Mineral Oils and Paper&Board for food contact: a brief overview on a FCMs hot topic

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What are MOH?

I MOH (Mineral oil hydrocarbons) are complex mixtures, which are defined as substances of unknown and variable composition (UVCB substances) in the REACH Regulation.

They consist of three major classes of hydrocarbon compounds, namely:
(i) straight and branched open-chain alkanes (paraffins),
(ii) mostly alkylated cycloalkanes (naphthenes) and
(iii) alkylated and non-alkylated aromatics.
The latter is defined as MOAH and the first two classes are collectively defined as MOSH (EFSA CONTAM Panel, 2012).
MOH do not encompass the hydrocarbons naturally occurring in food, i.e. n-alkanes of predominantly odd-numbered carbons from C21 to C35, hydrocarbons of terpenic origin, such as squalene, and carotenoids.
Polyolefin oligomeric saturated hydrocarbons (POSH), that may be present in food due to migration from plastic packaging (such as polyethylene or polypropylene), are not included in the term MOSH.

In the scientific opinion on mineral oil hydrocarbons in food from the European Food Safety Authority (EFSA), published in 2012, the exposure of consumers to mineral oil hydrocarbons (MOH) was considered to be of potential concern. The potential human health impact of MOH varies widely.
Mineral oil aromatic hydrocarbons (MOAH), in particular 3-7 ring MOAH, may act as genotoxic carcinogens, while some mineral oil saturated hydrocarbons (MOSH) can accumulate in human tissue and may cause adverse effects in the liver. [1]

Which are the sources of MOH?

MOH may enter the food chain via different routes, such as:

  • environmental contamination from the air or via the terrestrial or aquatic ecosystem;
  • contamination during harvesting and processing from lubricated/oiled machine parts;
  • migration from food contact materials;
  • use of food additives and pesticides;
  • contaminated feed due to the use of refined edible oil, binders for feed additives and waste entering feed.

Due to the numerous potential sources, the source of the contamination is often difficult to identify. A comprehensive review of the sources of MOH in the food chain is presented in the EFSA opinion (EFSA CONTAM Panel, 2012). [1]

Which are the MOH methods of analysis?

The Joint Research Centre (JRC) has developed a guidance on sampling, analysis and data reporting for the monitoring of MOH in food and food contact materials. It provides guidance on the minimum performance requirements of the analytical methods used for MOSH/MOAH monitoring and was developed to support the implementation of Commission Recommendation (EU) 2017/844 for the monitoring of mineral oils.

The analysis of MOH in food is challenging. Current methods are not capable of separating MOH into single compounds with clearly defined peaks. MOH are complex mixtures and chromatograms show irregular and varying humps of largely unresolved components. Separation of MOSH from MOAH can be achieved by LC, which is combined with GC-FID for quantification. The two separation techniques can be combined on-line and off-line. [1]

Some important steps

• In January 2017, the European Commission published the recommendations for Europe-wide monitoring of the occurrence of mineral oil hydrocarbons in foodstuffs (RECOMMENDATION 2017/84 on the monitoring of mineral oil hydrocarbons in foodstuffs and materials and items intended to come into contact with foodstuffs). [2]

• At the beginning of March 2017, the German Federal Ministry of Food and Agriculture (Bundesministerium für Ernährung und Landwirtschaft, BMEL) announced the fourth draft of a 22nd regulation on the modification of the German Consumer Goods Ordinance with last edit as at 07 March 2017 for the creation of a national “mineral oil regulation”.[3]

• On February 23, 2019, the European Commission’s (EC) Joint Research Centre (JRC), published a guidance on “sampling and analysis of mineral oil saturated hydrocarbons (MOSH) and mineral oil aromatic hydrocarbons (MOAH) in food and FCM [food contact materials] in the frame of Recommendation (EU) 2017/84 for the monitoring of mineral oils”. [4]

• On 17th of August 2020 Germany notified on the TRIS website the draft Zweiundzwanzigste Verordnung zur Änderung der Bedarfsgegenständeverordnung (Twenty-second Ordinance amending the Consumer Goods Ordinance) the so called “mineral oil ordinance”.  [5]


  1. EFSA
  2. Official Journal of the European Union
  3. Bundesministerium für Ernährung und Landwirtschaft
  4. European Commission
  5. European Commission

Ecol Studio can support your company in the the evaluation of Mineral Oil
Hydrocarbons in paper&board FCMs; rely on our experts and our certified laboratories.

Contact us +39.0583.40011 or Mail to: productsafety@ecolstudio.com

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