Update on Mineral Oil Hydrocarbons | Global Webinar | Join ALS Experts

The update latest update draft for Commission Regulation (EU) 2023/915 was advocated by the responsible committee May 13^th 2026, planning to introduce product specific MOAH limits.

The general requirements for Mineral Oil Hydrocarbon (MOH) testing in food and food contact material have long been established in Germany, yet, have been relation to so-called orientation values.

A variety of analytical approaches has been developed, but the results are different and hard to compare between labs. Whilst plenty of retailers and larger corporates took the orientation values as almost legal limits, global producers and suppliers had certain struggle to apply the right methods to fulfill clients and markets expectation.

Webinar - FAQ

Composite foods Do proposed MOAH maximum levels apply to composite foods?

Yes. The regulation draft includes maimum limits for composite food. However gerneral maximum limits for this will only apply in 2030.

Fish products What approach applies to canned fish containing olive oil or vegetable oil?

A specific EU limit for this processed-food category had not yet been defined. For raw products, the applicable limits may be used as a reference; from 2030, values of 1 or 2 mg/kg may apply depending on fat content.

Herbs and spices How should herbal infusions and dried herbs be assessed?

For dry herbs the regulation draft contains a direct maximum limit. For herbal infusions the testing result needs to be recalculated to the dired herbs of the infusion to have an applicable maximum limit.

Herbs and spices Can a concentration factor be used for fresh herbs and spices?

For fresh herbs and spices, a concentration factor should be applied when assessing against the maximum level for dried herbs and spices.

Herbs and spices Does a drying factor apply to turmeric powder?

If turmeric powder is classified as a dried spice, the maximum level applies to the dried product itself, without an additional drying factor.

Oleoresins How should chilli oleoresin be categorised?

As the oil may be a risk as well the approach of applying a concentartion factor to use the dired spices maximum limit is not correct. Therefore such products will be assessed against the compound food or compound food with spices categroy from 2030 on.

Microalgae and gums Are EU maximum levels established for spray-dried microalgae powder or gum acacia?

No specific EU maximum levels had been set for these products. For dried products, concentration may sometimes be calculated under Article 3 of Regulation (EU) 2023/915, but this does not create a maximum level where none exists.

Coconut oil Why is coconut oil excluded from the vegetable-oil benchmark?

A separate provision in section 5.5.2.2 of the draft regulation for coconut oil. Consult the current adopted text and product-specific requirements for the applicable reference value.

Food contact materials Can labels be treated in the same way as paper or cardboard packaging?

Labels were considered within the paper-and-cardboard food-contact grouping; there is no need to differentiate labels from packaging.

Food contact materials What is a functional barrier against MOSH/MOAH?

There is no single material that always can be classified as a functional barrier. Performance depends on conditions such as contact time and temperature. Glass and aluminium are generally effective, whereas PE and PP are generally not; other materials should be assessed case by case.

Food contact materials Can recycled paper and cardboard still be used for food packaging?

Yes, but particular care is needed where recycled paper or cardboard may be in direct contact with food. Monitoring potential migration and using an appropriate functional barrier are important considerations.

Food-grade lubricants Can MOSH and MOAH be measured directly in food-grade lubricants?

Yes. Direct analysis of food-grade lubricants is possible.

MOSH monitoring Is there an EU maximum level for MOSH?

The EU has not yet established maximum limits for MOSH. However, several countries have published guidance or action values that are used by regulatory authorities for assessment purposes. Elevated MOSH levels in food may still result in a product being deemed unfit for human consumption under Article 14 of Regulation (EC) No 178/2002, even in the absence of EU-wide maximum limits.

Analytical methods Why can different laboratories report different results for the same sample?

Differences can arise from sample clean-up and method selection. For complex matrices, ALS labs are combining ALOX clean-up and epoxidation to improve result reliability.

Analytical methods Is FID sufficient, or is mass spectrometry required to avoid false positives?

With comprehensive sample clean-up using both aluminium-oxide treatment and epoxidation, false-positive risk should be limited and LC-GC-FID is sufficient in most cases. Mass spectrometry can provide additional structural information but may be less suitable for general quantification.

Analytical methods Which method is most reliable for mineral oil hydrocarbons in vegetable oils, cereal snacks and baby food?

The LC-GC-FID method is the preferred option for reliable general quantification. GC×GC-MS can provide further insight into contaminant structure and potential sources.

Analytical methods What analytical variability should be expected for MOSH/MOAH testing?

An analytical variation of approximately 50% is common for these methods, although it is not applied automatically in the same way as for example pesticide measurement uncertainties.

Food contact materials Are there EU maximum levels for MOSH/MOAH in packaging materials such as tin cans and corrugated board?

There are currently no official limits established at either the EU or global level. However, some countries have introduced specific requirements for certain materials. For example, in Germany, the BfR published guidance values for paper and cardboard intended for food contact. For most other matrices, no official limits or regulatory thresholds have been established to date.

Data sharing Are laboratory results shared with authorities to monitor MOSH/MOAH trends?

There was no current request from our local authorities. yet Where needed and permitted, anonymised data could potentially be shared.

This Q&A is a simplified summary of webinar responses. It is not legal advice and may not reflect subsequent regulatory changes, final adopted texts, national requirements, customer specifications or product-specific circumstances.