MOSH-MOAH - Immediate application of maximum residue limits by German authorities possible

As already reported in September 2023, the European food safety authorities are working on a risk assessment for MOSH/MOAH. The aim is to derive specific guideline values and associated calls for action.

EFSA's efforts have resulted in the current decision by the "Working Group of the Common Guidance Values of the Federal States" that foods in which MOAH exceeds the limits of quantification are "unsuitable for human consumption" and are contrary to the ALARA requirement.

In concrete terms, this means that the following analytical limits of quantification for MOAH (C10 - C50) are now used as the limit value by the German authorities:

  • Dry foods with a low fat content up to 4% fat/oil: 0.5 mg/kg.
  • Foods with a higher fat content of more than 4% - 50% fat/oil: 1 mg/kg.
  • Fats/oils or foods with more than 50 % fat/oil: 2 mg/kg


Currently, the measured value determined by the authorities is still reduced by the measurement uncertainty in the assessment. If values below the limit value are detected, the parties responsible for the product can be notified in order to comply with the duty of care and avoid contamination. If the authorities are certain that the limit value has been exceeded, a recall order can be issued.

Our method used for this purpose (DIN EN 16995 - 2017-08) is an online LC/GC-FID analysis, which meets the performance criteria of the analytic regarding the EFSA requirements. In addition to that, our experience in the analysis, evaluation, and assessment of mineral oil hydrocarbons (MOSH, POSH, PAO, MOAH) in different food matrices supports you in the clarification of possible contamination sources.



Goldbeck, Christophe: “Vorgehen der deutschen Überwachung bezüglich der EFSA-Opinion und SCoPAFF-Statements“, DLR 119. Jahrgang, Dezember 2023,

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

Bratinova, S. and Hoekstra, E., Guidance on sampling, analysis and data reporting for the monitoring of mineral oil hydrocarbons in food and food contact materials, EUR 29666 EN, Publications Office of the European Union, Luxembourg, 2019, ISBN 978-92-76-00172-0, doi:10.2760/208879, JRC115694.

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    Mr Dirk Westermann
    +49 421 64905 1800