* to be postponed to 01/01/2027
GOED is currently seeking confirmation on the discussions that were held about marine oils and food supplements. Also to be confirmed is the ML of 2 mg/kg for blends of oils of different origins.
Importantly, the meeting did lead to a decision that MOAH thresholds will apply to crude oils intended for refining (but not to what are called “intermediary products”). GOED will seek further information about what this means in practice for the importation of crude fish oil batches intended to be refined in the EU.
Regarding MOSH, no definitive position was found by the Expert Group and remains a point of discussion. It appears that the Indicative limit of 15 mg/kg (total MOSH) would remain.
Finally, a new stakeholder consultation will take place after the Member States agree on a final draft. GOED recommends that members participate in this consultation, if possible, through their national representatives or any European trade associations of which they are a member.
It is also worth mentioning that the European consumer organization FoodWatch recently published a press release contesting the discussed limit values. FoodWatch’s influence was one of the factors that kickstarted the original discussions about the need for setting regulations for mineral oil contamination of food in Europe. It is currently unclear to what extent the organization’s opinion will influence the current Member States’ discussions.
GOED last reported on the EU MOH proposed limits in the July 8, 2024 GOED Current and the MOH Resources webpage in the October 21 issue. For any questions, please reach out to Gerard Bannenberg or Harry Rice.