Food News

The latest draft legislation and monitoring recommendations reflect a comprehensive European regulatory approach. This aims to ensure food safety by setting mandatory limits for MOAH and establishing a formal monitoring framework for MOSH and MOAH.

The current regulatory landscape is summarized below based on the latest draft documents:

1. Mandatory Maximum Levels (ML) for MOAH

The European Commission is amending Regulation (EU) 2023/915 to set legally binding limits for the total content of MOAH (range ≥C10 to ≤C50). These limits apply regardless of the source of contamination, including raw materials, processing aids or packaging. MOAH limits are proposed for:

• oilseeds

• oils & fats

• tree nuts

• pulses

• cereals and products thereof

• milk and dairy products

• cocoa

• confectionary

• spices, dried herbs and instant tea

• processed and compound foods containing the above as ingredient

• infant/baby food

• food supplements

• food additives

General limit values based on fat content: The draft largely adopts the ‘SCoPAFF’ guideline values as legal limit values for most foods:

• 0.50 mg/kg for foods with< 4% fat/oil
• 1.0 mg/kg for foods with ≥ 4% and ≤ 50% fat/oil
• 2.0 mg/kg for foods with> 50% fat/oil

Specific categories:

• Fats and Oils: maximum limit of 2.0 mg/kg applies to most vegetable oils (rapeseed, sunflower, etc.). For certain oils such as argan, coconut or peanut oil, higher limits apply temporarily (up to 10.0 mg/kg), which will be gradually reduced to 2.0 mg/kg by 1st January 2030
• Spices, dried herbs and instant tea: The draft proposes a limit of 10.0 mg/kg from 2027, to be reduced to 5.0 mg/kg by 2030
  Exemption for tea: Conventional dry tea and herbal teas are generally exempt from the MOAH limits, provided they are not instant products or used as food ingredients, as only limited transfer of MOAH occurs into the brewed beverage. beverage
• Food supplements: Proposed limit of 10.0 mg/kg (2027), to be reduced to 5.0 mg/kg by 2030
• Processed and compound foods: The general limits based on fat content will also apply to processed and compound foods from 2030

2. Recommendation on the monitoring of MOSH/MOAH (2026–2029)

A new Commission recommendation has been drawn up for the years 2026 to 2029. The aim is to collect data where it is currently lacking and to monitor product categories where the safety margins for exposure are limited.

• Indicative levels (IL): These are not legal limits for market exclusion, but triggers for investigations to identify the source of contamination
  • Indicative MOSH values: These range from 1.0 mg/kg (infant formula) to 50 mg/kg (e.g. olive pomace oil, fish oils). Common foods such as cereals and milk have an IL of 5.0 mg/kg
  • MOAH guideline values: These range from 1.0 to 10 mg/kg for products not yet subject to mandatory limits (e.g. coffee, essential oils)
• Target categories: Monitoring will cover a wide range of products, from staple foods such as cereals and meat to specific products such as poultry meat (testing for paraffin from vaccines) and cereal grains for beer production

3. Sampling and analysis requirements

To support these new limits, Regulation (EC) No 333/2007 will be updated with strict performance criteria:

• Precautions during sampling: Samples must be stored in inert containers (glass or PTFE-coated lids) and wrapped in aluminium foil to prevent cross-contamination from adhesives, labels or the environment
• Analytical Performance: 
  • Limit of quantification (LOQ): Must be ≤ 0.50, 1.0 or 2.0 mg/kg depending on fat content, or ≤ 5.0 mg/kg for special products such as spices and food supplements
  • Verification: The use of GC×GC is recommended for the validation of the analysis and the differentiation between actual mineral oil and interfering substances

4. Implementation timeline

If adopted, the new regulations are expected to come into force on 1st January 2027, with the final harmonised limits for all processed foods becoming fully effective on 1 January 2030.

YOUR PLUS: Your partner for global MOH compliance: With many years of experience and two specialised laboratory sites, the AGROLAB GROUP offers MOSH/MOAH testing that exceeds the latest EU draft requirements.

• Ready to perform: Full compliance with the new standards for recovery and reproducibility
• Expert evaluation: Extensive experience in interpreting complex chromatograms to accurately distinguish mineral oil of fossil origin from biogenic contaminants and other matrix effects
• Future-proof: Strategically prepared for the implementation date of 1st January 2027 and the final targets for 2030

Work with us to ensure your compliance with the new maximum limits for the monitoring period 2026–2029 and beyond.

Autor: David Guth, Operational Product Manager Food, AGROLAB GROUP