Mineral oil: New regulations planned for recycled paper in contact with food
Thomas Reiner | 17.09.2020
The German Federal Ministry of Food and Agriculture (BMEL) is planning to introduce a regulation on the use of functional barriers in food contact materials containing recycled paper. The barriers should prevent the migration of mineral oil aromatic hydrocarbons (MOAH).
The plan for the new regulation is based on the European Commission’s averaging of 17 August 2020. According to it, the BMEL has announced an updated version of the 22nd Ordinance amending the country’s consumer goods ordinance on the use of recycled paper in the manufacture of food contact materials (FCM – Food Contact Material).
Mineral oil hydrocarbons, including MOAH, are generally obtained from crude oil and may consist of mixtures of thousands of different molecules. MOAH mixtures have mutagenic and carcinogenic properties. When present in food, they therefore pose a risk to human health. Scientific studies and test campaigns have shown in the past that the levels of saturated petroleum hydrocarbons (MOSH) and MOAH in food are often above 2 and 0.5 mg/kg of food respectively.
Manufacturers will only be granted an exemption from the planned BMEL regulation if they can prove that the migration of MOAH does not exceed the limit of 0.5 mg MOAH/kg food or 0.15 mg MOAH/kg food simulant even without a functional barrier.
Regulations are undoubtedly important. And the planned regulation addresses an undoubtedly important issue. Unfortunately, however, it has come about without a co-ordinated dialogue with industry. As a result, the regulatory proposal lacks the greatest source of technical expertise and know-how.
At the same time, industry is deprived of the opportunity to help shape legislation and regulation. This is a major shortcoming. This will not change – until companies learn to communicate together. Fragmented communication of the kind that currently prevails, in which everyone speaks only for themselves, is powerless and will remain without consequences.
Only communication by the industry as a whole can become the key to becoming not just a recipient of information in the legislation of the future, but an important partner in dialogue.
