MOSH and MOAH testing of food and food contact materials – how to ensure safety and compliance?

Reacting to concerns about the adverse health effects of mineral oil aromatic hydrocarbons (MOAH), the EU Standing Committee on Plants, Animals, Food and Feed (SC PAFF) published a report limiting their acceptable concentrations in food in the spring of 2022.¹ The limits outlined in the report took effect immediately, and dozens of products have since been withdrawn or recalled from the market for containing excessive amounts of MOAH.²

In May 2026, SC PAFF voted in favour of a regulation that will officially introduce maximum levels for MOAH as part of EU food contaminant legislation from 1 January 2027.³ A recommendation to monitor the levels of MOAH and mineral oil saturated hydrocarbons (MOSH), another group of potentially harmful mineral oil compounds, was also endorsed at the same time. While exceeding the indicative limits specified for MOSH in the recommendation will not automatically result in product withdrawals, companies are strongly advised to investigate the causes of contamination and apply appropriate mitigation measures.⁴

As transfer from food contact materials (FCMs) is one of the main sources of mineral oil contamination, laboratory tests should be performed to measure the migration of MOSH and MOAH from high-risk materials, such as recycled paper and board. The compounds can also be analyzed directly from food products.

Measurlabs is included in the European Reference Laboratory for Processing Contaminants (EURL-PC) list of laboratories that can detect MOAH at concentrations consistent with the current maximum limits.⁵ This makes us well-equipped to provide the required testing to evaluate products' compliance with EU MOAH regulations.

What are MOAH and MOSH, and what are the concerns?

Mineral oil hydrocarbons (MOH) are chemical compounds derived mainly from crude oil but also produced synthetically from coal, natural gas, and biomass. Falling under the umbrella of MOH, MOAH and MOSH are specific types of hydrocarbon compounds that have been linked to detrimental health effects. 

In the case of MOAH, the European Food Safety Authority (EFSA) has identified compounds with at least three aromatic rings as genotoxic and carcinogenic. While MOSH compounds have not been found to raise similarly acute health concerns, they do accumulate in the liver, spleen, and other tissues. The long-term effects of MOSH accumulation have not been studied, and EFSA considers them to remain uncertain.⁶

Due to the higher toxicological risks, EU regulations and recommendations have thus far been directed primarily at MOAH. However, as continued MOSH accumulation might lead to harmful effects, the EU is also planning to introduce monitoring requirements for MOSH.

What are the EU regulations on MOAH and MOSH?

General EU enforcement limits for MOAH in food were established in SC PAFF summary reports from April and October 2022.⁷ The levels are set to match the limits of quantification (LOQ) with currently available measurement techniques, and they vary depending on the fat content of the food: 

• 0.5 mg/kg for dry foods with a low fat/oil content (≤ 4% fat/oil)

• 1 mg/kg for foods with a higher fat/oil content (> 4% fat/oil, ≤50% fat/oil)

• 2 mg/kg for fats and oils (>50% fat/oil)

Limits specified in the Regulation that will formally incorporate maximum MOAH levels into Regulation (EU) 2023/915 on food contaminants from 1st January 2027 are, in some cases, higher than the above general limits. In such cases, the limits in the new Regulation take precedence over the general limits from 13 May 2026 for compliance assessment purposes.⁸ Some of the food categories to which higher limits apply are listed in Table 1.

Indicative threshold levels for MOSH, ranging from 1 to 50 mg/kg depending on the food category, are specified in a Commission Recommendation on monitoring mineral oil hydrocarbons in food. Exceeding the indicative levels will not lead to immediate product withdrawals, but rather a strong recommendation to investigate and address the root causes of contamination.⁹

There have also been discussions about setting a limit for total MOAH migration in Regulation (EU) No 10/2011 on plastic food contact materials, but no timeline has been set thus far.¹⁰

Which products should be tested?

The maximum and indicative levels apply to the total amounts of MOSH and MOAH in food regardless of the source, which means that testing is needed across the value chain.

In terms of finished products, high-risk foods that have been found to contain MOSH and MOAH include vegetable oils, stock cubes, nuts and seeds, cereals, baby food, chocolate products, and dairy. In the food contact material category, the likelihood of MOSH or MOAH being present is higher when the material contains recycled fibers, printing inks, or waxes. Ingredients used in the production process, such as lubricants, greases, and sealants, can also lead to contamination and therefore warrant testing.

How to test for MOSH and MOAH?

General EU guidelines for MOSH and MOAH testing are provided in a Joint Research Centre (JRC) 2023 guidance report, which outlines guidance on sampling and minimum requirements for analytical methods.¹¹

MOH analysis is usually performed using LC-GC-FID (liquid and gas chromatography with flame ionization detection). Due to structural similarities, MOH cannot be separated into individual substances using the technique, but MOSH and MOAH components can be distinguished from one another. Further analysis with two-dimensional gas chromatography may be required to confirm the MOAH concentration in cases where naturally occurring substances interfere with the analysis.

Avoiding contamination at all stages of sampling and analysis is crucial, as mineral oils may unintentionally end up in the sample material from sources such as plastic bags and cosmetics. Due to the low detection limit and high risk of contamination, MOSH and MOAH testing requires a high level of expertise from the testing laboratory.

Measurlabs' solutions for MOSH and MOAH testing

Measurlabs provides analytical services for the determination of mineral oil hydrocarbons across the full manufacturing chain, from production aids and raw materials to finished food contact materials and food products. Further technical details and indicative pricing are available in the following service descriptions:

• MOSH/POSH and MOAH in food and supplements

• Migration of MOSH/POSH and MOAH from food contact materials

• MOSH/POSH and MOAH in non-food samples (e.g., printing inks, carbon black, oils, waxes)

See also our example test report for MOSH/POSH & MOAH migration from food contact materials.

For further information or a quotation tailored to specific testing needs, please use the contact form below.