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.
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. 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.
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.