GOED Submits Letter to European Commission Regarding Latest MOH Proposal
On July 3, 2025, GOED submitted a letter to the European Commission (EC) regarding the proposed regulation of mineral oil hydrocarbons (MOH). The letter was in response to documents the EC issued with proposals to regulate MOH in the European Union and included multiple suggestions and requests for clarification with respect to EPA/DHA omega-3 oils.
Our letter incorporates feedback from members of the Technical and Regulatory Affairs Committees and incorporates learnings from previous discussions with members and the GOED board, as well as recent occurrence data provided by members. In summary, GOED raised six main points:
Reinstating the name of the applicable category 5.5.2.5 as “Fish oils and oils from other marine organisms, and algae” rather than “Oils produced from fishery products and algae.”
Setting a customized higher Maximum Level (ML) for crude unrefined EPA/DHA omega-3 oils because these oils will be refined prior to consumption. It appears the EC will implement the same ML for all edible oils independently of their level of refining. Since refining of fish oils is necessary to partially mitigate the levels of apparent MOSH and MOAH, we have suggested a slightly higher ML of 15 mg/kg for crude unrefined oils destined to be refined.
Creating a category for ingredient oil blends of category 5.5.2.5 and vegetable oils. For blends of oils of different origin that are handled as ingredients, there is no current classification in the draft regulation.
Including the handling of measurement uncertainty in SANTE PLAN 2023 2726 Rev.6. While we believe the handling of measurement uncertainty will be included in Regulation EC 333/2007 if the regulation is adopted, this was not included in SANTE PLAN 2023 2726 Rev.6. We have asked for confirmation in writing since it is often critical to be able to apply the measurement uncertainty to be in compliance with the MOAH regulation.
Requesting European Commission guidance on the need for a laboratory proficiency program for EPA/DHA omega-3 oils. Since the submission of GOED’s letter last year to the EC, the interlaboratory variability in reported MOSH and MOAH testing values remains unacceptably high and the only way to know which third-party laboratories are accurate is to have a laboratory proficiency program in place for the relevant products, which does not currently exist for EPA/DHA omega-3 oils.
Recognition of limitations in the analytical testing and confirmatory analyses of EPA/DHA omega-3 oils because of inevitable matrix interference. Matrix interference in the analytical methods is an important issue inherent to specific food groups, including omega-3 oils. We have asked the EC for guidance after pointing out specific challenges in the omega-3 sector.
GOED would like to thank everybody who has provided input. GOED has not yet received a reply from the EC and will report any further developments to members. GOED last reported on MOH in the June 23 Current and June 12 News Alert.
GOED Announces Special Achievement Program Awardees
GOED is pleased to announce the awardees of the 2025-2026 Special Achievement Program, the second year that this program is operational in recognizing third-party laboratories that are highly proficient in quantifying EPA and DHA in omega-3 oils. This year two laboratories have met the highly stringent criteria that are required by the program. The laboratories are GOED members Eurofins Nutrition Analysis Center and KD LabService. GOED would like to congratulate both laboratories for achieving this recognition.
Information about the methods these laboratories use and their contact information, as well as more details about the criteria of the Special Achievement Program, can be found here.
GOED previously reported on the Special Achievement Program on June 23, 2025.
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
India to Submit Codex Proposal for New Work on Food Supplements
GOED has learned that at the recent Codex Committee on Contaminants in Food (CCCF), India reaffirmed its intention to pursue new international standards for food supplements and will submit a proposal for new work to the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU) to be discussed at its next meeting in 2026 (date not yet announced). This proposal was originally presented at the last meeting of the Codex Alimentarius Commission (CAC), and at that time, CAC advised India to submit the new work proposal to CCNFSDU.
Given that India is discussing the transfer of regulatory authority of nutraceuticals to the Central Drugs Standard Control Organization (CDSCO), which would translate to the implementation of tighter regulations, the proposal for new work is a disconnect. GOED will continue to monitor the present situation and report back to the membership with any relevant updates.
Join the Discussion on GOED’s Omega-3 LCA White Paper
As noted in the June 30 GOED Current, GOED has commissioned a new white paper on how to recognize and conduct fair, comprehensive life cycle assessments in the omega-3 category.
This Wednesday’s Sustainability Committee call [click here for your time zone] will include speakers from EcoEngineers/LRQA, the company GOED has retained to research and write this advice, as well as GOED member Austral Group, who recently published its own LCA. Click here and select the Sustainability Committee and “Attend as a guest” if you’d like to join this call.
We also want to ensure that the right industry stakeholders are shaping this document. If your company has sought professional advice on conducting an LCA, conducted an LCA but not released it, or published an LCA, we would love to hear from you via this form.
Production & Supply Chain
GOED member Maruha Nichiro has set up a Southeast Asia regional headquarters in Thailand to oversee its operations across Asia and Oceania, excluding Japan, South Korea and China.
The Joint FAO/WHO Expert Committee on Food Additives (JECFA) 100th meeting (Safety evaluation of certain food additives) was held last month and the summary and conclusions have been published. As anticipated, rosemary extract, which is sometimes used as an antioxidant in omega-3 oils, was discussed and an acceptable daily intake (ADI) of 0–0.6 mg/kg bodyweight (bw) (expressed as carnosic acid and carnosol) per day was established. This replaces the temporary ADI of 0–0.3 mg/kg bw per day. The establishment of an ADI for rosemary extract means that it is one step closer to being added to the General Standard for Food Additives (CXS 192-1995) for use in fish oils per the Standard for Fish Oils (CXS 329-2017). Rosemary extract will be discussed further at the next Codex Committee on Food Additives (CCFA) in April 2026.
The US Food and Drug Administration (FDA) has released its 2025 Human Foods Program Guidance Agenda, highlighting priorities for completion in 2025, including “New Dietary Ingredient Notifications and Related Issues: Identity, and Safety Information About the NDI: Guidance for Industry.” It’s worth noting that Cara Welch, PhD, Director of the FDA’s Office of Dietary Supplement Programs (ODSP), said that her group will most likely have to find 10 older regulations to eliminate before it can proceed with the new guidance. See NDI process caught in Trump’s war on regulations for more information.
Since GOED’s last commentary on new dietary ingredient notifications (NDIN) in the 4 March 2024 GOED Current, the FDA released a draft guidance for the industry entitled “New Dietary Ingredient Notification Master Files for Dietary Supplements.” This draft guidance responded to the dietary supplement industry’s requests for specific guidance on recommendations about Master Files for NDINs.
As part of the US administration’s focus on American manufacturing, the US Federal Trade Commission (FTC) sent warning letters to four companies who claim their consumer goods are of US origin, reminding them to comply with the FTC’s “Made in USA” requirements. Additionally, the FTC sent letters to Amazon and Walmart regarding third-party sellers who appear to be making deceptive “Made in USA” claims about their products on those online marketplaces. While none of the warning letters went to dietary supplement companies, the requirements are the same.
GOED member Corbion has received regulatory approvals from China’s General Administration of Customs (GACC), allowing its algae-based omega-3 DHA products, AlgaPrime DHA and AlgaVia DHA, to enter China’s human and animal nutrition markets.
As part of the “Make America Healthy Again” focus, US states Louisiana and Texas will require physicians to complete continuing medical education (CME) courses in nutrition for license renewal.
Australia has enacted new seafood labeling laws requiring all foodservice outlets to follow the AIM model used in grocery stores, labeling products as Australian (A), Imported (I), or Mixed Origin (M).
GOED member Brudy Technology has published an updated systematic review on the therapeutic benefits of topical omega-3s in skin diseases and cosmetics.
GOED member Nestlé Health Science has published the article, “The Importance of Lipids for Neurodevelopment in Low- and Middle-Income Countries” in Frontiers in Nutrition, highlighting the roles of EPA and DHA.
GOED offers connections for companies looking for omega-3 related solutions or partners. If you want to include an anonymous request, please contact Ashley Becnel.
(New) A company is looking for 300-400 tons of fish oil and 500-600 tons of fish meal every month. [Posted 7/14/2025]
Pet nutrition company Redbarn has expanded its Air Dried Powerfood line with a new formula for cats, featuring omega-3s from New Zealand green-lipped mussels and salmon oil to support joint, skin, cognitive and heart health.
To celebrate 170 years globally and 10 years in Romania, GOED member Orkla’s Möller's brand has launched its national “Catch the Golden Fish” campaign, giving customers the chance to win one of 170 gold fish-shaped pendants. Möller’s has also released a new passion fruit-flavored omega-3 product.
GOED member Marine Stewardship Council (MSC) has opened a second office in China. The new office is located in Qianhai, Shenzhen, which has been seeking to develop a more robust tuna industry.
The Best Aquaculture Practices (BAP) certification, run by the Global Seafood Alliance, has seen a sharp rise in applications from seafood firms serving China’s domestic market, growing from 3% to 50% of new applications in five years.
Phytolipid Technologies, a Tokyo University of Science spin-off, raised ¥220 million (US$1.4 million) in seed funding to build a Nannochloropsis algae cultivation facility on Japan’s Seto Inland Sea coast. The company aims to reduce CO₂ emissions through advanced plant- and algae-based lipid production.
GOED member Fermentalg reported €7.6 million (US$8.8 million) in sales in the first half of 2025, up 20% from 2024 and 57% above the five-year average. Growth was driven by its Origins range, with strong demand in Europe (over 80% of sales), and expansion into pet food, infant nutrition and aquaculture.
July presentation: EcoEngineers/LRQA and GOED member Austral Group, which recently published its life cycle assessment (LCA), will discuss how to conduct fair and comprehensive LCAs in the omega-3 sector.
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