6 replies to this topic

[SHQuality]

Can someone shed some lights on the limits for MOSH and MOAH used in Germany?

I am aware that the BfR set reference values and BMELV drafted legislation, but so far there's only clear legislation on MOAH limits.

 

Which MOSH/POSH limits are used by most German clients and what are these limits based on? A legislation draft from 2014 seems too old to base anything off if it's still not full implemented.

 

Mineral Oil Hydrocarbons (MOH) in food and packaging - Merieux Nutrisciences

Mineral oil hydrocarbons (MOH) in foods: Update of the recommended benchmark levels for MOH (lebensmittelverband.de)

 

 

 

[Marloes]

Hi SHEQuality,

Please see the updated benchmarks for MOSH/MOAH here: Länderarbeitsgemeinschaft Verbraucherschutz (lebensmittelverband.de)
The same document also states: ''Consequently, the levels are recommendations and give guidance for practical use; by definition they are not to be interpreted or used as threshold limit levels.''

 

You should also keep in mind that there is no legislation on MOSH MOAH as of yet. We are still waiting on the EFSA risk assessment, which should be published any moment now.
 

 

But we do off course have the SCOPAFF statement from last year, proposing MOAH limits to which members states can choose to create there own legislation/monitoring.

1. Dry foods with a low fat content (≤ 4% fat/oil): 0.5 mg/kg
2. Foods with a higher fat content (> 4% fat/oil, ≤ 50 % fat/oil): 1 mg/kg
3. Fats/oils and foods with > 50 % fat/oil: 2 mg/kg

But to my understanding hardly any EU member states are currently enforcing these limits.

[SHQuality]

I'm struggling with certain German retailers who have set requirements far below what could be reasonably considered a current recommendation.

The MOAH recommendations are basically settled, but I've seen MOSH recommendations of 24 mg/kg on a COA, a limit of 12 mg/kg on another document and a limit of 4 mg/kg  for my specific product on another. Meanwhile some of those retailers have set requirements of 2 mg/kg which is far below what I consider to be reasonable compared to the other values I've read in the guidance documents.

 

Why are they setting limits on something that isn't even legally required yet?

It feels like they're making it up as they go.

[Marloes]

It is all a big political issue at this moment. We don't even know how toxic (carcinogenic) these substances are and which specific components within MOSH/MOAH are actually toxic. They are currently modelling after BenzoAlfaPyrene (BaP), but this is most likely not accurate.

I think the retailers are covering themselves in case of (political/consumer) backlash. (see the foodwatch - bouillon cubes issue for that one)
If you have data available show what is normal for your product category at this time and how you are mitigating these issue's and push to better/fairer/no limits.

 

Are retailers setting 2mg/kg for MOSH?

[SHQuality]

At least one big German retailer did and, naturally, the customer didn't feel it was in their own best interest to call them out on it.

[Nikolina_D]

Hello,

 

Lately, I have received numerous requests from clients regarding Moah and Mosh.

 

Last year, a new draft was published that will come into force by the end of this year or the beginning of 2025, as far as I know.

 

You can find it online by searching for:

 

SANTE PLAN 2023/2345 Rev.1. COMMISSION REGULATION (EU) …/… of XXX amending Regulation (EU) 2013/915 concerning maximum levels of mineral oil aromatic hydrocarbons in food.

 

However, I am not making any formal statements yet because it is not yet in force. Nonetheless, I have already engaged my suppliers to ensure that they begin monitoring these parameters.

[crismcl]

Hi, 

 

I have the same problem with that German retailer.

They keep sending non conformities for MOSH analysis of more than 2 mg/Kg.

Are there any relevant updates on MOSH control/limits?

 

Thank you!