As of 1 January, 2024, the NVWA (Netherlands Food and Consumer Product Safety Authority) will begin enforcing compliance limits for MOAH (Mineral Oil Aromatic Hydrocarbons) in food products. MOAH compounds occur in synthetic mineral oils and do not belong in food. Nevertheless, MOAH frequently enters food products unintentionally, posing potential health risks. “This impacts virtually every food product, affecting growers, manufacturers, and retailers alike. However, in this specific case, it may not be wise to test raw materials too early in the supply chain,” explains Ruben Thomaes, MOAH Expert at Eurofins Food, Feed, Water Benelux. In this article, he explains the background and what this means for your operations.
Draft EU regulations for MOAH have been in place for some time. This draft framework is laid down in sante.ddg2.g.5(2022)3966048 (Standing Committee on Plants, Animals, Food and Feed Section Novel Food and Toxicological Safety of the Food Chain, 21 April 2022). Thomaes: “In the Netherlands, the NVWA is now going to actively monitor this draft regulation. Currently, each EU member state approaches this individually, but other European countries will undoubtedly follow. MOSH (Mineral Oil Saturated Hydrocarbons) compounds are excluded from enforcement; the NVWA will not enforce MOSH limits. To date, MOSH has not been proven to be potentially pathogenic. However, the European Food Safety Authority (EFSA) considers MOAH to be potentially carcinogenic and genotoxic. The Dutch National Institute for Public Health and the Environment (RIVM) regards MOAH from insufficiently refined mineral oils as carcinogenic, even at low exposure levels. For MOSH/MOAH testing, MOSH remains an essential analytical parameter and will still appear on test reports.”
“Toxic MOAH compounds have been detected across all food categories: from pasta, baby food, and (breakfast) cereals to flour, chocolate, rice, spices, stock cubes, fats, oils, and packaged foods. Tracing the exact source is often challenging,” Thomaes explains. “MOSH and MOAH can contaminate our food via pesticides, vehicle or industrial emissions, or through mineral oil migration at virtually any stage of the manufacturing process—such as lubricants on conveyor belts, mineral oil evaporation, cleaning agent residues, or packaging materials. Furthermore, MOSH and MOAH migrate throughout the supply chain. If dry pasta contains MOSH and MOAH, the ready-to-eat spaghetti bolognese made with it will contain these substances too.”
Thomaes currently notes a dramatic increase in MOSH and MOAH analyses at Eurofins: sample volumes have doubled compared to last year. “We see this in the Netherlands, but also in Turkey and Switzerland, coming from both retailers and manufacturers. The Eurofins Food & Feed Testing network also analyszes substantial sample volumes outside the EU. Suppliers from China, the US, and Thailand must equally comply with these standards when exporting to Europe. Retailers and producers are increasingly shifting the responsibility for MOAH upstream, expecting their suppliers to test raw materials early in the chain. Normally, that is a sound strategy. With MOAH, however, it is complicated: analytical methods were originally developed for finished consumer products as purchased in the supermarket. Equipment and method manufacturers confirm this limitation. We are currently refining and optimising the methodology to better analyse raw materials and matrices prone to analytical interferences. This is an industry-wide challenge faced by all testing laboratories, not just the Eurofins network.”
Raw materials can cause significant analytical interference and distort test results. “This occasionally leads to false-positive MOAH results. Examples include natural aromatic compounds in spices or teas, which analytical instruments can register as positive. Other examples include fatty acids such as omega-3, additives like stabilisers or emulsifiers, and ingredients like lecithin or tocopherol (vitamin E). These compounds can also produce false-positive signals. While we can mitigate these interferences, doing so requires additional analytical steps and specialised cleanup, increasing costs and adding complexity.”
Why are these interfering substances manageable in finished products? “In a finished product, spices might make up only 0.5% of the total formulation, which does not interfere with the analysis. However, if we test a 100% pure sample of those spices, natural aromatics immediately cause interference issues. The same applies to testing neat samples of 100% olive oil or pure emulsifiers: these require entirely different sample preparation methods. Food producers and retailers are legally required to take every reasonable measure to ensure product safety, which naturally encourages testing as early in the supply chain as possible. However, from an analytical perspective, this creates new challenges.”
What limits must MOAH levels stay below in food products? The draft EU action thresholds depend on the product category:
| Product category | Draft EU Thresholds: Integrated Total MOAH (mg/kg) |
| Dry foods with low fat/oil content (≤4% vet/olie) | 0,5 |
| Foods with higher fat/oil content (> 4% ≤50% 1,0 vet/olie) | 1,0 |
| Fats / Oils (>50%) | 2.0 |
Contact our specialists via sales-food-nl@eurofins.com or call +31 (0)888 31 00 00, or click here for further information.
During the VMT Food Safety Event on 16 November, Ruben Thomaes will dive deeper into this topic: How should the food industry interpret MOAH guidelines? Should companies take action on MOSH? Eurofins conducted an in-depth study into the risks associated with MOAH. Thomaes will outline how MOAH enters the food supply, provide updates on applicable guidelines, review the risks of exceeding MOAH thresholds, and explain when monitoring is necessary. Drawing on practical case studies, he will demonstrate how the Eurofins Food & Feed Testing network approaches these analytical challenges in the laboratory. The session will conclude with an extensive Q&A to answer your questions.