PAH analysis – overview of EU regulations and testing requirements

updated 

Polyaromatic hydrocarbons (PAH) are harmful pollutants that may end up in the body through certain foods, skin exposure, and air containing cigarette smoke, exhaust gases, or asphalt fumes. EU legislation sets maximum permissible PAH concentrations for several types of products, materials, and environmental samples. Measurlabs offers the required laboratory testing to demonstrate that these limits are not exceeded.

What are PAHs, and what are the concerns?

Polycyclic aromatic hydrocarbons, or polyaromatic hydrocarbons, are a group of organic compounds whose molecular structure contains two or more aromatic rings fused together. PAHs are formed as a result of incomplete combustion of fuels, often in the oil industry and transport, or when organic material such as wood or animal fat burns incompletely.

Many PAH compounds have been shown to have genotoxic properties, and several have been linked to an increased risk of cancer. As a result, certain PAHs have harmonized classifications as presumed or suspected mutagens (categories 1B and 2) and as presumed carcinogens (category 1B) under the CLP Regulation.1

PAH restrictions under the REACH Regulation

The European Union’s REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) sets maximum concentrations for eight PAHs in plastic and rubber components of consumer products that come into contact with the human body. The restriction, specified in entry 50 of REACH Annex XVII, covers the following compounds:2

  • Benzo(a)pyrene

  • Benzo(e)pyrene

  • Benzo(a)anthracene

  • Chrysene

  • Benzo(b)fluoranthene

  • Benzo(j)fluoranthene

  • Benzo(k)fluoranthene

  • Dibenzo(a,h)anthracene

Applicable products include, among others, clothing, accessories, sports equipment, tools, and household utensils. These may not be sold in the EU if rubber or plastic parts contain more than 1 mg/kg of any of the eight PAH. The limit is stricter for toys and childcare articles, which may not be sold if relevant components contain more than 0.5 mg/kg of any listed PAH.

The PAH restriction specified in entry 50 also applies to other product groups. Extender oils used to produce tires may not be placed on the market if benzo(a)pyrene content exceeds 1 mg/kg or if the sum of the eight listed PAHs exceeds 10 mg/kg. For granules or mulches used in synthetic turf, other sports surfaces, or playgrounds, the sum of the eight PAHs must not exceed 20 mg/kg.

More recently, entry 50a was added to Annex XVII, setting a maximum limit of 50 mg/kg for the sum of 18 PAHs in clay targets for shooting from April 2026. Several PAHs are also restricted under entry 72 on textiles and entry 75 on tattoo inks. The textile limits are identical to entry 50 limits (1 mg/kg for each of the same eight PAHs), while the tattoo ink limits are particularly strict, going down to 0.005 mg/kg for benzo(a)pyrene and 0.5 mg/kg for other carcinogenic or mutagenic PAHs.3

EU regulations on PAH in food & food contact materials

PAH compounds may end up in food as a result of environmental contamination of raw materials, or they may be formed during manufacturing or cooking. They are most likely to be present in smoked, roasted, grilled, or dried foods, oils, and fats. EU regulations mandate PAH testing for high-risk foods and products intended for small children.

Maximum levels for PAH and other food contaminants in high-risk product groups are set in Regulation (EU) 2023/915. The PAH limits apply to the concentrations of benzo(a)pyrene and the combination of benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene, and chrysene, which are known together as PAH 4.4 The maximum concentrations for selected products are listed in Table 1.

Table 1: Maximum PAH concentrations in food by product type

Product

Limit for benzo(a)pyrene

Limit for PAH 4

Cocoa beans and derived products

5 μg/kg

30 μg/kg

Coconut oil

2 μg/kg

20 μg/kg

Other oils and fats

2 μg/kg

10 μg/kg

Smoked meats and meat products

2 μg/kg

12 μg/kg

Smoked fish and fishery products

2 μg/kg

12 μg/kg

Smoked mollusks

6 μg/kg

35 μg/kg

Baby food and infant formula

1 μg/kg

1 μg/kg

Traditionally smoked meat and fishery products*

5 μg/kg

30 μg/kg

Dried herbs and spices, plant powders for the preparation of beverages

10 μg/kg

50 μg/kg

Banana chips

2 μg/kg

20 μg/kg

* These higher limits apply to specific types of traditionally smoked products in Ireland, Croatia, Cyprus, Spain, Poland, Portugal, Latvia, Slovakia, Finland, and Sweden. The product must be produced and sold domestically.

In food-contact materials (FCMs), PAH presence can be a concern when carbon black is used as an additive. According to the Plastics Regulation (EU) No 10/2011, benzo(a)pyrene content in carbon black used to manufacture plastic FCMs must not exceed 0.25 mg/kg.5

Limits on PAH in drinking water

EU's revised Drinking Water Directive (EU) 2020/2184 defines maximum levels for a wide range of chemical contaminants, including several polycyclic aromatic hydrocarbons. According to the directive, the following PAH concentrations must not be exceeded for drinking water to meet minimum quality criteria:6 

  • 0.01 μg/l for benzo(a)pyrene

  • 0.1 μg/l for the sum of benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(ghi)perylene, and indeno(1,2,3-cd)pyrene

Monitoring of environmental samples

Several PAHs are identified as “priority hazardous substances” in Part A of Annex I to the Environmental Quality Standards Directive 2008/105/EC, which means that Member States must monitor their concentrations in bodies of water. The primary matrix for monitoring is biota (crustaceans and molluscs), and maximum levels are set at 6.1 µg/kg for fluoranthene and 0.6 μg/kg for the sum of eight PAHs, measured as benzo(a)pyrene equivalents.7

The Environmental Quality Standards Directive also sets maximum allowable concentrations (MAC-EQS) for PAHs in surface waters. These are applied when an acute exposure risk has been identified, for example due to a known discharge.8

Limits on PAHs in cosmetic products

The EU Cosmetics Regulation (1223/2009) lists around 1,700 substances that are prohibited in cosmetics. Several PAH compounds are among the forbidden substances, including benzo(a)pyrene, benzo(e)pyrene, chrysene, and benzo(k)fluoranthene. In addition, the use of numerous coal-based substances, such as paraffin waxes and coal tar, is prohibited if they contain more than 0.005% by weight of benzo(a)pyrene.9

PAH analysis methods

PAH analyses can be performed using various methods. Gas chromatography-mass spectrometry (GC-MS) and high-performance liquid chromatography (HPLC) are the most common techniques for quantifying PAHs in food. GC-MS is also used to determine the PAH content of environmental samples, such as air and water.

In some cases, PAH analysis can be performed using supercritical fluid chromatography (SFC), liquid chromatography (LC), or a heavy distillates analyzer (HDA). The chosen method depends on the boiling range of the sample, along with product specifications and applicable regulations.

One partner for all your PAH testing needs

Measurlabs offers accredited PAH testing for various sample matrices. See the following service descriptions for more information, including indicative pricing:

Various other sample types can also be analyzed, including sediment, biochar, and waste materials. You can contact our experts through the form below for more information or a quote. We will get back to you within one business day.

References: 

1 Part 3: Harmonized classification and labelling table in Regulation (EC) No. 1272/2008 on the classification, labelling and packaging of substances and mixtures. Examples of PAHs with harmonized classifications include benzo[a]pyrene, chrysene, and benzo[e]pyrene.

2 See entry 50, Annex XVII of the most recent consolidated version of the REACH Regulation (EC) No. 1907/2006 for up-to-date information on PAH restrictions.

3 See entries 50a, 72, and 75, and Appendices 12 and 13 of REACH Annex XVII for details of the clay target, textile, and tattoo ink restrictions.

4 These four have been selected based on the European Food Safety Authority’s (EFSA) 2008 Scientific Opinion, which concluded that PAH4 are the most suitable indicators of PAHs in food. The PAH limits are incorporated into the consolidated version of Regulation (EU) 2023/915 on food contaminants.

5 Restrictions on using carbon black are outlined under FCM substance No 411 in Table 1 of Annex I to Regulation (EU) 10/2011.

6 Directive (EU) 2020/2184; the minimum requirements for chemical parameters in drinking water are outlined in Part B of Annex I.

7 Article 3 of Directive 2008/105/EC on environmental quality standards in the field of water policy outlines the monitoring requirements and Annex I the maximum levels for priority substances.

8 See Article 3(3a) of Directive 2008/105/EC.

9 Regulation (EC) No 1223/2009 on cosmetic products.

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