{"hq_id":"hq-p-pet-000088","name":"Mineral Oil Aromatic Hydrocarbon (MOAH) Migration into Dry Pet Food (Recycled Paperboard, Printing Inks, EFSA 2023 Reaffirmed Guidance)","category":{"primary":"pet","secondary":"food_safety","tags":["MOAH","mineral oil aromatic hydrocarbon","MOSH","dry pet food","paperboard packaging","printing ink","recycled fibre","EFSA","Germany Mineral Oil Ordinance","migration"]},"product_tier":"PET","overall_risk_level":"moderate","description":"Mineral oil aromatic hydrocarbons (MOAH) and saturated mineral oil hydrocarbons (MOSH) migrate into dry pet food from recycled-paperboard packaging, mineral-oil-based printing inks, and food-contact lubricants in manufacturing line equipment. MOAH fractions contain polycyclic aromatic compounds, including suspected genotoxic carcinogens; MOSH fractions accumulate in mesenteric lymph nodes and spleen with no clear toxicity threshold — EFSA 2023 reaffirmed its 2012 health-based guidance value and identified MOAH as a contaminant of toxicological concern. This entry is differentiated from existing PET product 000057 (which covers BPA can linings, phthalate flexible packaging, and PFAS grease-resistant treat bag coatings) by focusing specifically on the MOSH/MOAH migration pathway from recycled fibre and printing inks into dry kibble — a packaging-mode that 057 did not address. Germany has a draft Mineral Oil Ordinance (Mineralöl-Verordnung) setting a 0.5 mg/kg MOAH limit; the EU framework references EFSA opinions but has not promulgated a specific limit; the United States has NO regulatory standard for MOSH/MOAH in pet food packaging. Pet exposure is uniform and chronic — daily consumption of the same packaged kibble for the lifetime of the animal. Dry kibble in particular exhibits high MOAH uptake because the kibble's lipid content and high surface area extract hydrocarbons from packaging more efficiently than moist/canned alternatives. Studies (Stiftung Warentest 2015, Foodwatch/Lebensmittelchemie 2019) have detected MOAH levels of 0.5-15 mg/kg in European dry pet food samples; comparable US data is sparse.","synthesis":{"derived_risk_level":"moderate","synthesis_confidence":0.673,"synthesis_method":"compound_composition","context_used":"human_infant","context_source":"available_priority","exposure_modifier":1.15,"vulnerability_escalated":false,"escalation_reason":null,"compounds_resolved":3,"compounds_total":3,"synthesis_date":"2026-05-09","synthesis_version":"1.2.0","methodology_note":"exposure_modifier and adjusted_magnitude are computed from ALETHEIA-calibrated heuristics (route × duration × frequency multipliers, clamped to [0.5, 1.4]). Multipliers are directionally informed by EPA Exposure Factors Handbook (2011) and CalEPA OEHHA but are not regulatory consensus. See /api/methodology for full disclosure."},"hazard_summary":{"sensitive_populations":"all pets fed exclusively dry kibble (chronic uniform exposure); particularly long-lived breeds and species","overall_risk":"moderate","primary_concerns":["MOAH fraction may include genotoxic carcinogens (EFSA 2023 + IARC vol 100F)","MOSH accumulates in mesenteric lymph nodes and spleen — unclear toxicity threshold","US has NO regulatory limit for MOSH/MOAH in pet food packaging (gap vs Germany)","Recycled paperboard fibre is the dominant migration source — sustainability vs safety trade-off","Pets consume the same packaged food daily for life — most uniform chronic exposure of any food-contact pathway"],"exposure_routes":"Oral ingestion via kibble that has absorbed MOSH/MOAH from packaging during shelf life"},"exposure":{"routes":["oral"],"contact_types":["oral_direct"],"users":["pet_dog","pet_cat"],"duration":"chronic","frequency":"daily","scenarios":["Daily consumption of dry kibble packaged in recycled-paperboard bag for years","MOAH uptake into kibble lipid fraction during 6-12 month bag shelf life","Bulk-bin dispensed pet food repackaged into uncertified secondary container","Printing-ink mineral oil migration through inner liner of laminated paper bag","Manufacturing-line lubricant carryover into kibble during extrusion / packaging"],"notes":"MOSH = Mineral Oil Saturated Hydrocarbons (n-alkanes, iso-alkanes, cycloalkanes); MOAH = Mineral Oil Aromatic Hydrocarbons (1-4 ring aromatics, potentially alkylated). EFSA 2012 + 2023 opinions: MOAH may include suspected genotoxic carcinogens; MOSH accumulates in mesenteric lymph nodes/spleen with unclear toxicity threshold. IARC: highly refined mineral oils Group 3; untreated/mildly treated Group 1 (per IARC vol 33 + 100F). Germany BMEL draft Mineralöl-Verordnung sets 0.5 mg/kg MOAH limit (multiple drafts since 2017, not yet final). Stiftung Warentest 2015 dry-pet-food analysis: 0.5-15 mg/kg MOAH detected. Foodwatch 2019 follow-up: persistent contamination despite voluntary industry commitments. US: no regulatory standard, no surveillance data publicly available. Mitigation: virgin-fibre paperboard, functional inner barrier (polyethylene + EVOH or aluminum), low-migration printing inks, food-grade white mineral oil (USP/FCC) only on packaging line equipment."},"consumer_guidance":{"usage_warning":"Choose pet food packaged in virgin-fibre paperboard bags WITH a functional inner barrier (polyethylene, EVOH, or aluminum laminate) rather than recycled-fibre single-layer paperboard. Once opened, transfer kibble to a sealed glass, ceramic, or stainless-steel container — do NOT keep kibble in the original bag for weeks. Avoid bulk-bin dispensed pet food where the original packaging is unknown. Larger bag sizes have longer shelf-life exposure to packaging migrants — consider smaller bags consumed within 30 days. Look for manufacturers that publish MOSH/MOAH testing or specify low-migration inks.","safer_alternatives":["Pet food in foil-lined or aluminum-pouched packaging (functional barrier)","Pet food in metal cans or glass jars (canned diet, freeze-dried in glass)","Smaller bags consumed within 30 days to limit migration time","Transfer to sealed glass/ceramic/stainless storage container immediately after opening","Manufacturers with published MOSH/MOAH analysis or third-party verification"]},"regulatory":{"applicable_regulations":[{"jurisdiction":"USA","regulation":"FDA 21 CFR Parts 170-199 (food-contact substances; pet food covered)","citation":"21 CFR 170-199; FDA Compliance Policy Guide 690.300","requirements":"Pet-food packaging materials must comply with FDA food-contact substance regulations. AAFCO model regulations adopted by states. No specific MOSH/MOAH limit in US (gap vs EU Germany Mineral Oil Ordinance).","compliance_status":null,"effective_date":null,"enforcing_agency":"FDA-CVM / state feed-control officials","penalties":null,"source_ref":null},{"jurisdiction":"EU","regulation":"Regulation (EC) No 1935/2004 + Germany Mineral Oil Ordinance (Mineralöl-Verordnung, draft)","citation":"EC 1935/2004; BMEL draft 2021 update","requirements":"EU framework requires food-contact materials not transfer constituents at hazardous levels. Germany draft sets 0.5 mg/kg MOAH limit; EFSA 2023 reaffirmed health-based guidance value for MOH.","compliance_status":null,"effective_date":null,"enforcing_agency":"EFSA / BMEL","penalties":null,"source_ref":null}],"certifications":[],"labeling":{"required_disclosures":[],"prop65_warning":{"required":null,"chemicals":[],"endpoint":null,"notes":null},"ghs_labeling":{"required":null,"signal_word":null,"pictograms":[],"hazard_statements":[],"notes":null},"hidden_ingredients":{"trade_secret_protected":null,"categories_hidden":[],"estimated_count":null,"known_concerns":null,"notes":null},"notes":null},"recalls":[],"regulatory_gap":null,"notes":null},"lifecycle":{"recyclable":true,"disposal_guidance":"Paperboard bags: paper recycling (where laminated bags accepted). Plastic-lined bags: regular waste. Foil pouches: specialty TerraCycle recycling.","hazardous_waste":false,"expected_lifespan":"6-18 month bag shelf life"},"formulation":{"form":"varies","key_ingredients":[],"certifications":[]},"materials":{"common":[],"concerning":[],"preferred":[]},"compound_composition":[{"hq_id":"hq-c-mix-000036","compound_name":null,"role":"moah_mosh_mixture","typical_concentration":"mineral oils (untreated/mildly treated) — MOAH and MOSH fractions; EFSA contaminant of concern"},{"hq_id":"hq-c-org-000415","compound_name":null,"role":"moah_mosh_mixture","typical_concentration":"mineral oils, untreated and mildly treated — IARC Group 1 (untreated), Group 3 (highly refined)"},{"hq_id":"hq-c-org-000683","compound_name":null,"role":"petroleum_distillate","typical_concentration":"mineral oil (petroleum distillate) — co-migration with MOSH/MOAH from packaging adhesives and lubricants"}],"identifiers":{"common_names":["mineral oil aromatic hydrocarbon (moah) migration into dry pet food (recycled paperboard, printing inks, efsa 2023 reaffirmed guidance)"],"aliases":[],"manufacturer":null,"brands":[]},"brand_examples":[],"brand_examples_disclaimer":null,"sources":[{"type":"expert_curation","name":"ALETHEIA Safety Database","date":"2026-05-08"}],"meta":{"schema_version":"4.0.0","last_updated":"2026-05-08","timestamp":"2026-06-11T20:59:22.556Z"},"_notice":"ALETHEIA output is reference data, not professional advice. Not a substitute for primary agency sources or qualified professionals. See https://aletheia.holisticquality.io/disclaimer.","_disclaimer_url":"https://aletheia.holisticquality.io/disclaimer"}