ICS EVIDENCE GOVERNANCE NOTEREGISTER · 2026

EVIDENCE BOUNDARY & STANDARDS DISPOSITION

The 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.

The controlling scientific record is the public Heavy Metal Index synthesis, supported by 6 named anchor sources and expressed for Lead, Cadmium, Mercury, Methylmercury, Inorganic arsenic, Tin.

ICS does not reproduce the source extraction here. Keeping the evidence on the independent index preserves source-level methods, units, species, basis, uncertainty, and review state. This note records only the institutional consequence of that evidence.

Maintain effective dates, amendments, matrix splits, and supersession links in the regulatory crosswalk; never cite an EU limit without its edition and scope.

This disposition may change taxonomy, analyte coverage, test basis, surveillance priority, disclosure, or claim language. It does not allow a market occurrence percentile or a dramatic single study to become an initial certification value.

The finding is published in two additional authority layers: the HMI evidence record and the HMTc certification interpretation. Distribution should prioritize regulatory professionals, manufacturers, attorneys, retailers while preserving those distinct roles in headlines, briefings, interviews, and social posts.

Audience

regulatory professionals · manufacturers · attorneys · retailers

SUGGESTED CITATION

Pendergrass, K. (2026). “The EU heavy-metals framework is versioned, not static.” ICS Evidence Governance Notes. ICS-EGN-2026-013. Institute of Contaminant Standards.

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