Introduction
Mineral oil hydrocarbons (MOH) are chemical contaminants that can enter food through packaging materials, processing equipment, lubricants, recycled paperboard, processing aids and environmental sources. Their presence has become an important food-safety and export-compliance concern, particularly for manufacturers supplying products to the European Union (EU).
MOH are broadly divided into two groups: mineral oil saturated hydrocarbons (MOSH) and mineral oil aromatic hydrocarbons (MOAH). Although they are often assessed together, their chemical characteristics, toxicological concerns and regulatory implications differ.
In 2026, the EU’s regulatory work on MOAH is moving towards more harmonised maximum levels in food, alongside updated sampling, analytical and monitoring measures. Food manufacturers, ingredient suppliers, packaging producers and exporters should review their contaminant-control programmes and prepare for applicable requirements.
This article explains the distinction between MOAH and MOSH, the key EU regulatory developments, analytical considerations and practical steps businesses can take to manage contamination risks.
1. What Are MOAH and MOSH?
Mineral oil hydrocarbons are complex mixtures of hydrocarbons derived mainly from crude oil, although they may also originate from coal, natural gas and other sources.
Mineral Oil Saturated Hydrocarbons (MOSH)
MOSH consist primarily of saturated aliphatic and alicyclic hydrocarbons. They may enter food through mineral-oil-based lubricants, processing aids, packaging materials and other sources.
The European Food Safety Authority (EFSA) concluded in its 2023 risk assessment that current dietary exposure to MOSH did not raise a health concern across the assessed age groups. However, EFSA highlighted the importance of maintaining mitigation measures because exposure could increase if those measures were discontinued.
Mineral Oil Aromatic Hydrocarbons (MOAH)
MOAH contain aromatic hydrocarbon structures. Certain MOAH, particularly compounds with three or more aromatic rings, may be associated with genotoxicity and carcinogenicity.
EFSA’s 2023 assessment concluded that health concerns could not be excluded because of the potential presence of these compounds in food and gaps in the toxicological evidence for some MOAH groups.
For this reason, MOAH contamination has become a particular focus of EU risk-management and regulatory developments.
2. How Can MOAH and MOSH Enter Food?
Contamination can occur at several stages of the food supply chain. Identifying the source is essential because a positive analytical result does not automatically establish that packaging is responsible.
Common potential sources include:
- Food-contact packaging: Migration from paperboard, recycled fibre packaging, printing inks, adhesives and other packaging components.
- Processing and packaging equipment: Lubricants, hydraulic fluids and machinery maintenance materials.
- Processing aids: Mineral-oil-based release agents, dust binders and other substances used during production.
- Raw materials and ingredients: Contamination introduced before ingredients reach the manufacturing facility.
- Storage and transport: Contact with contaminated surfaces, packaging or handling equipment.
- Environmental sources: Contamination originating from the surrounding production or supply-chain environment.
Recycled paper and board packaging may require particular attention because mineral-oil residues can originate from printing inks and other materials in recovered paper. The actual risk depends on the packaging composition, barrier performance, food characteristics and storage conditions.
3. EU Regulatory Developments in 2026
The EU has been progressing towards a more harmonised approach to controlling MOAH in food. Three developments are particularly relevant to manufacturers and exporters.
3.1 Proposed maximum levels for MOAH in food
The European Commission’s 2026 regulatory programme includes a draft regulation to amend Regulation (EU) 2023/915 by establishing maximum levels for MOAH in specified food categories.
According to the Commission’s published regulatory update, Member States gave favourable support to the draft on 13 May 2026. At the time of this article’s preparation, the Commission’s online information indicated that adoption was targeted for October 2026, subject to scrutiny by the European Parliament and the Council.Important compliance point: A favourable committee vote or published draft is not, by itself, proof that a regulation has been formally adopted and entered into force. Food businesses should verify the final regulation, its publication in the Official Journal of the European Union, the applicable dates and the relevant food-category provisions before making a legal compliance determination.
The proposed framework uses food-category-specific maximum levels rather than one universal numerical limit for every food. Applicable limits and any transitional provisions must therefore be assessed against the exact product category and the final published legal text.3.2 Updated official sampling and analytical requirements
The Commission has also progressed a draft implementing regulation amending Regulation (EC) No 333/2007 concerning methods of sampling and analysis for official control of MOH in foodstuffs.
The draft received favourable support from Member States in May 2026, with adoption targeted for October 2026 in the Commission’s published update.For food businesses, this development reinforces the importance of analytical methods that are suitable for the relevant food matrix and capable of meeting the applicable performance and limit-of-quantification requirements.
Manufacturers should not assume that every laboratory method, sample-preparation procedure or reported result is automatically interchangeable for regulatory purposes.3.3 Updated monitoring recommendation
A further Commission Recommendation on monitoring mineral oil hydrocarbons in food was endorsed by Member States in May 2026, with adoption targeted for October 2026.
Monitoring supports the collection of data on contamination levels, helps identify affected commodities and assists investigations into contamination sources.
Businesses should review the final recommendation when published and determine whether their internal surveillance programmes need to be updated.
What these developments mean for food businesses
The direction of EU regulatory policy is towards more structured control of MOAH, supported by defined food-category requirements and stronger alignment of official sampling and analytical procedures.
Manufacturers and exporters should review product risks, confirm the applicable legal position and establish a documented plan for testing, investigation and corrective action.4. Key EU Legislation and Guidance
The principal regulatory and technical references relevant to MOAH/MOSH management include:
Regulation (EU) 2023/915 on maximum levels for certain contaminants in food: This regulation provides the EU framework for maximum levels of specified contaminants. The proposed MOAH amendments should be assessed against the final version once formally adopted.Commission Recommendation (EU) 2017/84: This recommendation established a framework for monitoring mineral oil hydrocarbons in food and materials and articles intended to come into contact with food.
Regulation (EC) No 333/2007: This regulation addresses methods of sampling and analysis for official control of certain contaminants in foodstuffs. Proposed amendments specifically addressing MOH should be checked for their final legal status.European Commission Joint Research Centre guidance: The guidance on sampling, analysis and data reporting supports monitoring of MOSH and MOAH in food and food-contact materials.
European Reference Laboratory for Processing Contaminants guidance: The guidance on analysis, interpretation and data reporting for MOSH and MOAH by comprehensive two-dimensional gas chromatography (GC×GC) supports consistent analytical interpretation. These documents serve different purposes. A recommendation or technical guidance document should not be treated as equivalent to a binding regulation. Businesses should determine which legal requirements apply to their products and destinations.5. MOAH/MOSH Testing: Analytical Approach and Requirements
Reliable MOAH/MOSH analysis requires appropriate sample preparation, separation, detection, quality control and interpretation. Food matrices differ significantly in composition, so the analytical strategy should be selected according to the product and the purpose of testing.
5.1 Gas chromatography-based analysis
Gas chromatography is central to the analytical determination of mineral oil hydrocarbon fractions. Depending on the method, laboratory equipment and required level of characterisation, approaches may include online or offline liquid chromatography clean-up followed by gas chromatography with flame ionisation detection (GC-FID).
GC×GC-based approaches can provide additional separation of complex hydrocarbon mixtures and support more detailed interpretation of MOSH and MOAH fractions.
The suitability of a method depends on the applicable regulatory requirements, matrix, expected contamination level, analytical performance and intended use of the result.
5.2 Sample preparation and matrix effects
Sample preparation is particularly important because food naturally contains complex mixtures of fats, oils, waxes, olefins and other compounds that may interfere with interpretation.
The laboratory should consider:
- The type and composition of the food matrix.
- Appropriate extraction and clean-up procedures.
- Potential interferences and analytical artefacts.
- Method performance and recovery.
- The required limit of quantification (LOQ).
- Quality-control samples and relevant proficiency-testing performance.
5.3 Reporting and interpretation
Analytical reports should clearly identify the tested sample, the analytical approach, the reported fractions and units, and the relevant LOQ. Any limitations affecting interpretation should be considered.
A detected MOH signal may require further assessment to distinguish relevant mineral-oil contamination from matrix-related interferences or other compounds that affect chromatographic interpretation. Where a result is being used for regulatory decision-making, the laboratory’s method should meet the applicable official-control requirements. The reporting and interpretation approach should also be consistent with the relevant technical guidance.6. Which Food Products Should Be Prioritised?
Risk-based testing is generally more effective than applying an identical monitoring frequency to every product.
The following product groups may warrant consideration depending on their ingredients, processing conditions, packaging and supply chain:| Product group | Potential areas of concern |
| Edible oils and fats | Raw-material contamination, processing equipment and storage |
| Cereals and cereal-based products | Processing aids, dust binders and packaging |
| Rice, pasta and dry foods | Packaging materials, storage and handling |
| Chocolate and confectionery | Packaging, fats and processing operations |
| Bakery products | Ingredients, machinery and packaging |
| Nuts and seeds | Raw-material handling, processing and packaging |
| Infant and young-child foods | Product-specific risk assessment and stringent contamination control |
| Foods packed in paperboard | Potential transfer from recycled fibre packaging and associated materials |
This table is a practical risk-screening guide, not a statement that all products in these categories are subject to identical legal limits. Applicable regulatory provisions must be confirmed for each food category.
7. MOAH/MOSH in Food Packaging: Migration and Source Investigation
Packaging is one potential source of mineral oil hydrocarbons, particularly where recycled paper and board or printing-related materials are involved.
However, finding MOAH or MOSH in food does not by itself prove migration from packaging. A source investigation should consider the entire production and distribution chain.A practical investigation may include:
- Test the food: Establish the presence and concentration of the relevant hydrocarbon fractions.
- Review the packaging: Assess paperboard, inks, adhesives, barriers and other relevant components.
- Evaluate processing sources: Review lubricants, release agents, equipment maintenance and handling practices.
- Review storage conditions: Consider storage duration, temperature and other conditions that could influence transfer or contamination.
- Compare relevant samples: Where technically appropriate, analyse the food, packaging and potential source materials using suitable, comparable methods.
- Implement corrective action: Address the identified source and verify whether the corrective measures are effective.
A functional barrier may reduce migration, but its effectiveness should be assessed for the specific packaging system and intended conditions of use. A general declaration or the presence of a barrier alone should not be treated as proof that mineral-oil migration cannot occur.
8. How Food Manufacturers Can Prepare for EU Compliance
Food manufacturers, packaging suppliers and exporters can strengthen their MOAH/MOSH control programmes through the following actions.
Step 1: Map potential contamination sources
Review raw materials, processing aids, lubricants, packaging, equipment and storage conditions. Document the potential sources relevant to each product.
Step 2: Conduct a product-specific risk assessment
Prioritise products according to ingredients, fat content, packaging type, shelf life, processing conditions, intended consumer group and export destination.
Step 3: Establish a risk-based testing programme
Select suitable samples and analytical methods according to the food matrix, the risk assessment and the applicable regulatory or customer requirements.
Step 4: Confirm analytical suitability
Before testing, clarify the required analytes or fractions, method performance, LOQ, reporting format and whether the results are intended for screening, supplier verification or regulatory assessment.
Step 5: Review packaging and supplier controls
Request relevant technical information from packaging suppliers, including material composition, recycled-content details where relevant, barrier information and measures to control mineral-oil contamination.
Step 6: Verify the final 2026 regulatory position
Check the final legal texts and applicable dates for the MOAH maximum-level regulation, official sampling and analytical requirements, and updated monitoring recommendation.
Step 7: Document corrective actions
Where contamination is detected, investigate the likely source, record the root-cause assessment, implement corrective measures and conduct follow-up testing where appropriate.
9. Common Mistakes to Avoid
Businesses should avoid the following errors when developing their MOAH/MOSH compliance programmes:
- Treating MOAH and MOSH as the same analytical or toxicological category.
- Assuming that a single numerical limit applies to every food.
- Treating a draft regulation as an adopted and applicable legal requirement.
- Using a method without confirming its suitability for the specific food matrix.
- Comparing results generated using materially different sample-preparation or analytical procedures.
- Assuming packaging is the source without investigating other possible contamination routes.
- Relying exclusively on supplier declarations without a risk-based verification programme.
- Interpreting a result below the LOQ as proof of absolute absence.
- Failing to review regulatory updates and transitional provisions before shipment.
10. How Eureka Supports MOAH/MOSH Testing and Food Safety
Eureka supports businesses seeking analytical information to strengthen food-safety programmes, investigate potential contamination and evaluate relevant compliance requirements.
Depending on the applicable testing scope and sample requirements, support may include:
- Food contaminant testing: Analytical support for selected food-safety parameters.
- Risk-based testing planning: Assistance in identifying appropriate testing priorities based on product type and intended use.
- Analytical result interpretation: Support in understanding reported results in the context of the selected method and its limitations.
- Packaging-related investigations: Testing support for evaluating potential contamination sources where the required analytical service is available.
- Compliance-oriented testing support: Assistance in aligning testing requirements with the applicable destination-market and customer expectations.
The appropriate testing plan depends on the food matrix, the required analytes, the applicable regulatory provisions and the available analytical scope. Customers should confirm method availability, reporting limits and intended use of results before sample submission.
Conclusion
MOAH/MOSH contamination remains an important consideration for food manufacturers and exporters, particularly where packaging, processing aids, machinery and storage conditions may contribute to contamination.
The EU’s 2026 regulatory developments signal a move towards more harmonised MOAH maximum levels and updated official sampling, analytical and monitoring arrangements. Businesses should distinguish proposed measures from formally adopted legislation, review the final requirements and strengthen source identification and risk-based testing programmes. A structured approach combining suitable analytical methods, supplier controls, packaging assessment and documented corrective action can help businesses manage contamination risks and prepare for applicable EU food-safety requirements.Frequently Asked Questions (FAQ)
1. What are MOAH and MOSH in food?
MOAH stands for mineral oil aromatic hydrocarbons, while MOSH stands for mineral oil saturated hydrocarbons. They are two broad groups of mineral oil hydrocarbons that may contaminate food through packaging, processing, lubricants, ingredients and environmental sources.
2. Why is MOAH a food-safety concern?
Certain MOAH, particularly compounds with three or more aromatic rings, may be associated with genotoxicity and carcinogenicity. EFSA has concluded that health concerns cannot be excluded based on the available evidence.
3. Are MOSH and MOAH subject to the same regulatory limits?
Not necessarily. Their risk assessments and regulatory treatment differ. Businesses should check the specific legal provisions applicable to the product and destination market rather than assuming that the same limit or control applies to both fractions.
4. What changed for MOAH/MOSH regulation in the EU in 2026?
The European Commission reported favourable Member State support in May 2026 for a draft regulation establishing maximum levels for MOAH in specified foods, a draft update to official sampling and analytical rules, and an updated monitoring recommendation. The final adoption and application dates should be verified in the official publications.
5. Which analytical techniques are used for MOAH/MOSH testing?
Gas chromatography-based approaches are commonly used. Depending on the method and purpose, analysis may involve GC-FID and, for additional separation and interpretation, GC×GC. The method must be suitable for the food matrix and the applicable requirements.
6. Can MOAH/MOSH migrate from food packaging?
Yes. Migration from certain food-contact materials, including some paper and board packaging systems, is a recognised potential source. However, other contamination routes must also be investigated before identifying the cause.
7. Which foods should be tested for MOAH/MOSH?
Testing priorities should be established through a risk assessment. Edible oils, cereals, dry foods, confectionery, nuts, packaged foods and infant foods may warrant consideration depending on their composition, processing and packaging.
8. Does a result below the LOQ mean the food is completely free of MOAH or MOSH?
No. A result below the limit of quantification means the substance or fraction was not quantified at or above that method’s stated LOQ under the test conditions. It does not establish absolute absence.
9. How should a food business respond to a positive result?
The business should verify the analytical result and its suitability for the intended decision, investigate potential sources, review relevant ingredients and packaging, implement corrective measures and conduct follow-up testing where appropriate.
10. What should exporters do before shipping food to the EU?
Exporters should identify the applicable food-category requirements, assess contamination risks, select suitable analytical methods, review packaging and supplier controls, and verify the final legal requirements and application dates before shipment.
Official References
- Regulation (EU) 2023/915 on maximum levels for certain contaminants in food
- Commission Recommendation (EU) 2017/84 on monitoring mineral oil hydrocarbons in food and food-contact materials
- Regulation (EC) No 333/2007 on methods of sampling and analysis for official control of certain contaminants in food
- European Commission – Mineral Oil Hydrocarbons (MOH) regulatory information
- European Food Safety Authority (EFSA) – Update of the Risk Assessment of Mineral Oil Hydrocarbons in Food (2023)
- European Commission Joint Research Centre – Guidance on Sampling, Analysis and Data Reporting for Monitoring Mineral Oil Hydrocarbons in Food and Food-Contact Materials
- European Commission — Food Contact Materials
- European Reference Laboratory for Processing Contaminants – Guidance on Analysis, Interpretation and Data Reporting for MOSH and MOAH by GC×GC
Regulatory note: EU food-contact requirements can differ according to material, intended use, food type and Member State provisions. Manufacturers and exporters should verify the latest consolidated legislation and applicable guidance before making compliance decisions.
