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Trying to Run Before You Can Walk: Control and Enforcement of Mineral Oil Aromatic Hydrocarbon Contamination of Food in the European Union

Craig Simpson

The current agreement between European Union (‘EU’) Member States to withdraw or recall food products in which a quantified presence of the contaminant mineral oil aromatic hydrocarbons (‘MOAH’) is confirmed may soon be replaced by EU legislation establishing maximum levels of MOAH in food. Both initiatives will likely lead to significant business interruption of global supply chains for a wide range of food products in which MOAH concentrations are detected. This article critically assesses the harmonised EU enforcement approach to MOAH contamination of food and finds it to be questionable from both a legal and scientific perspective.

Craig Simpson, Partner at Keller and Heckman. For correspondence: <>.


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