1. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Health & Consumers Directorate General Update on contaminants legislation Advisory group on fish and Aquaculture 23 March 2010

2. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Contents Issues of relevance for fish and fishery products PCBs and dioxins Heavy metals (cadmium, arsenic, lead) Polycyclic aromatic hydrocarbons (PAH)

3. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission PCBs and dioxins Setting levels for non-dioxin like PCBs in food sum of 6 indicator PCBs (PCB 28, 52, 101, 138,153,180) level under discussions for fish: 75 ng/g fresh weight separate level for eel, river fish (?), exemption Baltic fish (?) Consultation stakeholders July 2009.

4. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission PCBs and dioxins Reviewing levels of dioxins and dioxin- like PCBs TEF 1998  TEF 2005 levels TEF 2005 currently under discussion: For dioxins (PCDD/F) alone fish: 3 pg/g fresh weight Eel: 3,5 pg/g fresh weight Marine oil: 1,75 pg/g fat For the sum of dioxins and dioxin-like PCBs Fish: 6 pg/g fresh weight Eel: 10 pg/g fresh weight Marine oil: 6/7,5 pg/g fat

5. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission PCBs and dioxins Simultaneously, discussions are ongoing for dioxins and PCBs in feed sector (fish meal, fish oil and fish feed) setting levels for non dioxin-like PCBs reviewing existing maximum levels by using TEF 2005 values

6. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Heavy metals Cadmium EFSA opinion adopted January 2009 Follow up discussions ongoing within Expert Committee of Member States Arsenic: EFSA opinion adopted October 2009 Follow up discussion to start soon Lead: EFSA opinion adopted March 2010, not yet published

7. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Cadmium- EFSA conclusions Tolerable Weekly Intake (TWI) of 2.5 µg/kg bodyweight (previously: 7 µg/kg b.w.) Vegetarians, children, smokers and people living in highly contaminated areas may exceed the TWI by about 2- fold. Cadmium exposure should be reduced

8. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Follow up on EFSA Opinion - Cadmium Review of current MLs in the light of EFSA opinion – still at initial stage Fish and seafood not major contributors to exposure (mainly vegetables and cereals) But fish/seafood to be considered within the review, e.g. list of exemptions of default limit of 0.05 mg/kg (14 species)

9. Cadmium- Fishery products- Data needs I Fish species Data needs- priorities Bonito (sarda sarda)++ Common two banded seabream (Diplodus vulgaris) ++ Eel (anguila anguilla)++ Grey mullet (Mugil labrosus labrosus) ++ Horse mackerel (Trachurus species) ++

10. Cadmium- Fishery products- Data needs II Fish species Data needs- priorities Louvar (Luvarus mperialis)++ Mackerel (Scomber species)++ Sardine (Sardina pilachardus)+ Sardinops (Sardinops species)++ Wedge sole (Dicologoglossa cuneata) ++

11. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Cadmium- Fishery products-Data needs III Fish species Data needs- priorities Bullet tuna (Auxis spp.)+ Anchovy (Engraulis spp.)+/- Swordfish (Xiphias gladius)+/- Tuna (Thunnus, Euthynnus spp., Katsuwonus pelamis) -

12. Arsenic – EFSA conclusions Inorganic arsenic is the most toxic form. Organic forms less toxic, but data on toxicity and occurrence lacking JECFA PTWI of 15 µg/kg b.w. for inorganic arsenic no longer appropriate. Margin of exposure approach (MOE) was used. Estimated dietary exposures for inorganic arsenic for average and high adult consumers is within the range of the benchmark dose (BMDL01 values); therefore there is little or no margin of exposure Exposure for children can be 2-3 fold that of adults

13. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Arsenic – EFSA conclusions Main conclusion: Dietary exposure to inorganic arsenic should be reduced. Total arsenic levels in fish and seafood are high, but the relative proportion of inorganic arsenic in fish is small and tends to decrease as total arsenic increases Fixed values for inorganic arsenic in fish were assumed (0.03 mg/kg in fish and 0.1 mg/kg in seafood)

14. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Arsenic – Follow up Questions to be discussed in Expert group: Need for MLs on arsenic? If so, on basis of total or inorganic As? For which food groups? Need for improvement of analytical methods and enhance laboratory performance?

15. Lead – EFSA Conclusions Opinion adopted on 19 March 2010 Publication expected for end of April 2010

16. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission PAH – EFSA conclusions Benzo(a)pyrene alone is not a suitable indicator for the occurrence of PAH in food A system of PAH4 or PAH8 would be more appropriate, with PAH8 not providing much added value compared to PAH4 Highest contributors to human exposure: cereals& cereal products, seafood, vegetables Margin of exposure for average consumers of low concern; for high consumers close to or less than 10,000  potential concern

17. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Review of PAH MLs Benzo(a)pyrene MLs will be maintained but reviewed with new occurrence data Sum ML for PAH4 will be introduced (benzo(a)pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene) Review of analytical performance criteria (Regulation (EC) No. 333/2007): current proposal is to use the performance criteria for BaP

18. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Specific issues on PAH in fish/seafood Sprats in oil: request from Latvia for higher than current ML Smoked meat and fish, bivalve molluscs: are lower than current MLs possible/appropriate? Fresh and smoked bivalves: confirm that no difference in PAH levels Crustaceans, cephalopods other than smoked Need to maintain ML? No data and apparently low levels Do they metabolise PAH as fresh fish does (therefore low levels expected?)

19. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Data needs for PAH Smoked sprats Crustaceans, cephalopods other than smoked Bivalve molluscs, smoked and not smoked

20. This presentation expresses exclusively the author’s personal opinions and does not, in any case, bind the European Commission Contacts Frans.Verstraete@ec.europa.eu Almut.Bitterhof@ec.europa.eu Thank you for your attention!