Mineral oils – what do we know about the limits for the mineral oils in the EU?


Mineral oils are mixtures of liquid hydrocarbons containing MOAH extended aromatic rings and MOSH extended aliphatic and cyclic chains. The entire group can be called mineral oils hydrocarbons MOH. Mineral oils accumulate in many internal organs and can lead to damage to the liver, heart valve and lymph nodes. They are also suspected to be genotoxic carcinogens and therefore increase the risk of cancer. Over several years of MOH research they have been detected in many food products.

The first identified source of MOH food contamination was cardboard packaging printed with inks containing MOH. Likewise, oils and lubricants used in machinery may contain a fraction of MOAH. Other sources of contamination may include water used for agricultural watering and livestock watering contaminated with petroleum products. For now, cardboard packaging and cardboard liners containing recycled paper can still be a potential source of MOH. For this reason, regulatory enforcing measures for packaging are heading in this direction.



The most popular document for paper and board packaging manufacturers regarding the content and migration of MOAH is the draft of the German Mineral Oil Ordinance dated 14.8.2020 announced by the German Federal Ministry of Food and Agriculture (BMEL). Previous drafts contained limits on the content of MOSH and MOAH, but this draft has not been taken forward because the MOH content in recycled paper products and corrugated board products has proved to be too high. In the next version of the project draft, limits on MOSH and MOAH migration were given. The most recent version refers only to the migration of MOAH with chain lengths C16-C35.

  • 0.5 mg/kg in food
  • 0.15 mg/kg in food simulant

At the same time the BFR XXXVI food paper requirements alone include a migration limit for paraffinic, naphthenic-type hydrocarbon solvents with chain lengths of C10 to C20 at:

  • 12 mg/kg food for C10-C16
  • 4 mg/kg food for C16-C20

On 13 April 2022 The French Ordinance was introduced defining the substances contained in mineral oils whose use is prohibited in packaging and printed material distributed to the public.  The aim of this regulation is mainly to reduce the presence of MOH in paper and cardboard going to recycling and thus to improve the quality and increase the quantity of recycled materials.  The regulation took effect from 1 January 2023.

While formally the limits apply to the content in inks used for printing packaging, also finished products can be tested implicitly.

  • 1% MOSH C16 – C35
  • 0.1% MOSH C16 – C35 from 01.01.2025
  • 0.1% MOAH C1 – C7 aromatic ring numbers
  • 1 mg/kg MOAH C3 – C7 aromatic ring numbers from 01.01.2025

In 2017 The European Commission (EC) adopted the EU Recommendation 2017/84 on the monitoring of MOH in food and food contact materials. Food contact materials are all materials intended to come into contact with food including packaging and containers.

On 17 May 2022 The Standing Committee on Plants, Animals, Food and Feed has issued a recommendation on the maximum acceptable content of MOAH in food.

By all accounts, these values are similar or higher than the migration limits passed in the German draft regulations.

≤ 4% fat – 0.5 mg/kg MOAH

> 4% fat – 1 mg/kg MOAH

Fatty foods – 2 mg/kg MOAH


The table below compiles the requirements for MOH migration limits discussed above.

Project German

Recommendation BFR XXXVI

Regulations French

Committee Recommendation

MOAH C16-C35 0,5 mg/kg

lub 0,15 mg/kg

12 mg/kg C10-C16

4 mg/kg C16-C20


1% MOSH C16 – C35

0,1% MOSH C16 – C35

0,1% MOAH C1 – C7

1 mg/kg MOAH C3 – C7


≤ 4% fat 0,5 mg/kg MOAH

> 4% fat 1 mg/kg MOAH

Fatty Food 2 mg/kg MOAH


Due to the increasing demands of the EU and our customers, the J.S Hamilton Poland Accredited Laboratory Services offers a wide range of testing for migration and mineral oil content in different matrices.

If you have any questions or concerns, the J.S. Hamilton Experts remain at your disposal.

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