Toy pacifiers (toy-designated) — HMTc Standard

How every number on this page is set

READING THE STRICTER-UNSELECTED FLAGS. The audit scan compares every credible-regulator register row whose product scope matches this category against each cell's binding value, and flags anything stricter that was not named. Three families of flag recur and each has a single standing answer. (1) SIBLING MATERIAL CATEGORIES. Directive 2009/48/EC Annex II Part III point 13 sets three limit sets for the same instrument, keyed to material form; the Category I and Category II rows share a product scope with Category III, so on a Category III row the Category I and Category II values are always flagged as stricter. They are inapplicable: a limit for dry, brittle, powder-like or pliable material, or for liquid or sticky material, does not govern a material that must be scraped to be tested. Each row's basis_guard admits only its own category, so the flagged value could not have been used even if it had been named. (2) ASTM F963-17 NOMINAL ARSENIC, MERCURY AND CHROMIUM. ASTM states its soluble limits in the legacy EN 71-3 / ISO 8124-3 lineage, in which conformity is judged against an ADJUSTED result: a per-element analytical correction is subtracted from the laboratory result before comparison to the limit (ISO 8124-3:2020 Table 2 — 60 percent arsenic, 50 percent mercury, 30 percent chromium, lead and cadmium — ingested at wiki/sources/iso2020-8124-3-toy-migration-elements.md, which records that F963 4.3.5 sits in that lineage and used the legacy EN 71-3 limits unchanged through F963-07). EN 71-3:2013 and later abolished the correction, so the Directive's figures are compared against the raw result. On a common raw-result footing ASTM's arsenic ceiling is 62.5 mg/kg against the Directive's 47, and its mercury ceiling is 120 mg/kg against the Directive's 94, so the EU value is the stricter limit as enforced and is what HMTc publishes and applies to the raw uncorrected result. Nothing here rests on that convention alone: HMTc requires conformity with the ASTM figure on ASTM's own corrected-result terms as a companion obligation IN ADDITION to the raw-result ceiling published here, so no HMTc cell is looser than ASTM under either reading of the correction clause. For total chromium, where the Directive sets Cr(III) and Cr(VI) limits and no total-chromium limit, HMTc applies ASTM's nominal 60 mg/kg to the RAW result, which is stricter than ASTM as enforced — deliberate over-compliance, disclosed as such. REGISTER GAPS RECORDED, NOT WORKED AROUND. The EU Cr(III) migration rows of point 13 are absent from the register, as are the ISO 8124-3:2020 Table 1 material-category tiers whose modelling-clay and finger-paint chromium limits (25 mg/kg) would be STRICTER than the published total-chromium screen on the Category I and Category II rows, and the REACH Annex XVII entry 27 nickel-release limit (0.5 ug/cm2/week, a per-area release basis). None is invented into this config; each is returned for ingestion through the verified regulatory-fetch pathway. (3) CANADIAN TOTAL-MERCURY COATING LIMITS. SOR/2011-17 and SOR/2016-193 cap TOTAL mercury at 10 mg/kg in surface coating material. That is a content ceiling, not a migration ceiling; it is a real and binding parallel obligation, it is disclosed on every mercury cell, and it is excluded from the migration cells by the basis_guard because a content limit and a migration limit are different measured quantities. NOT CONVERTED INTO NUMBERS. The US LHAMA regime (15 U.S.C. 1277 / 16 CFR 1500.14(b)(8) via ASTM D-4236) is a chronic-hazard review and labelling duty with no numeric maximum level, and the mechanical requirements of EN 71-1 and ASTM F963-17 (small parts, magnet flux index, projectile kinetic energy, lid supports, balloon and marble warnings) are not metals limits. Neither is converted into a ceiling anywhere in this config.

Master Limit Table

All values in ppb (µg/kg), as-sold basis. 7 of 11 analytes carry a firm ceiling; the remainder are governed by mandatory control or reflex-speciation screening 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.

Tier 1 (Pb, iAs, Hg, MeHg, Cd) are zero-tolerance toxics with no established safe threshold. Tier 2 (tAs, Cr-VI, Ni, Sn, Al, Cr) carry a 150% transitional allowance under the program’s Status A–E framework.

Derivation — every government’s number, side by side

The full derivation for Toy pacifiers (toy-designated). 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: controlled by reflex speciation or packaging control, not a standalone number.

Cite this standard

Pendergrass, K. “Toy pacifiers (toy-designated).” In Heavy Metal Tested & Certified (HMTc) Children's Toys, Arts, and Crafts standard, version 1.0. Institute of Contaminant Standards (ICS), 2026. DOI: registration pending.

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.