As the year draws to a close, an important issue is on the agenda for companies that closely follow European Union food legislation. Under the new food regulation planned to apply in EU countries from 1 January 2027, products will begin to be examined with regard to residue limits for mineral oil hydrocarbons. So what are mineral oil hydrocarbons?
Mineral oil hydrocarbons (MOH) are compounds containing 10 to about 50 carbon atoms. They derive mainly from crude oil, but can also be produced synthetically from coal, natural gas and biomass. They are divided into two main groups: MOSH (saturated), which are paraffinic and naphthenic hydrocarbons, and MOAH (aromatic), which are hydrocarbons containing aromatic rings. Studies have found that these compounds accumulate in the body, that MOAH compounds with three or more rings in particular can show carcinogenic effects, and that they have harmful effects. As a result, these compounds have begun to be measured in the production of fat-containing raw materials and in processes that can leave residues through contact with food.
The issue first reached the public and regulatory agenda in 2008. High levels of mineral oil were detected in sunflower oil of Ukrainian origin and reported to RASFF, the alert system used for food in the EU. Konrad Grob, a researcher specializing in this field, wrote an article about the harmful effects of these compounds that made a considerable impact. However, the problem was not limited to contamination in oils. Once the seriousness of the situation was recognized, it became clear that similar contamination could also occur through mineral oils from newspaper ink in recycled cardboard evaporating and transferring to food. In surveys carried out in Germany in 2010–2011 on 119 dry food samples, packaging-related mineral oil migration was detected.
So what happens now?
The European Food Safety Authority (EFSA) has published a comprehensive risk assessment on the subject. According to the 2023 assessment, MOSH exposure does not currently give rise to a concern, but it will be monitored. On the other hand, MOAH compounds with three or more rings in particular have genotoxic and carcinogenic potential. For this reason, a binding limit is being introduced, which will also affect the EU's trading partners, that is, heavily exporting countries such as Türkiye. EU member states agreed on 13 May 2026 to set maximum levels.
All raw materials at risk of contamination are within scope: oilseeds, oils, tree nuts, pulses, cereal products, milk and dairy products, cocoa and confectionery, spices, dried herbs, teas, compound and processed foods, baby foods, food supplements and food additives.
The measures food producers will need to take going forward include, first of all, requesting MOSH/MOAH C10–C50 results (LC-GC-FID) in suppliers' certificates of analysis for the raw materials they use, inspecting contamination sources such as lubricants, sacks and recycled cardboard, and adding compliance declarations to contracts. Foods exceeding the set limit will not be allowed on the market and cannot be used as a raw material or ingredient in other foods. In other words, the raw material supplier will also be responsible.
Products lawfully placed on the market before the date of application will be able to remain on the market until their use-by or best-before date. Publication of the regulation in the Official Journal of the EU is expected before end of the year, and the date of application will be confirmed once it is published. In the meantime, member state enforcement authorities have been using the limits as a basis for their risk assessments since 13 May 2026. Companies across the supply chain should therefore prepare without waiting for the publication date.
References
- EFSA Panel on Contaminants in the Food Chain (CONTAM) (2023). Update of the risk assessment of mineral oil hydrocarbons in food. EFSA Journal 21(9): e08215. https://doi.org/10.2903/j.efsa.2023.8215
- EFSA Panel on Contaminants in the Food Chain (CONTAM) (2012). Scientific Opinion on Mineral Oil Hydrocarbons in Food. EFSA Journal 10(6): 2704. https://doi.org/10.2903/j.efsa.2012.2704
- European Commission. Draft Commission Regulation amending Regulation (EU) 2023/915 as regards maximum levels of mineral oil aromatic hydrocarbons (MOAH) in food (SANTE/PLAN/2023/2345, Rev. 10; Standing Committee on Plants, Animals, Food and Feed, 13 May 2026). https://food.ec.europa.eu/document/download/5adfb70c-b57f-42a6-b4b3-37bc390c8b36_en?filename=cs_contaminants_catalogue_sante-plan_b-01_2023-2345-text_ml-moah_rev-10.pdf
- Grob, K. (2008). Could the Ukrainian sunflower oil contaminated with mineral oil wake up sleeping dogs? https://www.researchgate.net/publication/286939760_Could_the_Ukrainian_sunflower_oil_contaminated_with_mineral_oil_wake_up_sleeping_dogs
- Biedermann, M. & Grob, K. (2009). How "white" was the mineral oil in the contaminated Ukrainian sunflower oils? https://www.researchgate.net/publication/228009341_How_white_was_the_mineral_oil_in_the_contaminated_Ukrainian_sunflower_oils
- Vollmer, A. et al. (2011). Migration of mineral oil from printed paperboard into dry foods: survey of the German market. European Food Research and Technology 232: 175–182. https://link.springer.com/article/10.1007/s00217-010-1376-6
- Lorenzini, R. et al. (2013). Migration kinetics of mineral oil hydrocarbons from recycled paperboard to dry food: monitoring of two real cases. Food Additives & Contaminants: Part A 30(4). https://www.tandfonline.com/doi/abs/10.1080/19440049.2013.766765
- FoodNavigator (27 May 2008). EU moves to restrict Ukrainian sunflower oil imports. https://www.foodnavigator.com/Article/2008/05/27/eu-moves-to-restrict-ukrainian-sunflower-oil-imports/
- Eurofins. MOAH findings in foodstuffs. https://www.eurofins.de/food-analysis/food-news/food-testing-news/moah-findings-in-foodstuffs/