Additional Mineral Oil Hydrocarbon EU Regulation Updates
We have learned some additional details since GOED’s 12 June 2025 News Alert reporting on the proposal by the European Commission (EC) for the regulation of mineral oil hydrocarbons (MOH) in the EU.
On May 6-7, the EC Working Group on Industrial and Environmental Contaminants in Food held a meeting to finalize the technical discussions on MOH. The final versions of the texts were sent to EU Member States and stakeholders for information only. Final discussions on details of the text (for example, implementation dates for certain categories) will take place during the SCoPAFF (Standing Committee on Plants, Animals, Food and Feed) meeting of 19 September 2025, with the final vote expected on 19 November 2025.
One important aspect of the technical discussions that took place, but which is not reflected in the SANTE PLAN 2023 2726 Rev.6, is the proposal amending Commission Regulation (EC) No 333/2007 regarding the methods of sampling and analysis for the control of levels of mineral oil hydrocarbons in foodstuffs. The EC has confirmed the addition of MOAH into the regulation, thereby allowing the deduction of the analytical measurement uncertainty, both for official controls and self-monitoring. Self-monitoring is what companies report themselves based on their own testing results. An example would be a fish oil that tests 12,0 mg/kg for MOAH, and after allowable deduction of a (fictional) measurement uncertainty of 3,0 mg/kg, the oil would have a reportable level of 9,0 mg/kg, which would be compliant with the proposed maximum level (ML) of 10 mg/kg for oils derived from fishery products and algae.
Regarding some of the points we highlighted in the News Alert on which we did not have clarity, the following can be said:
Crude unrefined oils: While European trade associations argued for exempting crude oils intended for refining, the EC’s current position is that the available studies on the impact of refining are not sufficient and there are not enough guarantees regarding the effectiveness of refining in removing MOAH to reduce contamination to acceptable levels. Therefore, MLs should indeed apply to crude oils imported into the EU from third countries.
MOSH: The EC’s position is that indicative values should not be used as thresholds for product withdrawal/recall, since they are recommendations and not legally binding. However, some Member States apparently disagree and want to have some discretion in how they apply this guidance. For example, in France, a product that exceeds twice the recommended (indicative) value renders the product unfit for consumption, and recall/withdrawal measures must be implemented. It is unclear at this stage how this will turn out for any regulation of MOSH, but discrepancies in the interpretation of an indicative limit between EU countries regarding MOSH may be expected.
GOED will keep you informed as it learns about new developments occurring between now and September 19. 2025. We are also planning to discuss with GOED’s board of directors the possibility of submitting a letter to the EC on various outstanding concerns. Please contact Gerard Bannenberg with any questions.
Final Call for 2025 Special Achievement Program Applications
Third-party laboratories that participate in the AOCS-GOED Nutraceutical Oil LPP and have demonstrated high accuracy in the quantification of EPA and DHA in omega-3 oils are reminded to apply for this year’s GOED Special Achievement Program (SAP). The “Special Achievement” title is held for one year, during which time GOED promotes these laboratories to members and the public by including them on a dedicated webpage, promoting them in the GOED Current and preferentially recommending these laboratories when companies ask which testing labs to use. Two laboratories have already qualified for the 2025 award.
To apply, send your results from the most recent AOCS-GOED Nutraceutical Oil LPP and Analyst Number (series 2 and 3 results for the six samples) to gerard@goedomega3.com by June 30 (or whenever the appeals period is closed).
If you work with an external laboratory for the quantification of EPA and DHA in omega-3 oils, please encourage them to participate in the AOCS-GOED Nutraceutical Oil LPP, improve their proficiency and apply for the SAP in the future. You can download a flyer about the SAP here. For any questions, please contact Gerard Bannenberg.
Please note that GOED does not analyze or make any representation of accuracy for the Omega-3 News items. This is simply a compilation of news articles found on the internet that are relevant to the EPA and DHA business.
Highlights
Calling for Member Testimonials
We are inviting members to share a short video or text quote about how GOED has helped your business or supported you personally. These testimonials demonstrate the value of our community and will help expand our membership globally. If you would like to contribute a testimonial video or a text quote, please send it to Vicky Lin.
See the video below for a new testimonial from GOED member Tharos. Visit this page to see more examples of other testimonials.
Solutions Needed
GOED is offering connections for companies looking for omega-3 related solutions or partners. If you want to include an anonymous request, please contactAshley Becnel.
(New) A Chinese company is looking for 1 mT of any type of crude oil. [Posted 6/23/2025]
The program has been announced for the upcoming Food Matters Live event, which takes place in Rotterdam, The Netherlands, on September 23-24. The event features ingredient innovation showcases and expert insights for the product development community.
Note: GOED will not attend all listed industry events.
To suggest industry events for fellow GOED members, email Vicky Lin.
New Products
GOED member Maruha Nichiro will launch its first frozen dog food through subsidiary AIXIA on July 1, marking its entry into the frozen pet food market.
MegaFood, sister company to GOED member Pharmavite, launched three new supplements, including Omega-3 Fish Oil with 2,000mg fish oil concentrate (1,200mg EPA and DHA) per serving to support brain, heart, eye, joint and immune health.
Pet food brand Royal Canin launched its Fresh Health Nutrition dog food line. The Fresh Health Nutrition Puppy formula features EPA and DHA from fish oil to support brain development.
Pet nutrition brand Full Moon Pet introduced its new dog food line, Pure Protein. In addition to proteins, the dog food contains fish oil and vitamins to support immune health.
China’s middle class is projected to exceed 250 million by 2030, driving increased demand for premium imported seafood, according to the Norwegian Seafood Council.
ConsumerLab.com, a publisher of independent health and nutrition product test results, has added a comparison of omega-3 blood tests in the ConsumerTips section of its fish oil supplements review.
GOED member Marine Stewardship Council's (MSC) 2025 Small Pelagic Yearbook reports that the US Gulf of Mexico menhaden fishery, which contributes to many omega-3 pet food ingredients, has made significant progress on its Endangered, Threatened or Protected species management program.
Emerging anti-greenwashing regulations in the EU are having ripple effects in the way brands can frame or market their sustainability certifications, including the MSC "Blue Check" label used on seafood and supplement products.
MSC will invest US$6.4 million (€5.6 million) in its Ocean Stewardship Fund by 2030. The fund’s main goal is to end overfishing, but it also supports a wide variety of initiatives that make fisheries more sustainable.
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