03 / EVIDENCE GOVERNANCE
A disposition for every major finding
Evidence may change the work
without choosing the limit.
These notes record what each major Heavy Metal Index synthesis changes in category scope, testing, surveillance, or claim language—and what it cannot change under the institutional firewall.
REGISTER / 2026
One evidence finding, one visible governance consequence.
The evidence page remains the scientific record. HMTc publishes any certification interpretation. ICS records the boundary, decision right, and standards-governance action.
Dietary nickel and the botanical floor
Keep nickel controls matrix-specific, disclose naturally elevated staple categories, and apply improvement rules without implying that agricultural sourcing can eliminate a physiological plant-uptake pathway.
Nickel →02 · GOVERNANCE NOTETin migration in canned and acidic foods
Treat packaging format and acidity as part of the certification cell, preserve the acute gastrointestinal endpoint, and avoid generalizing an agricultural contaminant model to a contact-material pathway.
Tin →03 · GOVERNANCE NOTEBreastmilk as a distinct exposure pathway
Keep maternal biomonitoring and lactation evidence outside food-product conformity claims while retaining it as vulnerable-population context for infant exposure communication.
Lead, Cadmium, Arsenic, Mercury, Aluminum, Chromium →04 · GOVERNANCE NOTEInfant formula metal amplification
Maintain separate powder, ready-to-feed, soy, and non-soy cells; include aluminum in surveillance; and require basis-explicit finished-product testing rather than recipe inference.
Aluminum, Lead, Cadmium, Arsenic, Mercury →05 · GOVERNANCE NOTEWastewater irrigation as a multi-metal crop pathway
Use irrigation source and geography as supplier-risk and surveillance fields, especially for leafy produce, without silently pooling unlike markets into a single occurrence claim.
Lead, Cadmium, Chromium, Nickel, Arsenic →06 · GOVERNANCE NOTEBotanical supplements as an under-surveilled pathway
Require finished-product, multi-metal evidence for botanical preparations and distinguish supplements from conventional foods instead of borrowing a food surveillance assumption.
Lead, Cadmium, Arsenic, Mercury →07 · GOVERNANCE NOTEOffal as a distinct accumulation category
Keep liver and kidney separate from skeletal muscle in taxonomy, sampling, and claims because physiological accumulation invalidates a generic meat category.
Cadmium, Lead, Mercury, Chromium →08 · GOVERNANCE NOTECookware and utensils as post-harvest metal pathways
Treat food-contact articles as their own material-and-migration program scope and keep them separate from claims about the cleanliness of raw ingredients.
Lead, Cadmium, Nickel, Chromium, Aluminum, Arsenic →09 · GOVERNANCE NOTETea totals and infusion transfer
Preserve dry-leaf and prepared-infusion bases as different records and require consumer-facing claims to name which basis was actually tested.
Aluminum, Lead, Cadmium, Chromium, Arsenic →10 · GOVERNANCE NOTEAquaculture and wild-caught fish are not one occurrence pool
Record production method and species in fish evidence, stratify occurrence summaries, and prevent a lower farmed-fish distribution from masking higher-risk wild predator categories.
Methylmercury, Mercury, Cadmium, Lead, Arsenic →11 · GOVERNANCE NOTEBivalve cadmium amplification
Maintain a mollusc-specific category rather than using finfish expectations, with sampling and claims that reflect filter-feeding accumulation.
Cadmium, Lead, Mercury →12 · GOVERNANCE NOTECooking is not a methylmercury control
Reject preparation-based mitigation claims for methylmercury and assess the food on the governed native basis without promising that household cooking removes the hazard.
Methylmercury, Mercury →13 · GOVERNANCE NOTEThe EU heavy-metals framework is versioned, not static
Maintain effective dates, amendments, matrix splits, and supersession links in the regulatory crosswalk; never cite an EU limit without its edition and scope.
Lead, Cadmium, Mercury, Methylmercury, Inorganic arsenic, Tin →14 · GOVERNANCE NOTESelenium-to-mercury ratios do not silently relax methylmercury controls
Retain the selenium-mercury ratio as a disclosed scientific debate and reject any automatic relaxation of a methylmercury requirement absent an explicit, externally governed rule.
Methylmercury, Mercury →15 · GOVERNANCE NOTEClimate-linked methylmercury projections
Use projected change as a surveillance and review trigger for marine categories while clearly separating forecasts from measured present-day conformity evidence.
Mercury, Methylmercury →16 · GOVERNANCE NOTEMining-impacted freshwater fish
Capture catch geography and mining influence as routeable evidence fields, and prevent commercial-market fish data from standing in for subsistence or impacted-water populations.
Mercury, Methylmercury, Lead, Cadmium, Chromium, Nickel →17 · GOVERNANCE NOTEOrganic certification is not a contaminant proxy
Prohibit organic status from substituting for analytical evidence and keep contaminant claims tied to the tested lot, analyte panel, and stated basis.
Lead, Cadmium, Aluminum, Nickel, Arsenic →18 · GOVERNANCE NOTESeaweed cadmium and arsenic accumulation
Keep seaweed and kelp separate from terrestrial vegetables, preserve arsenic species, and require species-explicit reporting wherever inorganic arsenic is the governed analyte.
Cadmium, Arsenic, Inorganic arsenic, Lead →19 · GOVERNANCE NOTEClimate adaptation creates contaminant trade-offs
Add climate-sensitive categories to the standards review watch and require measured evidence before a projected trade-off changes any product decision.
Inorganic arsenic, Cadmium, Methylmercury, Mercury →20 · GOVERNANCE NOTECombined exposure and single-analyte limits
Preserve transparent per-analyte conformity while disclosing multi-metal coverage and resisting claims that a pass on one analyte describes aggregate exposure.
Lead, Cadmium, Inorganic arsenic, Methylmercury, Nickel, Aluminum →21 · GOVERNANCE NOTEThe organoarsenical inertness assumption
Preserve arsenic species throughout evidence routing, make uncertainty visible, and prevent total-arsenic or generic organic-arsenic claims from answering an inorganic-arsenic question.
Arsenic, Inorganic arsenic →22 · GOVERNANCE NOTELead chromate spice adulteration
Add authenticity, supplier, and fraud controls to analytical testing because an intentional lead-chromate pathway is not governed adequately by agricultural sourcing assumptions alone.
Lead, Chromium →23 · GOVERNANCE NOTESubsistence fishing methylmercury disparity
Keep vulnerable-population and catch-location context visible, and do not represent commercial-market sampling as coverage of subsistence exposure.
Methylmercury, Mercury →24 · GOVERNANCE NOTEChocolate lead declined while cadmium did not
Track lead and cadmium as separate time series, preserve cocoa-solids and product-form splits, and require current lots rather than treating category-level improvement as a brand claim.
Lead, Cadmium →