MOSH-MOAH – Application of Limit Values – Update
In January 2024, we reported that the EFSA opinion and SCoPAFF statement on MOAH have led German authorities to adopt the analytical limits of quantification for MOAH (C10–C50) as regulatory limits. Previous article.
The latest draft (Version 7) of the amendment to Regulation (EU) 2023/915 now sets maximum limits for MOAH in certain foods. According to the current draft regulation, no maximum limit is planned for coffee. Consequently, no official maximum limit can be used to assess the marketability of coffee with regard to MOAH under this draft. In its letter dated November 2024, the Lebensmittelverband Deutschland (German Food Association) already recommended conducting an individual risk assessment when evaluating a potential marketing ban under Article 14 of Regulation (EC) No. 178/2002. The reference to roasted or instant coffee, rather than prepared coffee, appears problematic with regard to the assessment under Article 14 if, in the ready-to-drink beverage, analytically detectable MOAH levels are no longer reasonably expected.
Since it is expected that consumers will consume coffee as a prepared coffee beverage, we recommend taking the levels in the prepared beverage into account for the assessment under Article 14. Based on previous experience, the migration of MOAH into the ready-to-drink coffee beverage is low (but present). Regular screening of coffee as part of risk management is still recommended, also in view of the planned monitoring recommendation.
It remains to be seen how German authorities will handle MOAH findings in coffee that exceed the analytical limit of quantification until the draft amendment to Regulation (EU) 2023/915 enters into force.
We are happy to assist you with the evaluation of your analysis results.
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Source:
7th Draft Amendment to Regulation (EU) 2023/915
ALB Lebensmittelverband Deutschland: Beurteilung von Mineralölkohlenwasserstoffen (MOH) in Lebensmitteln. Erläuternde Hinweise zur EFSA-Stellungnahme und zur gemeinsamen Erklärung der EU-Mitgliedstaaten im SCoPAFF
Stellungnahme der Europäischen Kommission: Standing Committee on Plants, Animals, Food and Feed Section Novel Food and Toxicological Safety of the Food Chain, 19 October 2022 – A.03 Clarifications on the joint statement of 21 April 2022 of the Member States regarding the presence of Mineral Oil Aromatic Hydrocarbons (MOAH) in food, including food for infants and young children
Stellungnahme der Europäischen Kommission: Standing Committee on Plants, Animals, Food and Feed Section Novel Food and Toxicological Safety of the Food Chain – A.01 Mineral oil hydrocarbons in food: follow-up to the December 2021 Foodwatch report, 2022