EU comment period on new MOAH limits in food nearing deadline
The European Union is approaching the end of the public consultation period on its new proposal to limit mineral oil aromatic hydrocarbons (MOAH) in food. Stakeholders can submit comments on the draft regulation until May 10.
Mineral oil hydrocarbons (MOH) are a group of compounds primarily derived from crude oil. They are generally divided into mineral oil saturated hydrocarbons (MOSH), which can accumulate in the body but are considered less toxic, and mineral oil aromatic hydrocarbons (MOAH), some of which may include potentially carcinogenic substances.
Food contamination with MOH can occur through multiple pathways, including lubricants used in agricultural machinery, processing aids, food additives, migration from packaging materials, and environmental exposure.
On March 11, the EU notified the World Trade Organization of a draft regulation introducing maximum levels for MOAH in a wide range of products starting January 1, 2027. These include oilseeds, fats and oils, nuts, pulses, cereals, dairy products, cocoa products, spices, teas, infant foods, and food additives.
The proposed limits follow the ALARA principle (as low as reasonably achievable) and set minimum enforceable thresholds depending on fat content — from 0.5 mg/kg for low-fat foods to 2.0 mg/kg for high-fat products.
Food business operators will need to strengthen monitoring and mitigation of MOAH across the entire supply chain, including processing and food contact materials. The limits are based on the 2023 risk assessment by the European Food Safety Authority, which identified potential carcinogenic risks associated with certain MOAH compounds.
Market participants have already raised concerns about the potential trade impact. In particular, representatives of the Philippine coconut sector warn that the new requirements could complicate crude coconut oil exports to the EU due to compliance challenges and the high cost of laboratory testing, affecting an industry that supports millions of farmers.
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