New draft on maximum residue limits for MOAH

: Published: 04 September 2024

At its last meeting at the end of June, the EU working group on environmental contaminants agreed on the establishment of new limit values for aromatic mineral oil hydrocarbons (MOAH).

In the next step, the member states will have the opportunity to discuss the proposals at the national level and then present a joint draft regulation to the stakeholders. However, this process is not expected to be completed until 2025, so that new limit values are not expected until 2026 at the earliest.

Our AGROLAB RADAR has, of course, registered the proposals of the working group, which we would like to share with you. The information is not yet publicly available, but it comes from generally reliable sources

5.5	Mineral Oil Aromatic Hydrocarbons (MOAH) (≥C10 to ≤C50)	Maximum levels (mg/kg)
5.5.1	Oilseeds and oilfruits	2,0
5.5.2	Animal and vegetable fats and oils other than those produced from cocoa beans and milk.
5.5.2.1	Maize, rapeseed, sunflower, soybean, linseed and olive oil other than olive pomace oil listed under 5.5.2.4.	2,0
5.5.2.2	Oils and fats other than those listed in 5.5.2.1, 5.5.2.3, 5.5.2.4, 5.5.2.5 and 5.5.8 and those produced from cocoa beans and milk.	4,0 _{from 01/01/2026} 2,0 _{from 01/01/2028}
5.5.2.3	Blackcurrant seed, grapeseed, groundnut, sesame, argan, cottonseed and rice oil and coconut fat and oil.	6,0 _{from 01/01/2026} 4,0 _{from 01/01/2028} 2,0 _{from 01/01/2030}
5.5.2.4	Olive pomace oil	10,0 _{from 01/01/2026} 5,0 _{from 01/01/2028} 2,0 _{from 01/01/2030}
5.5.2.5	Marine oil and essential oil	10,0 _{from 01/01/2026} 5,0 _{from 01/01/2030}
5.5.3	Tree nuts	2,0
5.5.4	Pulses	0,5
5.5.5	Cereal grains _{The maximum level does not apply to cereals used for the production of beer or distillates, provided that the remaining cereal residue is not placed on the market for the final consumer as food. In case the remaining cereal residue is placed on the market for the final consumer as food, the maximum level applies, taking into account Article 3} ^{(1), (2)}.	0,5
5.5.6	Milk	0,5
5.5.7	Cocoa beans	2,0
5.5.8	Sugar	0,5
5.5.9	Spices & dried herbs	5,0
5.5.10	Infant formulae ⁽³⁾, follow-on formulae ⁽³⁾, young-child formulae ⁽⁴⁾, food for special medical purposes intended for infants and young children ⁽³⁾, baby food ⁽³⁾, processed cereal-based food for infants and young children ⁽³⁾ and drinks for infants and young children placed on the market and labelled as such (depending on fat content)
5.5.10.1	Products with < 4% fat/oil content	0,5
5.5.10.2	Products with ≥ 4% and ≤ 50% fat/oil content	1,0
5.5.10.3	Products with > 50% fat/oil content	2,0
5.5.11	Food supplements	10,0 _{from 01/01/2026} 5,0_{from 01/01/2030}

(ohne Gewähr) Die Fußnoten entsprechen den Fußnoten im Anhang der Verordnung (EU) 2023/915

For dried, diluted, processed and compound foodstuffs, the maximum level shall be calculated in accordance with Article 3 of Regulation (EU) 2023/915.

Contamination with MOAHs that occurs during the processing of a product shall not be taken into account when calculating the maximum level for the final product.

When calculating the maximum level of a dried, diluted, processed or compound food, only the concentrations of MOAH in the original ingredients and the concentration or dilution of the contaminants during the production process should be considered.

For ingredients of compound foods for which no maximum level of MOAH has been set, the following concentrations must be applied when calculating the maximum level for the compound food

0.50 mg/kg for ingredients with a fat content < 4 % fat/oil
1.0 mg/kg for ingredients with a fat content ≥ 4 % and ≤ 50 % fat/oil
2.0 mg/kg for ingredients with a fat content of more than 50%.

YOUR PLUS: It is still only a proposal. Regardless of what the regulation will ultimately contain, one thing is certain: the experts at AGROLAB will conscientiously test your raw products, ingredients and end products and always assess them according to the applicable legal requirements.

Author: Dr. Frank Mörsberger, AGROLAB

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