Annex to Regulation on Levels of PAH in Foodstuffs Amended by EU Commission

On 10 July 2015, the European Commission published Regulation (EU) No 2015/1125 amending Annex to Regulation (EC) No 1881/2006 in regards to maximum levels for polycyclic aromatic hydrocarbons (PAHs) in foodstuffs.

The new regulation adds Katsuobushi (dried bonito) and certain smoked herring to a range of foodstuffs where maximum levels of PAHs are set.

PAHs Analysis

Polycyclic aromatic hydrocarbons (PAHs) are a group of environmental pollutants resulting from incomplete combustion of organic matter such as oil, wood, garbage and coal. PAHs are carcinogenic and can occur during food processing such as smoking, roasting, baking, drying and grilling. Maximum levels should both be safe for consumers and set at a level which is as low as reasonably achievable (ALARA), based on good manufacturing, drying and agricultural/fishery practices. Therefore, the EU has set maximum levels of PAHs in foodstuffs via Regulation (EC) No 1881/2006 amended by Regulation (EU) No 835/2011 [1], which added limits for the sum of four PAHs in foodstuffs including adding smoked sprats and canned smoked sprats to the range of foodstuffs.

New Regulation for Traditional Foods: Drying Fish and Smoking Fish

This latest update, Regulation (EU) No 2015/1125 [2], includes Katsuobushi which is a traditional Japanese food product made from bonito. Its manufacturing process involves filleting, boiling and deboning followed by a smoking/drying process, using wood as the combustion source. Japanese authorities provide evidence to show that despite the application of good smoking practices, lower levels for PAHs are not achievable for Katsuobushi. Therefore, Katsuobushi products are added to the Regulation with maximum levels of PAHs.  

Additionally, a product called “Sprotid” which is a traditional product in Estonia, can contain both sprat (Sprattus sprattus) and Baltic herring (Clupea harengus membras) depending on the season and availability. Sprotid needs to be labeled mentioning whether the product contains sprats, or Baltic herring, or a mixture, with the ratio of each fish species present. Due to the fact that both fish are of comparable size and classified as small scale fish, the smoking procedures are the same and consequently levels of PAHs are very similar. Therefore, maximum levels of PAHs in smoked Baltic herring and canned smoked small herring should be set the same as for smoked sprats and canned smoked sprats.

Regarding the information of Katsuobushi and Sprotid, Regulation of PAHs in the annex to Regulation (EC) No 1881/2006 is amended in point 6.1.6 in section 6 as follows:    

1) Foodstuffs
- 6.1 Benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene
- 6.1.6 Smoked sprats and canned smoked sprats (Sprattus sprattus); Smoked Baltic herring less than or equal to 14 cm length and canned smoked Baltic herring less than or equal to 14 cm length (Clupea harengus membras); Katsuobushi (dried bonito, Katsuwonus pelamis); bivalve mollusks (fresh, chilled or frozen); heat treated meat and heat treated meat products sold to the final consumer.

2) Maximum levels (microgram/kg)
- Benzo(a)pyrene: 5.0
- Sum of benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene: 30.0

The new regulation enters into force 20 days after the publishing date.

Food manufacturers, processors and retailers supplying to and/or selling Katsuobushi and smoked herring products within the EU must verify that their products comply with the new regulation.

References:

(1)    Commission Regulation (EU) 835/2011 of 19 August 2011 amending Regulation (EC) No 1881/2006 as regards maximum levels for polycyclic aromatic hydrocarbons in foodstuffs, EUR-Lex– August 2011

(2)    Commission Regulation (EU) 2015/1125 of 10 July 2015 amending Regulation (EC) No 1881/2006 as regards maximum levels for polycyclic aromatic hydrocarbons in Katsuobushi (dried bonito) and certain smoked Baltic herring, EUR-Lex – July 2015

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