EU measures for dealing with MOSH/MOAH findings

Update: New regulation for MOAH to be published in 2026

June 2026 (Update). At the end of 2023, the European Commission presented an initial draft regulation to establish maximum levels for mineral oil aromatic hydrocarbons (MOAH) in food. On 13 May 2026, with the approval of the Standing Committee on Plants, Animals, Food and Feed (SCoPAFF), the European Union has taken a decisive step toward regulating MOAH in food. The committee of Member States approved a draft amendment to the European Contaminants Regulation (EU) 2023/915, which, for the first time, sets binding maximum levels for MOAH in food.

The final adoption by the European Commission is currently expected in autumn 2026. Publication in the Official Journal of the European Union is anticipated at the end of the year, as the limits are intended to enter into force already in 2027.

The proposed regulation covers a wide range of products: specific maximum levels will be established for numerous food categories, including oils and fats, cereal-based products, dairy products, cocoa, infant formula, as well as food supplements and spices/herbs. This will, for the first time, create a harmonised EU-wide legal framework for limiting this group of contaminants — which are of concern due to their genotoxic and potentially carcinogenic properties.

Product groups covered by the final draft regulation (MOAH C10–C50)

The final draft regulation with specific maximum levels for MOAH includes the following product categories:

Oilseeds and oil fruits
Fats, oils, products with >50% fat
Tree nuts
Pulses
Cereals and cereal products (ML depending on fat content)
Milk
Dairy products (ML depending on fat content)
Cocoa beans, cocoa mass, cocoa powder
Spices, dried herbs, tea and herbal tea as ingredients in food
Baby food (ML depending on fat content)
Food supplements
Food additives produced from food
Composite food containing listed raw materials with maximum levels (from 2030, ML depending on fat content)
Composite food containing >15% spices, dried herbs, tea, or herbal tea as ingredients (from 2030, ML depending on proportion)

New indicative levels combined with a monitoring recommendation for MOSH and MOAH

The legislative package for MOSH/MOAH regulation also includes a proposal for a monitoring recommendation for mineral oil saturated hydrocarbons (MOSH) and MOAH for the years 2026 to 2029. This aims to establish requirements for risk minimization based on defined MOSH indicative levels. Numerous product groups are included. The MOAH monitoring is intended to cover products that are not included in the draft amendment of the European Contaminants Regulation (EU) 2023/915, such as coffee, tea, processed fruit, processed vegetables, and flavourings.

New requirements for sampling and analysis of mineral oil hydrocarbons

For the first time, requirements for the sampling and analysis of mineral oil hydrocarbons (MOH) will also be incorporated into Regulation (EU) No 333/2007 via an amending regulation. The draft also received a positive vote in the SCoPAFF on 13 May 2026. A newly included element is, for example, a proposal for an additional LOQ level (limit of quantification). For analytically complex products such as spices, herbs, essential oils, food supplements, or marine oils, an LOQ of up to 5 mg/kg will be accepted in the future. The previous SCoPAFF requirement to define LOQs exclusively based on fat content has therefore been removed.

SCoPAFF guidance for European food control authorities

The ongoing work on maximum levels was preceded by a 2022 statement from the SCoPAFF on an EU-wide approach for handling findings of MOAH in food.

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

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

Alignment of MOAH assessment with EU maximum levels

In May 2026, SCoPAFF issued an additional statement. From 13 May 2026 onward, Member States agreed that the maximum levels for MOAH set in the Commission Regulation amending Regulation (EU) 2023/915 should be used as a basis for enforcement on the basis of Article 14 of Regulation (EC) 178/2002.

This approach follows the favourability principle, as many of the new maximum levels define higher values than the SCoPAFF levels from 2022. Only for foods, for which no maximum level is established, the statement from 2022 will remain applicable.

The general SCoPAFF 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.
Furthermore, for difficult matrices, additional characterisation of the MOSH/MOAH fractions should be performed by using comprehensive analytical techniques such as GC×GC‑MS/FID. The aim is to enable a more precise characterisation of the MOSH/MOAH fractions and to quantify MOAH according to the number of their aromatic rings. This advanced analytical approach is in line with a Scientific Opinion on the risk assessment of mineral oil hydrocarbons published by EFSA in 2023.

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 been recognised 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 a full EU compliance check including additional support in identifying potential sources of contamination and 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.