Stricter MOH limits for printing inks in France

In the spring of 2022, the French Ministry of the Environment published a decree that gradually bans or restricts the use of mineral oils in printing inks for packaging and specific printed matter such as leaflets and brochures. The reason for this is the health risks that can arise from certain mineral oil hydrocarbon compounds. France is significantly tightening the current legal regulation again from January 1, 2025.

Mineral oils for printing inks and their potential health risks

The French regulation applies to mineral oils used in the manufacture of printing inks whose raw materials are derived from petroleum. Specifically, it concerns

– aromatic mineral oil hydrocarbons (MOAH) with 1 to 7 aromatic rings and
– saturated mineral oil hydrocarbons (MOSH) with 16 to 35 carbon atoms.

Note: For better readability, only “MOAH” and “MOSH” are mentioned in the following – however, the specified variants are always meant, i.e. MOAH with one to seven aromatic rings and MOSH with 16 to 35 carbon atoms.

The main sources of mineral oils in packaging made of recycled paper and cardboard are considered to be newspapers and other print media that are recycled. In the case of packaging made of other materials, additives in plastic production or lubricants used in can production are possible sources.

It is possible that mineral oil hydrocarbons (MOH) unintentionally migrate from packaging materials into food. Some MOSH can accumulate in human tissue and certain MOAH can act as genotoxic carcinogens, i.e. they can damage the DNA structure and cause cancer. For these reasons, the absorption of MOH is considered to be potentially hazardous to health.

Note: The European Food Safety Authority (EFSA) currently classifies MOSH in food as harmless, but points out that MOAH with three or more aromatic rings can have a genotoxic and carcinogenic effect.

For the sake of completeness, it should be mentioned at this point that there are also sources of mineral oils in food that are independent of packaging, for example anti-dust additives for cereals and other food additives. In these cases, mineral oil hydrocarbons are even used intentionally.

Data and facts about the requirements in France

Since January 1, 2023, the use of printing inks with an MOAH concentration exceeding one percent has been prohibited. This regulation is valid until the end of 2024. Starting January 1, 2025, the MOAH concentration may only be a maximum of 0.1 percent.

To date, there have been no specific requirements for MOSH. From January 1, 2025, the value of 0.1 percent will also be the upper limit for these mineral oil hydrocarbons.

Source: Siegwerk printing inks, ‘Statement on mineral oils in printing inks and varnishes’

The aim of the requirements is to minimize the potential health risks posed by mineral oils in printing inks. Therefore, the above-mentioned substances, as well as others that could disrupt recycling loops and/or limit the recovery of recycled materials due to their health risk, are to be gradually eliminated from the market.

Why the regulations have also been criticized

In some quarters, the French regulations on the concentration of minerals in printing inks have met with strong resistance. On the one hand, the law’s explosive effect on the free movement of goods is pointed out, and on the other hand, the fact that analytical detectability and the exact demarcation of the mineral oil hydrocarbons concerned are problematic.

For example, it can be difficult to distinguish MOSH from polyolefin oligomeric saturated hydrocarbons (POSH) because they have a similar analytical detection profile. To date, POSH have not been evaluated for health. Thus, no data on the potential for harm from these substances is available. A mix-up could be fatal under certain circumstances.

Recommendations for packaging users

In view of the tightened requirements, users of packaging, especially printed folding cartons, should carefully check their supply chains and work closely with printing ink manufacturers and suppliers. Only in this way can they succeed in complying with the French regulation on the use of mineral oils in printing inks.

Ideally, the focus should be on minimizing the use of inks containing mineral oils and switching to alternatives that do not use mineral oils as soon as possible. This will reduce or even avoid legal risks and the threat of costly and reputation-damaging recall campaigns.

Summary

Mineral oils in printing inks and packaging can migrate into food and thus into people. They contain, among other things, mineral oil aromatic hydrocarbons (MOAH), which are potentially carcinogenic, and mineral oil saturated hydrocarbons (MOSH), whose possible accumulation in the human body is also considered to be a health hazard in some cases. Recycling materials, additives and production aids are the main sources of MOAH and MOSH in packaging.

In order to minimize health risks and promote recycling, France is restricting the use of MOAH and MOSH in printing inks and packaging. From January 1, 2025, the permitted limits of a maximum of 0.1 percent each are significantly lower than the current requirements, which will continue to apply until the end of 2024. It remains to be seen to what extent these regulations will prove effective, because the detectability and reliable differentiation of the substances concerned from other substances currently pose major technical challenges.

Nevertheless, it is advisable for packaging users to switch to mineral oil-free alternatives for materials and printing inks as soon as possible in order to be on the safe side legally and to offer their customers only products whose packaging is completely harmless to health.