How limits are set
Two boundary decisions in this category are disclosed rather than assumed. FIRST, breath fresheners split by presentation: the row certifies cosmetic-presentation forms (sprays, strips, films, non-food oral tablets) on the cosmetic instrument family, and food-presented mints, gums and confectionery lozenges are routed out to Category 33 rather than certified against a cosmetic ceiling — the relevant food instrument (the FDA lead action level for candy likely to be frequently consumed by small children, 100 ug/kg) is five times stricter than this category's lead value, so the routing is in the protective direction.
SECOND, articles are not stretched onto cosmetic limits: a toothbrush, a floss, an irrigator tip and a tongue scraper each take a real article-scoped sovereign lead ceiling and a full-panel component-level control, and never a toothpaste value.
Total chromium is a control rather than a published screen value in every row because no sovereign publishes a chromium content limit for any product form in this category; hexavalent chromium is deliberately NOT registered as a method artifact here, because oral-care matrices routinely contain peroxide and persulfate oxidising systems in which the reduction of Cr(VI) to Cr(III) cannot be assumed.
Tin and aluminium are controls with declaration reconciliation rather than impurity ceilings, because stannous fluoride is an authorised active and hydrated alumina is a conventional abrasive, so both elements are present by design in compliant products.
Master Limit Table
All values in ppb (µg/kg), as-sold basis. 8 of 11 analytes carry a firm ceiling; 2 are toxic species bounded by their parent totals (species ≤ total, measured on every lot), and the remaining 1 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.
| Analyte | HMTc limit | Binding basis |
|---|---|---|
| Lead (Pb) | 90000 | strictest government ML (Canada) |
| Inorganic arsenic (iAs) | bounded | ≤ total tAs, measured every lot (see note) |
| Total arsenic (tAs) | 47000 | government read-across (EU) |
| Mercury, total (tHg) | 94000 | government read-across (EU) |
| Methylmercury (MeHg) | bounded | ≤ total tHg, measured every lot (see note) |
| Cadmium (Cd) | 17000 | government read-across (EU) |
| Hexavalent chromium (Cr-VI) | 53 | government read-across (EU) |
| Nickel (Ni) | 930000 | government read-across (EU) |
| Tin (Sn) | 180000000 | government read-across (EU) |
| Aluminium (Al) | 28130000 | government read-across (EU) |
| Total chromium (Cr) | control | mandatory control — no government ML; screened every lot (see note) |
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 Toothbrushes (manual, electric heads). 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 | HMTc | Binds |
|---|---|---|
| Lead (Pb) | 90000 | Canada |
| Inorganic arsenic (iAs) | bounded&sup5; | species ≤ tAs |
| Total arsenic (tAs) | 47000² | read-across |
| Mercury, total (tHg) | 94000² | read-across |
| Methylmercury (MeHg) | bounded&sup5; | species ≤ tHg |
| Cadmium (Cd) | 17000² | read-across |
| Hexavalent chromium (Cr-VI) | 53² | read-across |
| Nickel (Ni) | 930000² | read-across |
| Tin (Sn) | 180000000² | read-across |
| Aluminium (Al) | 28130000² | read-across |
| Total chromium (Cr) | control&sup4; | screened |
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. &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.
Risk Flag
On the published occurrence literature to date, Toothbrushes (manual, electric heads) 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.
Cite this standard
Pendergrass, K. (2026). Toothbrushes (manual, electric heads): HMTc standard. Institute of Contaminant Standards.
© 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.