DRAFT

German Mineral Oil Ordinance

Summary Sector reactions

Jan CardonAdvisor ECMA

Draft Mineral Oil Ordinance Germany Summary based on FFI circular letter 22/05.

• First draft : 5 May 2011

Second draft : 16 May 2013

• No measure on MOSH included.

Analytical difficulty to split between MOSH

(Mineral Oil Saturated Hydrocarbons) and POSH (Polyolefin Oligomeric Saturated Hydrocarbons) from plastics.

• The second draft of the Ordinance covers only MOAH (Mineral Oil Aromatic

Hydrocarbons) with chain lengths ranging from C10 to C25.

No detailed definition of MOAH given.

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According to the EFSA opinion (June 2012) certain

substances in this fraction may be mutagenic and

carcinogenic.

• When mineral oils are migrating from paper and

board packaging there is an indicative 80/20 split between

MOSH and MOAH. By regulating MOAH the measure restricts indirectly

also the MOSH migration.

• MOAH substances should not migrate from packaging made of recycled

fibres to the food.

Virgin fibre packaging is excluded.

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• No limit included.

In the first draft, migration limits of 0,6 and 0,15 mg into 1 kg of food were

mentioned for MOSH and MOAH.

Unclear where this is leading.

Discussion on analytical methods and the subjective interpretation ongoing.

• The text mentions how “with the currently available technology” in most

cases a barrier (separate bag or barrier layer on the board) is required, in

order to avoid the MOAH migration.

• Transport packaging

Corrugated boxes need to be labelled. “The user of the packaging

needs to make sure, MOAH (C10 - C25) is not migrating into the food.”

This labelling is mandatory unless a barrier is present or a risk assessment

demonstrates migration is excluded.

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• Application : 2 years after publication.

• Status : Draft 2

Industry federations invited to comment until the 25 June.

Risk the chain length range will be broadened to C10-C35.

Above C25 MOAH is only migrating in case of a wetting contact.

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Sector reaction (ECMA/CEPI/CITPA)

Sector has been seriously managing MO issue since 09/2010. (LM inks, risk assessments)

24 September 2010

www.ecma.orgPublic Affairs Product Safety Position noteECMA recommendation on the use of low migration inks for food packaging

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Further responsible step forward : elimination of those MOAH substances

indentified as carcinogenic in the EFSA scientific opinion (3-5 ring MOAH ...)

from the entire paper and board supply chain.

- Availability analytical methods ?- Many not harmful substances in MOAH fraction.

BfR Seminar 22-23 September 2011 K. Grob

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Final objective is public health : all sources should be taken in account.

(advent calendar outcome ...)

INFORMATION STATEMENT ON MIGRATION ISSUE GERMANY

30 November 2012.

…

Concerning the information published by “Stiftung Warentest” ECMA points out

that there are clear indications (also mentioned in the test article) that not only

the packaging could be hold responsible as possible source of contamination.

http://www.ecma.org/templates/mercury.asp?page_id=2088

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26 11 2012

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Harmonised EU approach required.

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France & Belgium BPA …EFSA should be mandated by the Member States.

(p. 5-6)

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