Germany Circulates Proposal to Restrict MOAH in Food Contact Recycled Paper and Board

On March 22, 2021, the World Trade
Organization (WTO) circulated a draft regulation signaling Germany’s intention
to regulate mineral oil aromatic hydrocarbons (MOAH) in food contact materials
and articles made from recycled paper and board.

The draft regulation includes:

• New definitions for waste paper pulp, functional barriers and MOAH. MOAH means alkylated
  aromatic hydrocarbons with carbon numbers C₁₆-C₃₅ and
  containing one or more rings (except diisopropylnaphthalenes)
• Allowances
  for food contact paper, paperboard or cardboard materials and articles to be
  made with recycled paper provided a functional barrier ensures that any MOAH
  migration is within defined limits:
  1. MOAH in food (sum): no more than 0.5 mg/kg
  2. MOAH in food simulant (sum): no more than 0.15 mg/kg
• Provision
  to allow two-year sales period for products that were compliant before the
  amendment

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Stakeholders
should be aware the new requirements will come into effect three-years after
publication of the ordinance.

SGS Food Contact Materials Services

SGS’s technical experts have extensive experience of testing materials and
articles in contact with food. They can ensure that your products meet the
appropriate regulations for food contact materials and pave the way for
compliance. SGS offers the full range of testing, including migration tests,
along with expert advice on emerging regulations, compliance issues and
documentation review. Learn more
about SGS’s Food
Contact Materials Services.

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