Grain maximum contaminant levels
Hello,
can you please help me interpret COMMISSION REGULATION (EC) No 1881/2006 of 19 December 2006 setting maximum levels for certain contaminants in foodstuffs:
Our company is buying unprocessed wheat, maize, oats and other cereals from farmers. We give them to our subcontractor who dries, cleans and stores them for our company. The grain are separated by product, but the same grain crop is mixed from different farmers. We do not manufacture products for end consumers, but they may be packed by companies which we sell to and sell these products to end consumers.
Can you please help me interpret which maximum levels is applicable for our products?
2.4.1 Unprocessed cereals (31) (32) other than durum wheat, oats and maize - 1 250μg/kg
2.4.2 Unprocessed durum wheat and oats (31) (32) -1 750μg/kg
2.4.3 Unprocessed maize (31), with the exception of unprocessed maize intended to be processed by wet milling (47) - 1 750μg/kg (33)
2.4.4 Cereals intended for direct human consumption, cereal flour, bran and germ as end product marketed for direct human consumption, with the exception of foodstuffs listed in 2.4.7, 2.4.8 and 2.4.9 - 750μg/kg
►M37 ( 31 ) The maximum level applies to unprocessed cereals placed on the market before first-stage processing. In integrated production and processing systems the maximum level applies in the production chain at the stage before first-stage processing. Integrated production and processing systems means systems where all incoming lots are cleaned, sorted and processed in the same establishment. ◄
Drying and cleaning, including sorting (colour sorting where applicable) and scouring, are not considered to be ‘first-stage processing’ insofar as the whole grain remains intact.
If you know that your customers sell straight to consumers, I would interpret that as 2.4.4. If you had any other limit, there is no way they could possibly comply with the rules once the product enters their system.