Food contaminant compliance in the EU has changed again.<\/p>\n\n\n\n
On 29 July 2026, the European Commission adopted Commission Regulation (EU) 2026\/1825<\/strong>, amending Regulation (EU) 2023\/915 on maximum levels for certain contaminants in food.<\/p>\n\n\n\n The update concerns 3-monochloropropanediol (3-MCPD), 3-MCPD fatty acid esters and glycidyl fatty acid esters<\/strong> in vegetable oils, fish oils, marine oils, baby foods and certain compound foods.<\/p>\n\n\n\n The Regulation entered into force on 19 August 2026<\/strong>. Several of its most important new and reduced limits for foods intended for infants and young children apply from 1 January 2027<\/strong>. [European Commission, Commission Regulation (EU) 2026\/1825<\/em>]<\/p>\n\n\n\n For manufacturers using refined oils, fish oils or oil-rich formulations, this is not simply another regulatory update to archive.<\/p>\n\n\n\n It is a reason to review specifications, finished-product testing and supplier data now.<\/p>\n\n\n\n 3-MCPD and its fatty acid esters are processing contaminants<\/strong>. They can form unintentionally during food manufacturing, particularly during the refining of vegetable oils at high temperatures.<\/p>\n\n\n\n Glycidyl fatty acid esters are another group of process contaminants associated particularly with refined fats and oils.<\/p>\n\n\n\n EFSA has assessed both groups because of potential health concerns. Its updated assessment established a tolerable daily intake of 2 micrograms per kilogram of body weight per day for 3-MCPD and its esters<\/strong>, while the presence of glycidyl esters has also been identified as a health concern. [EFSA, Revised safe intake for 3-MCPD in vegetable oils and food<\/em>]<\/p>\n\n\n\n The European Commission classifies 3-MCPD and glycidyl fatty acid esters among the processing contaminants for which legally binding maximum levels apply to defined food categories. [European Commission, Contaminants \u2013 Food Safety<\/em>]<\/p>\n\n\n\n These substances are not intentionally added ingredients.<\/p>\n\n\n\n They can arise from processing.<\/p>\n\n\n\n That makes process control and analytical verification particularly important.<\/p>\n\n\n\n The regulation replaces the existing sections of Annex I covering both the sum of 3-MCPD plus its fatty acid esters and glycidyl fatty acid esters.<\/p>\n\n\n\n There are several changes that food businesses should distinguish.<\/p>\n\n\n\n Vegetable oils, fish oils and oils from other marine organisms intended for the manufacture of baby food or processed cereal-based foods for infants and young children already had specific limits.<\/p>\n\n\n\n Those limits are now being reduced.<\/p>\n\n\n\n From 1 January 2027<\/strong>, the maximum level for the sum of 3-MCPD and 3-MCPD fatty acid esters in these oils decreases from:<\/p>\n\n\n\n 750 \u00b5g\/kg \u2192 500 \u00b5g\/kg<\/strong><\/p>\n\n\n\n For glycidyl fatty acid esters, expressed as glycidol, the corresponding maximum decreases from:<\/p>\n\n\n\n 500 \u00b5g\/kg \u2192 250 \u00b5g\/kg<\/strong><\/p>\n\n\n\n [European Commission, Regulation (EU) 2026\/1825, Annex I points 5.3.2 and 5.4.2<\/em>]<\/p>\n\n\n\n For suppliers serving the infant-nutrition sector, this means existing oil specifications should be checked against the 2027 limits<\/strong>, not only against the currently accepted specification.<\/p>\n\n\n\n A raw material that is compliant today may not meet the applicable limit from January.<\/p>\n\n\n\n The regulation does more than tighten the limits on the oils used as ingredients.<\/p>\n\n\n\n It also establishes maximum levels directly for baby food and processed cereal-based food for infants and young children<\/strong>.<\/p>\n\n\n\n From 1 January 2027:<\/p>\n\n\n\n The maximum levels apply to the product as placed on the market<\/strong>. [European Commission, Regulation (EU) 2026\/1825, Annex I points 5.3.4 and 5.4.4<\/em>]<\/p>\n\n\n\n This distinction matters.<\/p>\n\n\n\n Checking only the incoming oil is no longer sufficient to establish compliance of the finished baby food.<\/p>\n\n\n\n Finished-product verification becomes a separate consideration.<\/p>\n\n\n\n When Regulation (EU) 2023\/915 was adopted, sufficient occurrence data were not yet available to establish specific maximum levels for these contaminants in baby foods and processed cereal-based foods for infants and young children.<\/p>\n\n\n\n The Commission states that these occurrence data have since become available, allowing maximum levels to be established.<\/p>\n\n\n\n It also concluded that the limits applying to oils intended for these foods should be lowered to remain consistent with the limits that can be achieved in the final products. [European Commission, Regulation (EU) 2026\/1825, recitals 4\u20135<\/em>]<\/p>\n\n\n\n This is a useful compliance lesson beyond this specific regulation:<\/p>\n\n\n\n Ingredient compliance and finished-product compliance are not always interchangeable.<\/p>\n\n\n\n One of the most commercially important parts of the regulation extends beyond infant products.<\/p>\n\n\n\n The revised Annex introduces explicit provisions for compound foods containing more than 5% fat and containing added vegetable oils, fats, fish oils or oils from other marine organisms<\/strong>.<\/p>\n\n\n\n For the sum of 3-MCPD and its fatty acid esters, the applicable level depends on the type of oil used.<\/p>\n\n\n\n For qualifying compound foods containing only oils from the lower-limit category, the maximum is:<\/p>\n\n\n\n 1,250 \u00b5g\/kg fat<\/strong><\/p>\n\n\n\n For products containing oils from the other category, it is:<\/p>\n\n\n\n 2,500 \u00b5g\/kg fat<\/strong><\/p>\n\n\n\n Mixtures require a calculation based on the oils used and the applicable maximum levels. If the quantitative composition is not known to the authority and the food business operator that did not manufacture the mixture, the level may in any case not exceed 2,500 \u00b5g\/kg fat. [European Commission, Regulation (EU) 2026\/1825, Annex I point 5.3.5<\/em>]<\/p>\n\n\n\n For glycidyl fatty acid esters, qualifying compound foods containing more than 5% fat and added oils are subject to a maximum level of:<\/p>\n\n\n\n 1,000 \u00b5g\/kg fat<\/strong><\/p>\n\n\n\n [European Commission, Regulation (EU) 2026\/1825, Annex I point 5.4.5<\/em>]<\/p>\n\n\n\n The wording \u201c\u00b5g\/kg fat\u201d<\/strong> is critical.<\/p>\n\n\n\n These limits are based on the fat fraction, not simply on the total weight of the finished product.<\/p>\n\n\n\n This is one of the easiest details to miss.<\/p>\n\n\n\n The Regulation itself entered into force on the twentieth day after publication, 19 August 2026<\/strong>.<\/p>\n\n\n\n The text explicitly delays the application of the limits in points 5.3.2, 5.3.4, 5.4.2 and 5.4.4<\/strong> until 1 January 2027.<\/p>\n\n\n\n Those are the reduced limits for oils destined for baby and young-child foods and the newly established finished-product limits for those foods. [European Commission, Regulation (EU) 2026\/1825, Articles 1\u20132<\/em>]<\/p>\n\n\n\n The other amendments are not given that same 1 January 2027 application date in the Regulation.<\/p>\n\n\n\n Companies should therefore avoid treating the entire regulation as a \u201c2027 issue.\u201d<\/p>\n\n\n\n The review should start now.<\/p>\n\n\n\n The Commission also addresses an interpretation issue around refined olive oil.<\/p>\n\n\n\n It states that there had been confusion about which 3-MCPD maximum level applies to refined olive oil.<\/p>\n\n\n\n The revised Annex now explicitly places refined olive oil and pomace olive oils<\/strong> within the relevant \u201cother vegetable oils and fats\u201d category, while virgin olive oils are excluded from these particular entries. [European Commission, Regulation (EU) 2026\/1825, recital 7 and Annex I<\/em>]<\/p>\n\n\n\n For manufacturers working with olive-derived ingredients, existing specifications should therefore be checked against the exact type of oil used.<\/p>\n\n\n\n \u201cOlive oil\u201d is not sufficiently precise for this assessment.<\/p>\n\n\n\n The regulation also addresses how glycidyl fatty acid esters are measured.<\/p>\n\n\n\n Official laboratories commonly use indirect analytical methods. Recent research showed that these methods can determine 3-MBPD fatty acid esters and 3-MIPD fatty acid esters together with glycidyl esters<\/strong>, particularly in marine oils.<\/p>\n\n\n\n The amended Regulation therefore specifies that the maximum level for glycidyl fatty acid esters refers to the sum of glycidyl esters, 3-MBPD fatty acid esters and 3-MIPD fatty acid esters<\/strong>. [European Commission, Regulation (EU) 2026\/1825, recital 8 and Annex I section 5.4<\/em>]<\/p>\n\n\n\n This is particularly relevant for laboratories, fish-oil suppliers and companies relying on historical analytical reports.<\/p>\n\n\n\n An old result may not necessarily have been generated or interpreted using the same analytical scope now reflected in the regulation.<\/p>\n\n\n\n The update is particularly relevant for businesses working with:<\/p>\n\n\n\n Food-supplement companies should also review oil-based products where the composition may bring the finished product within a relevant food category, particularly products based on fish or marine oils.<\/p>\n\n\n\n The correct legal category should be assessed for the individual product rather than assumed from the marketing format alone.<\/p>\n\n\n\n A certificate of analysis from an oil supplier is an important part of compliance documentation.<\/p>\n\n\n\n It does not automatically answer every question created by Regulation 2026\/1825.<\/p>\n\n\n\n There are several reasons.<\/p>\n\n\n\n First, finished-product limits now apply to certain baby foods.<\/p>\n\n\n\n Second, compound-food limits can depend on the total fat content and the exact oils used.<\/p>\n\n\n\n Third, the analytical interpretation of glycidyl esters has been clarified.<\/p>\n\n\n\n Fourth, processing itself can influence contaminant formation.<\/p>\n\n\n\n 3-MCPD and related esters are process contaminants associated particularly with high-temperature oil refining. EFSA specifically identifies processed foods and refined vegetable oils as important sources. [EFSA, Revised safe intake for 3-MCPD in vegetable oils and food<\/em>]<\/p>\n\n\n\n The correct question is therefore not simply:<\/p>\n\n\n\n \u201cDoes our supplier have a COA?\u201d<\/strong><\/p>\n\n\n\n It is:<\/p>\n\n\n\n \u201cDoes our evidence demonstrate compliance for this ingredient, this finished product and the applicable legal category?\u201d<\/strong><\/p>\n\n\n\n A practical Regulation 2026\/1825 review should begin with the formulation library.<\/p>\n\n\n\n Identify products containing refined vegetable oils, fish oils or other marine oils.<\/p>\n\n\n\n Then determine:<\/p>\n\n\n\n Which regulatory food category applies?<\/strong><\/p>\n\n\n\n Is the limit expressed per kilogram of product or per kilogram of fat?<\/strong><\/p>\n\n\n\n Does a new limit apply now or from 1 January 2027?<\/strong><\/p>\n\n\n\n Are current supplier specifications sufficiently below the new maximum?<\/strong><\/p>\n\n\n\n Do finished products require analytical verification?<\/strong><\/p>\n\n\n\n Does the existing analytical method cover the substances included in the revised definition?<\/strong><\/p>\n\n\n\n For products intended for infants and young children, the remaining preparation period should be used to verify both ingredients and finished-product compliance.<\/p>\n\n\n\n For the new January 2027 limits, the Regulation includes a transitional provision.<\/p>\n\n\n\n Foods lawfully placed on the market before 1 January 2027<\/strong> in the categories specifically covered by the delayed limits may remain on the market until their date of minimum durability or use-by date. [European Commission, Regulation (EU) 2026\/1825, Article 1<\/em>]<\/p>\n\n\n\n That does not mean companies can ignore the deadline until December.<\/p>\n\n\n\n Production planning, raw-material purchasing, analytical testing and shelf-life management all need to be coordinated before the first 2027 batches are released.<\/p>\n\n\n\n A compliant inventory strategy should distinguish between:<\/p>\n\n\n\n products already legally placed on the market,<\/p>\n\n\n\n products produced but not yet placed on the market,<\/p>\n\n\n\n and products manufactured from 2027 onward.<\/p>\n\n\n\n It does not.<\/p>\n\n\n\n The Annex covers multiple vegetable oils, fish oils and oils from other marine organisms.<\/p>\n\n\n\n For certain categories, maximum levels now apply directly to the finished food.<\/p>\n\n\n\n For relevant compound foods, the regulation specifies limits in \u00b5g\/kg fat<\/strong>.<\/p>\n\n\n\n Using the wrong denominator can completely distort the compliance assessment.<\/p>\n\n\n\n The regulation is already in force, and not every amendment is delayed until 2027.<\/p>\n\n\n\n The amended text explicitly includes 3-MBPD and 3-MIPD fatty acid esters within the relevant maximum-level definition.<\/p>\n\n\n\n Regulatory compliance becomes much easier when the legal requirement and the analytical test are considered together.<\/p>\n\n\n\n Makrolife Biotech supports food and supplement manufacturers with contaminant testing, product analysis, specification verification and regulatory compliance assessment<\/strong>.<\/p>\n\n\n\n For Regulation 2026\/1825, a review can include:<\/p>\n\n\n\n Makrolife offers food-safety and contaminant analyses for foods and food supplements as part of its regulatory compliance services. [Makrolife Biotech, Food Safety, Contaminants & Compliance<\/em>]<\/p>\n\n\n\n Our broader Food & Supplements services also cover ingredient analysis, composition testing, labelling verification and product assessment for EU market entry. [Makrolife Biotech, Food & Supplements<\/em>]<\/p>\n\n\n\n Regulation (EU) 2026\/1825 is not simply a reduction of two contaminant limits.<\/p>\n\n\n\n It introduces new finished-product requirements, extends the framework for compound foods, clarifies the treatment of refined olive oil and updates how glycidyl ester results are interpreted.<\/p>\n\n\n\n For businesses using refined oils, fish oils or marine oils, the most efficient approach is therefore not to wait for a failed batch in 2027.<\/p>\n\n\n\n Review the formula.<\/p>\n\n\n\n Confirm the food category.<\/p>\n\n\n\n Verify the analytical method.<\/p>\n\n\n\n Test where necessary.<\/p>\n\n\n\n And make sure the result is assessed against the correct limit.<\/p>\n\n\n\n Need to review a product or formulation against Regulation (EU) 2026\/1825? Contact Makrolife Biotech for analytical testing and regulatory assessment.<\/strong><\/p>\n\n\n\n <\/p>\n","protected":false},"excerpt":{"rendered":" Food contaminant compliance in the EU has changed again. On 29 July 2026, the European Commission adopted Commission Regulation (EU) 2026\/1825, amending Regulation (EU) 2023\/915 on maximum levels\u2026<\/p>\n","protected":false},"author":2,"featured_media":255,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[75,9],"tags":[77,78,76,79,80,61,81,67],"class_list":["post-254","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-food-supplements-regulatory","category-regulatory","tag-3-mcpd","tag-eu-compliance","tag-eu-regulation-2026-1825","tag-food-contaminants","tag-food-safety","tag-food-supplements","tag-glycidyl-esters","tag-laboratory-testing"],"_links":{"self":[{"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/posts\/254","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/comments?post=254"}],"version-history":[{"count":1,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/posts\/254\/revisions"}],"predecessor-version":[{"id":256,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/posts\/254\/revisions\/256"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/media\/255"}],"wp:attachment":[{"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/media?parent=254"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/categories?post=254"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/makrolife-biotech.com\/blog\/wp-json\/wp\/v2\/tags?post=254"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}What Are 3-MCPD and Glycidyl Esters?<\/h2>\n\n\n\n
What Changes Under Regulation (EU) 2026\/1825?<\/h2>\n\n\n\n
1. Stricter Limits for Oils Used in Baby and Young-Child Foods<\/h2>\n\n\n\n
2. New Maximum Levels for Finished Baby Foods<\/h2>\n\n\n\n
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Why Did the EU Add Finished-Product Limits?<\/h2>\n\n\n\n
3. Compound Foods Containing Added Oils Now Need Closer Attention<\/h2>\n\n\n\n
Not Everything Waits Until January 2027<\/h2>\n\n\n\n
4. Refined Olive Oil Is Explicitly Clarified<\/h2>\n\n\n\n
5. Glycidyl Ester Analysis Now Includes an Important Analytical Clarification<\/h2>\n\n\n\n
Which Companies Should Review Their Products?<\/h2>\n\n\n\n
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Why a Supplier COA May Not Be Enough<\/h2>\n\n\n\n
What Should Food Companies Do Now?<\/h2>\n\n\n\n
Existing Products Also Need a Transition Review<\/h2>\n\n\n\n
Common Compliance Mistakes to Avoid<\/h2>\n\n\n\n
Assuming the regulation only concerns palm oil<\/h3>\n\n\n\n
Focusing only on raw materials<\/h3>\n\n\n\n
Reading the limit against total product weight when it applies to fat<\/h3>\n\n\n\n
Waiting until January 2027 to begin testing<\/h3>\n\n\n\n
Treating \u201cglycidyl esters\u201d as analytically unchanged<\/h3>\n\n\n\n
How Makrolife Biotech Can Support Your Review<\/h2>\n\n\n\n
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The Deadline Is January. The Review Starts Now.<\/h2>\n\n\n\n
Sources<\/h2>\n\n\n\n
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