INFORM March 2025

SAFER PRODUCTS

inform March 2025, Vol. 36 (3) • 23

palm oil products. To address this issue, the proposed solution is to switch to food-grade lubricants for processing equipment. However, these lubricants are 8 to 10 times more expen sive than traditional petroleum-based or synthetic lubricants, which could impact producers’ profit margins. Although the European Union has not yet established binding regulations for MOH in food, many buyers have imposed their own limits on acceptable levels. Contaminants such as MOSH and MOAH, known for their carcinogenic poten tial, have led Fast-Moving Consumer Goods (FMCG) and multi national companies to tighten supply chain controls. Producers are also addressing other contaminants, such as GE and 3-MCPDE, to ensure compliance with EU safety standards and maintain consumer trust. In Europe, the consumer protection NGO, Foodwatch, has been actively raising awareness about MOH contami nation in food products, particularly in edible oils and pro cessed foods. Through independent testing and analysis, Foodwatch publishes its findings to inform consumers and apply pressure on both food manufacturers and regulatory agencies to act. For instance, Foodwatch analysed 120 food products packaged in cardboard across Germany, France, and the Netherlands. The findings revealed that 43 percent of the products were contaminated with potentially carcinogenic and mutagenic mineral oil components, with most contaminants migrating from recycled packaging materials. REGULATORY DEVELOPMENTS In response to the toxicological risks posed by MOH, the EU introduced stricter guidelines, in April 2022, for the permissi ble levels of MOAH in food. To ensure consistent enforcement across the EU, Member States agreed to withdraw or recall products from the market if MOAH concentrations exceed the following limits of quantification (LOQ): • 0.5 mg/kg for dry foods with low fat content (≤ 4% fat) • 1 mg/kg for foods with moderate fat content (4-50% fat) • 2 mg/kg for oils and fats (> 50% fat) Analysis and sampling are done according to the provi sions of Regulation (EC) No 333/2007.

SOURCES OF MOH CONTAMINATION IN THE PALM OIL SUPPLY CHAIN

With the establishment of these regulations, the edible oil industry focused on minimizing MOH contamination. This con tamination can occur throughout the supply chain, making it a complex issue with multiple potential sources. It is there fore crucial to identify these sources. While MOH primarily originates from machinery lubricants, it can also enter food through environmental contamination, release agents, pro cessing aids, food or feed additives, and migration from food contact materials. The palm oil supply chain consists of various unit opera tions. Initial investigations indicate significant MOH contami nation occurring during estate activities, mill processing, raw materials transportation, and packaging within the supply chain. MOH contamination is classified into primary and sec ondary sources. Primary contamination results from direct leakage of grease and lubricant oils during processing, while

Raw Materials

Intermediate and final projects

Consumer

Cultivation Agriculture practice, Harvest

Storage, Trade, Transport

Packaging, Storage, Distribution

Contamination points:

Processing stages

Food Trade

Primary: Leakages of grease and lubricant oils during processing. Secondary: contamination from processing material chemicals. Migration: Packaging materials.

Exhaust gasses from vehicles etc. Trash/Debris? Cross Contamination

Illustration of contamination points throughout the supply chain, from raw materials to the final food trade, affecting consumers.

Hierarchy of Controls

Physically remove

Most effective

Elimination