A fair consideration of imports, particularly in relation to the proposed regulations on plant protection products and residues
Current Issues
MOSH/MOAH: No transfer of MOH into the infusion observed
Mineral oil hydrocarbons (MOH) have been part of cross-sectoral discussions at EU level for over a decade. MOH can be divided into two main types, mineral oil saturated hydrocarbons (MOSH), which are long chain, partly branched hydrocarbons and mineral oil aromatic hydrocarbons (MOAH), which are aromatic hydrocarbons with 1-5 ring systems. MOAHs are at the centre of the debate as they pose a higher health risk to consumers than MOSHs. On 15th December, 2023, the EU Commission picked up the pace and distributed a relatively concrete draft for setting maximum levels for MOAH under the Contaminants Regulation (EU) 2023/915. The intention is to introduce maximum levels for almost all food categories. In order to provide stakeholders with a platform for dialogue on 18th January, 2024, the Commission held an online stakeholder forum, where THIE was actively involved. THIE presented the position of the tea and herbal infusion industry. The transfer studies carried out by THIE’s member associations STEPI and UKTIA formed the centrepiece of the argumentation. On the basis of the presented studies, it could be scientifically proven that no transfer of MOH into the infusion can be observed. Accordingly, there is no need for setting MLs for MOAH in tea, herbal and fruit infusions in the EU contaminants Regulation (EU) 2023/915. The transfer studies, as well as other relevant aspects, such as the difficulties in analytics, can be found in the THIE Statement on MOSH/MOAH.
Position on Omnibus X Food and Feed Safety
Our position paper can be found here and after thoroughly reviewing the proposals, the European tea and herbal infusions industry demands:
THIE Position Paper on the European Commission Proposal for Setting Maximum Permitted Levels (MPLs) of Vitamins and Minerals in Fortified Foods
The European Commission drafted a model to establish harmonised Maximum Permitted Levels (MPLs) for vitamins and minerals in fortified foods and food supplements. However, the current proposal, as outlined in the Commission’s latest Working Document, is not appropriate for low-energy food categories, such as tea, herbal and fruit infusions. In its current form, it would significantly impact consumer choice and contradict efforts to address nutrient deficiencies through diverse, accessible and healthier formats. THIE has written a Statement on the Commission’s plan, with the key arguments being as follows: