On March 22, 2021, testing provider SGS reported that the German authorities have notified the World Trade Organization (WTO) of their intent to restrict mineral oil aromatic hydrocarbons (MOAH) in food contact materials and articles made from recycled paper and board under the nation’s Consumer Goods Ordinance (Bedarfsgegenständeverordnung, BedGgstV).

The draft regulation attached to the WTO notification provides information such as a definition for waste paper pulp, functional barriers, and MOAH. Further, the document sets limits for MOAH migration to food (<0.5 mg/kg) and food simulant (<0.15 mg/kg) from food contact paper, paperboard, as well as cardboard made of recycled paper. The ordinance will come into effect three years after publication.

In February 2020, a review article written by scientists from the German Federal Institute for Risk Assessment (BfR) had revealed a lack of safety data available on MOAH and that these impurities should be minimized in food and its contaminating sources (FPF reported). In August 2020, the European Commission had announced a draft version of this notification and opened it for public comment (FPF reported).

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SGS (March 31, 2021). “Germany proposes to regulate MOAH in food contact recycled paper and board.”

The Federal Ministry of Food and Agriculture (March 15, 2021). “Draft of the Federal Ministry of Food and Agriculture.” (pdf)

WTO (March 22, 2021). “G/SPS/N/DEU/12.” (pdf)