MOAH: new guidance from PAFF

The EU Standing Committee on Plants, Animals, Food and Feed (PAFF) has established strict limits of quantification (LOQs) for mineral oil hydrocarbons (MOH) in foods, with special focus on the aromatic fraction, MOAH (Mineral Oil Aromatic Hydrocarbons).

The European Food Safety Authority (EFSA) describes MOH as a diverse group of hydrocarbon mixtures comprising thousands of chemical compounds of different structures and sizes. Most MOH are derived from crude oil, but they can also be synthesised from coal, natural gas and biomass.

Composition, industrial uses and risks

The chemical composition of most MOH mixtures is unknown and varies by batch: technical specifications often omit composition, limiting themselves to viscosity or density values that are essential for the intended industrial application.

Depending on use, hydrocarbon-based mineral oils are marketed under names such as “paraffins, liquid paraffins, microcrystalline waxes, paraffin waxes” or “white mineral oil”. Applications are wide-ranging, from printing inks to cosmetics, from food packaging materials (including food contact materials – FCMs) to lubricants.

Several adverse health effects are attributed to MOH, though not all are fully established or documented. In particular, aromatic hydrocarbons (arenes), which always include benzene (C₆H₆), are considered potential genotoxic carcinogens capable of damaging DNA and causing cancer.

Occurrence in foods and contamination sources

In the EU, the use of some low- and medium-viscosity MOH as food additives is permitted. Beyond such specific legal uses, unwanted MOH in food mainly arise from migration from packaging materials, processing aids and environmental contaminants such as lubricants. Sporadic MOAH contamination has been detected in various foods: milk, snacks, biscuits, spreads and infant formula.

Microcrystalline wax in FCMs under scrutiny

The PAFF “Novel Food and Toxicological Safety of the Food Chain” meeting summary of 21 April 2022 recommends that Member States and food business operators check for MOAH in microcrystalline wax (petroleum wax, synthetic paraffin) and monitor potential migration into foods. The goal is to determine whether the use of microcrystalline wax in FCMs is a source of aromatic hydrocarbon contamination and, if so, to take measures to reduce or eliminate their presence in foods.

It is also necessary to verify whether microcrystalline wax in FCMs is declared as E905 (microcrystalline wax authorised for specific uses as a food additive) and, if so, whether it complies with the relevant specifications, in particular regarding benzo[a]pyrene (C₂₀H₁₂), a polycyclic aromatic hydrocarbon with known carcinogenic potential.

Recommended LOQs, withdrawals and analyses

According to PAFF, if checks confirm that MOAH in foods — including those intended for infants and young children — exceed the recommended LOQs for potentially carcinogenic compounds, the foods concerned must be withdrawn or, where necessary, recalled from the market, under Article 14 of Regulation (EC) No 178/2002. Article 19 of the same regulation underlines the shared legal responsibility of Member States and food business operators to ensure the highest possible level of consumer health protection.

To ensure a harmonised approach across the EU, Member States commit to withdraw and, where needed, recall non-compliant products when the sum of MOAH concentrations in foods is equal to or above the following LOQs:

• 0.5 mg/kg for dry foods with low fat/oil content (≤ 4% fat/oil);
• 1 mg/kg for foods with higher fat/oil content (> 4% fat/oil);
• 2 mg/kg for fats/oils.

Analyses must be carried out in accordance with Regulation (EC) No 333/2007. It is important to note that, for now, the LOQs specified in the PAFF summary are “recommended”, pending specific legislation to make them legally binding.

Carmine F. Milone

Sources:
https://food.ec.europa.eu/system/files/2022-07/reg-com_toxic_20220421_sum.pdf
https://www.efsa.europa.eu/it/topics/topic/mineral-oil-hydrocarbons
https://www.efsa.europa.eu/it/supporting/pub/en-1741
https://www.chimica-online.it/organica/idrocarburi-aromatici.htm
https://www.innovhub-ssi.it/media/articoli/la-contaminazione-degli-oli-vegetali-da-oli-minerali.kl
https://www.alimentiehaccp.com/2019/04/06/oli-minerali-e-loro-idrocarburi/