Germany has informed the WTO of its intention to restrict mineral oil aromatic hydrocarbons (MOAH) in food contact materials and articles made from recycled paper and board.

SAFEGUARDS | Consumer ProductsNO. 042/21

 SG 04221 Food box

On March 22, 2021, the World Trade Organization (WTO) announced a draft regulation from Germany on its intention to restrict mineral oil aromatic hydrocarbons (MOAH) in food contact recycled paper and board under the nation’s Consumer Goods Ordinance (Bedarfsgegenständeverordnung, BedGgstV).

The draft regulation (in German or English), attached to WTO document number 21-2349, contains several important provisions. It:

  • Provides a new definition for waste paper pulp, functional barriers and MOAH, where MOAH means alkylated aromatic hydrocarbons with carbon numbers C16-C35 and containing one or more rings (except diisopropylnaphthalenes) 
  • Allows 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 the defined limits (see Table 1)
  • Provides a two-year sales period for products that are in compliant before the amendment

Highlights of the proposal are summarized in Table 1. 

WTO Document Number 21-2349 of March 22, 2021
Draft of the Federal Ministry of Food and Agriculture
Twenty-Second Ordinance amending the Consumer Goods Ordinance
Substance Scope Requirement Effective Date
MOAH Food contact paper, paperboard or cardboard made of recycled paper
≤ 0.5 mg/kg (sum of MOAH in food) or 
≤ 0.15 mg/kg (sum of MOAH in food simulant)
Three years after publication of the Ordinance

Table 1

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials, paving the way for compliance. From overall migration tests to expert advice on emerging regulations, compliance issues and documentation review, SGS is the partner to trust. In the end, it’s only trusted because it’s tested. Discover more on our website and read our brochure.

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