MOSH/MOAH — Mineral Oil Hydrocarbons
ROLL Packaging STICKO PAPER cardboard cradles are industrial packaging for roll storage and shipping, not materials intended to come into direct contact with food. ROLL nevertheless monitors mineral oil hydrocarbon content through raw material supplier declarations, with reference to Commission Recommendation (EU) 2017/84.
What are MOSH and MOAH?
MOSH and MOAH are two classes of mineral oil hydrocarbons that may be present in paper and cardboard materials, particularly in cardboard manufactured from recycled fibres where residual printing inks can be a source of mineral oils.
MOSH
Mineral Oil Saturated Hydrocarbons. Saturated paraffinic and naphthenic structures. Subject to monitoring under EU recommendation due to potential bioaccumulation.
MOAH
Mineral Oil Aromatic Hydrocarbons. Aromatic structures that may include compounds of toxicological concern. Subject to monitoring as a precautionary measure.
Commission Recommendation (EU) 2017/84 of 16 January 2017 invites Member States to monitor MOSH and MOAH levels in food and in food contact materials, including paper and cardboard packaging, to support the assessment of dietary exposure and to inform potential future regulatory measures.
Applicability to ROLL products
ROLL STICKO PAPER cradles and stackers (PC family) are industrial packaging components designed for the storage, shipping and multi-roll handling of industrial rolls and reels. They are not designed nor placed on the market as materials intended to come into direct contact with food, within the meaning of Regulation (EC) No 1935/2004.
Consequently, the MOSH and MOAH migration limits recommended for food contact materials by Commission Recommendation (EU) 2017/84 and by national measures adopted by some EU Member States do not apply directly to ROLL STICKO PAPER products.
Where a ROLL STICKO PAPER cradle is used in the supply chain of a food roll (for instance, a roll of food-grade film), the cradle remains a tertiary packaging element separated from the food product itself by the primary packaging layer (the film roll), and therefore is not a source of direct migration of substances to the food.
ROLL voluntary monitoring approach
Although MOSH and MOAH limits are not directly applicable to ROLL STICKO PAPER products, ROLL applies a voluntary monitoring approach based on raw material supplier declarations, in alignment with the principles of Commission Recommendation (EU) 2017/84.
Supplier declarations
ROLL collects from its cardboard suppliers the available technical and compositional information regarding the cardboard substrate used to manufacture STICKO PAPER products, including indication of fibre source (virgin or recycled), processing aids and any specific declaration regarding mineral oil hydrocarbon content where available.
Cardboard composition
STICKO PAPER cradles are manufactured from corrugated cardboard supplied by EU-based paper mills, with composition specifications collected and stored in ROLL technical documentation. Recycled fibre content is disclosed by the supplier under the relevant material identification framework (recycling code 20 — PAP cardboard).
Specific food contact applications
Where a customer intends to use a ROLL STICKO PAPER cradle in an application that requires specific MOSH/MOAH compliance (for instance, direct contact with food-grade rolls in the absence of a barrier layer), the customer is invited to contact ROLL for a case-by-case assessment. Specific testing, if required, can be arranged with the cardboard supplier upon request.
Substances in packaging are addressed under PPWR Article 5
The PPWR compliance page covers the broader framework on restricted substances in packaging materials.
Regulatory reference
This declaration is issued with reference to Commission Recommendation (EU) 2017/84 of 16 January 2017 on the monitoring of mineral oil hydrocarbons in food and in materials and articles intended to come into contact with food.
The official text of the recommendation in all 24 EU languages is available on the EUR-Lex portal at eur-lex.europa.eu. At the date of this publication, no harmonised EU regulation with binding migration limits for MOSH and MOAH in food contact materials has been adopted; national measures may apply in certain Member States.
Disclaimer
The information on this page is provided for guidance only, on the basis of ROLL's most up-to-date knowledge and experience and of declarations received from its raw material suppliers. ROLL cannot assume liability for damage arising from its use. This statement does not constitute any warranty, express or implied. It is intended only for the addressee and cannot be transferred to third parties. All ROLL products are sold subject to the ROLL SNC general sales conditions. This publication replaces all previous versions and is subject to change without notice.