What is the issue?
Mineral Oils, as expressed by MOSH (Mineral Oil Saturated Hydrocarbons) and MOAH (Mineral Oil Aromatic Hydrocarbons), have been identified as a potential source of food contamination and can unintentionally enter food at various points in the supply chain. As an example, a potential source of mineral oil contamination in food is recycled paperboard used in food packaging.
What is happening?
Some MOSH/MOAH species may bioaccumulate or are considered carcinogenic or potentially mutagenic. As such, EU regulations limiting the MOSH/MOAH content of food packaging materials might be pursued.
What are resins?
HARRPA members are producers of hydrocarbon, rosin and terpene resins which are based on natural (bio based) and petrochemical raw materials. These resins represent a distinct class of amorphous products that are characterized by a high glass transition temperature in relation to their molecular weight. As such, they are different from oils, waxes or plasticizers.
Rosin, terpene and hydrocarbon resins have been safely used for decades including in food contact materials. A number of resins are also listed on the Plastics Regulation (EC 10/2011 and amendments) and/or have been approved for food contact use by regulating bodies across the globe.
What is the concern for the resin manufacturers?
The LC-GC-FID or 1D-GC analytical approach for MOSH/MOAH analysis as prescribed by the JRC does not sufficiently distinguish between mineral oils and other hydrocarbons in a similar molecular weight range, such as polymer oligomers, waxes and resins. This method creates false positive test results that leads to an undue negative impact on the use, for example, of resins in packaging hotmelt adhesives.
HARRPA has therefore worked with the Laboratory Lommatzsch & Säger to develop an improved analytical method (2D-GC) that can better distinguish between resin oligomers and MOSH/MOAH. Our findings have been shared in a transparent manner with industry, and EU & national authorities.
What does HARRPA propose?
As recommended by the JRC in their recently published guidance, HARRPA proposes that in cases of difficult samples and matrices, additional analytical techniques such as 2D-GC could be used.
What would this mean in practice?
2D-GC is more sophisticated in analyzing resins in food contact materials compared to the EU method. Because 2D-GC shows clusters of resins species that can be distinguished from mineral oil, these interferences can be subtracted from the reported test results. Because resins are not MOSH/MOAH, using the 2D-GC testing method to correctly identify them in food and food contact materials would ensure greater transparency for industry and final consumer.
What are our aims?
We are looking to improve stakeholder awareness of the difference between MOSH/MOAH and resins and how the distinction can be measured. HARRPA will continue to promote to EU national authorities and relevant laboratories that in addition to the 1D-GC method, the 2D-GC technique should be utilized to help ensure a correction for resin oligomers when analytical results are over a specific threshold.
Manufacturers commitment to safe use
HARRPA members are committed to meeting stringent regulatory safety expectations on their resin products and are committed to contribute to food safety. HARRPA has issued several guidance documents on the use of resins in the supply chain. HARRPA members can provide further information regarding safety of their respective resins.
HARRPA Statement on the JRC Guidance Document
HARRPA welcomes the “JRC guidance on sampling, analysis and data reporting for the monitoring of mineral oil hydrocarbons in food and food contact materials”. The initiative provides guidance for sampling and analysis of mineral oil saturated hydrocarbons (MOSH) and mineral oil aromatic hydrocarbons (MOAH) in food and food contact materials (FCM). The guidance recognises that supplementary test methods may be needed. Indeed, HARRPA has shown that a simple analytical technique (referred to as LC-GC-FID or 1D-GC), does not sufficiently distinguish between mineral oils and other low molecular weight hydrocarbons, such as resins.
Food can be contaminated by microbial organisms or chemicals such as mineral oil that can unintentionally enter the food at various points in the supply chain, for example through recycled food packaging paper. The presence of MOSH/MOAH in food has been subject of debate. Certain components in mineral oil can cause adverse health effects as they may bioaccumulate or are considered carcinogenic. Regulations might be pursued that limit their content in packaging materials.
Hydrocarbon, Rosin and Terpene resins are a distinct class of amorphous products that are characterized by a high glass transition temperature in relation to their molecular weight. As such, they are different from oils, waxes or plasticisers. Resins can also be found in food contact materials but are not MOSH or MOAH.
HARRPA members are committed to meeting stringent EU regulatory safety expectations on their products, particularly those which may come in to contact with food. We are encouraged that the JRC guidance recommends that in some instances more sophisticated analytical techniques should be used, especially in the case of samples with difficult or complex matrices as illustrated in Annex II of the guidance [page 31].
HARRPA supports a two-stage approach to testing with the LC-GC-FID as a first stage and an additional testing method capable to distinguish between mineral oil and resins (or other substances) as the second. With that in mind, HARRPA engaged in 2017 with Laboratory Lommatzsch & Säger to develop a proof of concept based on 2-Dimensional Gas Chromatography (2D-GC) to distinguish mineral oil and resins in cereals. This was so successful that it was extended to the main resin families on the market.
The JRC guidance on sampling, analysis and data reporting for the monitoring of mineral oil hydrocarbons in food and food contact materials gives performance requirements and references to current analytical approaches. The JRC refers to a LC-GC-FID (1-Dimensional GC) method as the method of choice for the quantification of mineral oils in routine analysis. The LC-GC-FID cannot distinguish between mineral oils and other low molecular weight hydrocarbons such as resins, polymer oligomers, and waxes.
As such the JRC guidance recognises that supplementary testing methods exist which can better identify non-MOSH/MOAH substances in complex matrixes. For example, the guidance states:
− “With difficult samples and matrices, further characterisation of the MOSH/MOAH fractions can be performed by using additional analytical techniques, e.g. GC-MS, LC-GC-FID/MS or GCxGC FID/MS” [Section 4.3, page 12]
− “If an interference is suspected even after purification, the characterisation of the MOSH or MOAH fraction has to be verified by using additional analytical methods, such as (LC-)GC-MS or GCxGC FID/MS” [ Figure 1 and Section 4.4, page 14]
Proper adherence to the JRC guidance will help avoid any unjustified dismissal of evaluated and approved food contact materials, e.g. materials in the EU list of the Plastics Regulation. The 2D-GC is more sophisticated in analyzing resins in food contact materials compared to the 1D-GC. The 2D-GC shows clusters of resins species that can be distinguished from mineral oil. HARRPA intends to work with other stakeholders to pursue the adoption of a two-stage approach for food and FCM which would allow for greater transparency in the supply chain. The objective is to improve consumer confidence that potentially harmful substances and other substances are correctly identified and quantified.
i Although mineral oil varies considerably in composition due to the differences in level of refinement, the European Food Safety Authority has concluded that the mineral oil intake is a potential concern. In a review published in 2018, the Dutch National Institute for Public Health and the Environment reduced the concerns about the saturated hydrocarbons in food and advised to focus on the aromatic hydrocarbons.
