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EU measures for dealing with MOSH/MOAH findings

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Update: Proposed maximum levels for MOAH – Revison 7

June 2025 (update). At the end of 2023, the EU Commission presented a first Draft Regulation to establish maximum levels for mineral oil aromatic hydrocarbons (MOAH). The aim is to integrate these maximum levels into the European Contaminants Regulation (EU) 2023/915. The proposed maximum levels have already been extended and adjusted several times. In the current revision 7 of the draft, again changes were made for e.g. cereal products, cocoa products, confectionary and food additives prepared from food sources. The adoption of the draft legislation is still planned for the end of 2025. It is expected that the limit values will be applicable from 2027.

Likewise, there are currently discussions to lay down a maximum level for MOAH into the specifications for food additives via Regulation (EU) No. 231/2012. Food additives produced from food would be excluded here and regulated via the European Contaminants Regulation (EU) 2023/915. It is specified that raw materials (food) used must comply with the Contaminants Regulation. The use of processing factors in accordance with Art. 3 of Regulation (EU) 2023/915 is possible.

Discussion of MOSH guideline values in combination with a monitoring recommendation for MOSH and MOAH

In addition, a proposal for a monitoring recommendation for saturated mineral oil hydrocarbons (MOSH) and MOAH is currently under discussion in order to define requirements for risk minimisation by means of MOSH indicative values. Further product groups have also been included here. The MOAH monitoring is intended to cover products that are not subject to the planned regulatory draft of the European Contaminants Regulation (EU) 2023/915, such as coffee, tea, fruits, vegetables and essential oils.

Planned requirements for the sampling and analysis of mineral oil hydrocarbons

Specifications for the sampling and analysis of mineral oil hydrocarbons (MOH) are also to be incorporated into Regulation (EU) No. 333/2007 via a planned amending regulation. This includes a new proposal for an additional LOQ (Limit Of Quantification) level. For analytically complex products such as spices, herbs, essential oils, food supplements or marine oils, an LOQ of up to 5 mg/kg may be reported in the future. Currently, an LOQ requirement of 1-2 mg/kg applies to these product groups.

The current maximum level proposal was already preceded in 2022 by a Summary Report of the EU Standing Committee on Plants, Food and Feed (SC PAFF) on an EU-wide approach for handling findings of aromatic mineral oil hydrocarbons (MOAH) in food.

In September 2023, the European Food Safety Authority (EFSA) published its Scientific Opinion on the risk assessment of mineral oil hydrocarbons in food. This opinion forms the basis for the planned introduction of maximum levels for MOAH.

Current status of the discussion on proposed maximum levels for MOAH

The maximum LOQs mentioned in 2022 in the SC PAFF report for foods with certain fat contents have been proposed as "general maximum levels" for MOAH (C10-C50) since the end of 2023. These serve to harmonise the evaluation of MOAH findings among the European official food control labs.

  1. Products with a fat content ≤ 4 % fat/oil: 0.5 mg/kg
  2. Products with a fat content > 4 % fat/oil and ≤ 50% fat/oil: 1.0 mg/kg
  3. Products with a fat content > 50 % fat/oil: 2.0 mg/kg

The drafted revision 7 with specific maximum levels for MOAH (C10-C50) includes the following product groups:

  • Oilseeds and oilfruits
  • Animal and vegetable fats and oils >50% fat
  • Tree nuts
  • Pulses
  • Cereal grains and cereal products (ML depending on fat content)
  • Milk
  • Dairy products (ML depending on fat content)
  • Cocoa beans (from 2030), cocoa mass, cocoa powder
  • Confectionary, cocoa and chocolate products (ML depending on fat content)
  • Spices and dried herbs, tea and herbal infusions as food ingredient
  • Baby food (ML depending on fat content)
  • Food supplements
  • NEW: Food additives produced from food sources
  • NEW: Processed and compound foods containing certain ingredients listed above (from 2030, ML depending on fat content)

The use of processing factors in accordance with Art. 3 of Regulation (EU) 2023/915 is possible. If the processing results in lower maximum levels, those do not apply. The following “general maximum levels” according to fat content are to be used:

  1. Ingredients with a fat content of < 4 % fat/oil: 0.5 mg/kg
  2. Ingredients with a fat content of ≥ 4 % and ≤ 50% fat/oil: 1.0 mg/kg
  3. Ingredients with a fat content of > 50 % fat/oil: 2.0 mg/kg

The "general maximum levels" for MOAH, which are based on the fat content of foods, were originally taken from a 2019 Report by the EU Joint Research Center (JRC) as analytical limits of quantification, which published performance criteria for the sampling, analysis and reporting of mineral oil hydrocarbons. An update of this report was published in April 2023. Among other things, it stipulates that total MOSH and total MOAH n-C10 to n-C50 should be reported. The disclosure of further fractions is no longer required.

MOAH within the group of mineral oils

Mineral oils are complex mixtures of hydrocarbons (C10-C50) that originate predominantly from fossil, petrogenic sources. In addition to mineral oil saturated hydrocarbons (MOSH), mineral oils of technical quality also contain aromatic components (MOAH, mineral oil aromatic hydrocarbons). The MOAH fraction is a complex mixture of substances with varying and largely unknown toxicity, unlike, for example, the structurally related polycyclic aromatic hydrocarbons (PAH).

Toxicological evaluation and legal provisions

The toxicological relevance of the MOAH fraction, has already been known for many years. Following its opinions published in 2012 and 2019, the European Food Safety Authority (EFSA) has launched a Scientific Opinion on the risk assessment of mineral oil hydrocarbons in September 2023.

For MOSH, it was concluded that dietary exposure to MOSH is not of concern for any age group.

For MOAH, according to EFSA, recent studies confirm that their genotoxicity is related to the presence of MOAH with 3 or more aromatic rings. However, in order to establish reference values, robust data on the oral toxicity of MOAH are lacking, as well as on the influence of ring alkylation and on the genotoxicity of MOAH with 1 and 2 rings. Since only little information is available on the occurrence and composition of MOAH in food, the experts worked with two different prediction scenarios. Both exposure scenarios (MOE - Margin Of Exposure) indicate a possible health risk of MOAH in food. A basic human health concern has been expressed, but further data need to be collected e.g. on the composition of MOAH in food by ring number and on the sources of food contamination.

In addition, representatives of German Food Control Authorities and the food industry developed "benchmark levels" for mineral oil hydrocarbon contents and their structural analogues. The aim is to support minimisation strategies for mineral oils along the food supply chain applying the benchmark levels and the previously created toolbox.

Analysis of mineral oil hydrocarbons

The experts from the Competence Centre for Organic Contaminants of Eurofins Food & Feed Testing laboratories in Germany have long-term experience with the analysis, evaluation and assessment of mineral oil hydrocarbons (MOSH, POSH, PAO, MOAH) in various food matrices by means of online-LC-GC-FID.

In addition to online-LC-GC-FID analysis of mineral oils in food, we also offer the two-dimensional GCxGC-ToF-MS/FID for the mass spectrometric characterisation of mineral oil contaminations as well as the quantification of the toxicological relevant tri- to polyaromatic fraction (TPAF). With this set of methods, we offer our customers additional support in identifying potential sources of contamination and in conducting toxicological assessments. Please read also our article Characterisation of MOSH/MOAH results.

Do you still have questions about the analysis of mineral oils?

Do you have questions about analysing mineral oil in food or would you like to use our analysis service? Please contact your personal account manager or our expert Sabrina Hansen directly.