Update on MOSH/MOAH

The German Food Association and the representatives of the Länderarbeitsgemeinschaft Verbraucherschutz (LAV) / Arbeitsgruppe Lebensmittel- und Bedarfsgegenstände, Wein und Kosmetika (ALB) have recently published an extended recommendation for benchmack levels of mineral oil hydrocarbons.

The existing list was extended to include vegetarian and vegan products.

Food product group MOSH and analogues
[mg/kg] C10-C50
MOAH [mg/kg] C10-C50 Notes
Vegan and vegetarian savoury spreads, toppings, cold cuts and similar products (meat, fish and sausage substitutes) 5  n.b.1/2 not for plant based alternatives for milk, cheese and dairy

Vegan and vegetarian pan products with leanings towards products of animal origin, such as ground meat and ground meat products, burger patties, breaded products

11  n.b.1/2 not for plant based alternatives for milk,
cheese and dairy

LOQmax for total MOAH (cf. JRC Technical Report) for low-fat foods < 4% fat corresponds to 0.5 mg/kg; for foods > 4% fat corresponds to 1 mg/kg
LOQmax for total MOAH (cf. JRC Technical Report) for fats/oils corresponds to 2 mg/kg
Deferred due to insufficient data available

Statement on the handling of MOAH findings

In addition, the Standing Committee of the Commission on Plants, Animals, Food and Feed (SC PAFF) published an opinion this year on a uniform EU-wide approach for dealing with findings of aromatic mineral oil hydrocarbons (MOAH) in food.

The member states agreed to assess food as unfit for human consumption within the meaning of Art. 14 of Regulation (EU) No 178/2002 where official controls detect MOAH levels greater than/equal to the maximum limits of quantification proposed in the 2019 Joint Research Centre (JRC) Technical Report:

  • dry, low-fat foods [≤ 4% fat/oil]: 0.5 mg/kg
  • foods with higher fat content [> 4% fat/oil]: 1.0 mg/kg
  • fats/oils: 2.0 mg/kg

As the statement has no legal character, it remains to be seen to what extent the competent supervisory authorities will follow it.

Our experts from the contaminants department carry out the analysis of mineral oil hydrocarbons using an HPLC-GC-FID method based on the BfR method from 2009 and DIN EN 16995. Various optimisation steps are carried out to enable differentiated analysis of the mineral oil hydrocarbons in the sample.

We will be happy to advise you. Contact us for more information.


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