Reacting to concerns about the adverse health effects of mineral oil aromatic hydrocarbons (MOAH), the EU Standing Committee on Plants, Animals, Food and Feed (SC PAFF) published a report limiting their acceptable concentrations in food in the spring of 20221. The limits outlined in the report took effect immediately, although they are not legally binding until enforcement by the member states.
As migration from food contact materials (FCMs) is one of the main sources, laboratory tests should be performed to detect MOAH and other mineral oil hydrocarbons in such materials.
What are MOAH and MOSH?
Mineral oil hydrocarbons (MOH) are chemical compounds derived mainly from crude oil, but also produced synthetically from coal, natural gas, and biomass. Falling under the umbrella of MOH, MOAH and mineral oil saturated hydrocarbons (MOSH) are specific types of hydrocarbon compounds that have been linked to detrimental health effects. In the case of MOAH, the concerns include an increased risk of cancer, while MOSH may accumulate in the body and ultimately cause damage to the liver, spleen, and lymph nodes2.
EU regulations and recommendations have thus far been directed at MOAH compounds, as they present the highest toxicological risks. There are currently no specific limitations on the amount of MOSH in food or FCMs on the EU level.
What are the EU regulations on MOAH?
The maximum acceptable levels of MOAH in different types of food are outlined in the EU PAFF standing committee’s summary report3. The limits vary depending on the fat content of the food:
0.5 mg/kg for dry foods with a low fat/oil content (≤ 4% fat/oil)
1 mg/kg for foods with a higher fat/oil content (> 4% fat/oil, ≤50% fat/oil)
2 mg/kg for fats and oils (>50% fat/oil)
MOAH may end up in food from several sources, including additives, packaging materials, and manufacturing equipment. The above limits apply to the total amount of MOAH in food regardless of the source. With regard to food contact materials, manufacturers have to ensure that the total migration of restricted hydrocarbon compounds does not exceed the said thresholds.
How to test for MOAH?
There is currently no standard method for MOAH analysis, but general guidelines are provided in a Joint Research Centre (JRC) guidance report4, which outlines the minimum requirements for analytical methods that can be used in MOSH and MOAH testing. The guidance will likely be updated once the European Food Safety Authority (EFSA) publishes its upcoming opinion on the topic5.
MOH analysis is usually performed using either LC-GC-FID or GC-FID. Due to structural similarities, MOH cannot be separated into individual substances using the aforementioned analytical techniques, but MOSH and MOAH components can be distinguished from one another. Further characterization of MOSH and MOAH is possible with more advanced analytical methods.
The goal of testing is usually to demonstrate that the migration of MOAH components is below 0.5 mg/kg. There are no set limits for acceptable levels of MOSH migration.
Avoiding contamination at all stages of sampling and analysis is important, as mineral oils may unintentionally end up in the sample material from sources like plastic bags and cosmetics. Due to the low detection limit and high risk of contamination, MOAH testing requires a high level of expertise from the testing laboratory.
The likelihood of MOAH being present depends on the type of material. Paper and cardboard made of virgin fibers do not tend to contain mineral oils. With materials containing recycled fibers, the risk is higher, which has led to Swiss authorities banning the use of recycled paper and cardboard in food contact materials. Plastic materials are generally low-risk, as the use of mineral oils in additives has largely subsided.
Where is the regulation heading?
The specifics of the European Union’s stance on mineral hydrocarbons may change in the future, as there have been calls for even stricter regulation. Consumer rights organization foodwatch does not consider the current guidelines sufficient, calling instead for a complete ban on detectable amounts of MOAH in all foodstuffs6. It may, therefore, make sense to pre-emptively aim for no detectable MOAH migration from FCMs into food.
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2 EFSA, Scientific Opinion on Mineral Oil Hydrocarbons in Food, June 2012
3 SC PAFF summary report, 19th of October 2022. The document confirms the limits set out in the April report and clarifies the fat content for products for which the different limits apply.
5 The upcoming EFSA opinion on the risks of mineral oil hydrocarbons has been discussed in the meetings of the agency’s working group on MOH in food.