from soil, irrigation water, and seawater; rice and rice-derived ingredients, and some seaweeds, carry it far above the strictest sovereign limits.
Lead
Lead is taken up from soil and can enter through adulteration; grains and rice, protein and collagen powders, spices, root and tuber vegetables, and some botanicals are common carriers.
Total arsenic
Rice and rice-derived ingredients carry high total arsenic; where the category sets total arsenic as a firm ceiling rather than a speciation screen, rice-based products run above it.
Multipliers are the ratio of the pooled occurrence median to the published limit; occurrence characterises the market only and carries no compliance weight. See the cross-category summary.
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 lead, cadmium, nickel; Read-across for inorganic arsenic |
| 2 | FSSAI (Contaminants, Toxins and Residues) Regulations | 2011 | Maximum levels | Binds tin; Comparator for lead, cadmium |
| 3 | GB 2762: National Food Safety Standard | 2022 | Maximum levels | Read-across for total chromium; Comparator for cadmium |
| 4 | FSANZ Food Standards Code: Schedule 19 | 2015 | Maximum levels | Read-across for aluminium; Comparator for cadmium |
| 5 | Israel Food Contaminants Standard (FCS) | 2016 | Maximum levels | Read-across for total mercury; Comparator for cadmium |
| 6 | Contaminants in Food (retained Reg. 1881/2006) | 2006 | Maximum levels | Comparator for lead, cadmium |
| 7 | Codex General Standard CXS 193-1995 | 1995 | Codex standard | Comparator for lead |
| 8 | ANVISA RDC, Inorganic Contaminant Limits | 2022 | Maximum levels | Comparator for lead, cadmium |
| 9 | GSO 193, Gulf Technical Regulation | 2021 | Maximum levels | Comparator for cadmium |
| 10 | US FDA: Closer to Zero action levels | 2020 | Guidance action levels | Comparator for lead |
| 11 | MERCOSUR GMC Resolución 12/2011 | 2011 | Maximum levels | Comparator for lead, cadmium |
| 12 | Philippines PNS/BAFS 194:2017 | 2017 | Maximum levels | Comparator for cadmium |
| 13 | Paraguay Decreto 1335/2019 | 2019 | Maximum levels | Comparator for lead, cadmium |
| 14 | Singapore Food Regulations | 2023 | Maximum levels | Comparator for lead |
| 15 | Thailand MOPH Notification No. 414 | 2020 | Maximum levels | Comparator for cadmium |
| 16 | Vietnam QCVN 8-2:2011/BYT | 2011 | Maximum levels | Comparator for cadmium |
Cite this standard
Pendergrass, K. (2026). Teething biscuits & finger snacks: HMTc standard (Standard No. 10.83138/hmtc.std.1.teething-and-snacks). Institute of Contaminant Standards. https://doi.org/10.83138/hmtc.std.1.teething-and-snacks
© 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-sold 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. |