1. DRAFT German Mineral Oil Ordinance
Summary
Sector reactions
Jan Cardon
Advisor ECMA

2. No measure on MOSH included.
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. 2
BPIF Cartons 18 June Jan Cardon ECMA

3. 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. 3
BPIF Cartons 18 June Jan Cardon ECMA

4. mentioned for MOSH and MOAH. Unclear where this is leading.
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. 4
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5. 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. 5
BPIF Cartons 18 June Jan Cardon ECMA

6. Sector reaction (ECMA/CEPI/CITPA)
Sector has been seriously managing MO issue since 09/2010. (LM inks, risk
assessments)
24 September 2010
Public Affairs Product Safety Position note
ECMA recommendation on the use of low migration inks for food packaging 6
BPIF Cartons 18 June Jan Cardon ECMA

7. Availability analytical methods ? Many not harmful substances in
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 7
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8. (advent calendar outcome ...)
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. 8
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9. 9
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10. Harmonised EU approach required.10
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11. EFSA should be mandated by the Member States.
(p. 5-6)
France & Belgium BPA …
EFSA should be mandated by the Member States. 11
BPIF Cartons 18 June Jan Cardon ECMA