Joint EFFA-IOFI-EFEO-IFEAT Letter to EU-Commission on MOAH MLs

5 November 2025 – EFFA-IOFI-EFEO-IFEAT Comments regarding the Proposal for a Commission Regulation amending Regulation (EU) 2023/915 as regards maximum levels of MOAH in food (Draft Measure Rev7) & concerns on monitoring proposal. 

As follow-up to EFFA PPP TF letter from April 2025 (on the Draft Measure on Mineral Oils, Rev5) and the further exchange in April 2025, a joint letter was prepared by EFFA, IOFI, EFEO, and IFEAT concerning the latest revision of the Draft Commission Recommendation on Monitoring of MOH in food (Rev5) addressed to DG SANTE.

The purpose of the letter is to advocate for the removal of references to “essential oils” in the Draft Recommendation on Monitoring of MOH (rev.5), while clarifying their definition in accordance with ISO 9235.

The letter highlighted the analytical challenges involved in determining the content (and quantification) of mineral oils in various food matrices, especially essential oils as complex matrices.

Concerns are being expressed by the global flavour industry (IOFI) and essential oil suppliers (EFEO & IFEAT) about the impact this Regulation, and the resulting Commission Recommendation, will have on global trade.