The 5th international symposium of RAFA (Recent Advances in Food Analytics), in Prague on 7-2024 November, also brought attention to mycotoxins as emerging food safety risks.
Frans Verstraete – a European official with great experience in the sector (1) – dedicated the first part of his lecture on food contaminants to this specific theme. Some food for thought to follow.
1) Food contaminants, EU legislation
Food Contaminants Regulation (EU) No 2023/915 replaced the previous Regulation (EC) 1881/06, consolidating the 45 amendments to which it had been subjected over the years. (1) The new regulation, as we have seen, has not modified the contaminant thresholds. The new provisions in fact concern:
-the introduction of harmonised definitions;
-footnotes have in most cases been replaced by comments in additional comment boxes, in a format similar to that provided in the Codex General Standard for Contaminants and Toxins in Food and Feed CXS 193-1995).
2) DON, review of maximum limits
Commission Regulation (EU) No 2024/1022 introduced new MLs (maximum levels) for deoxynivalenol (DON), effective from 1 July 2024. The maximum level of deoxynivalenol in wheat bran not placed on the market for the final consumer is now under discussion.
The revision of the maximum levels concerned only the original parent toxin (DON) on the basis of the ALARA (as low as reasonably achievable) principle, Frans Verstraete indicated, since it was considered ‘premature’ to establish a maximum limit on total DON (sum of DON and modified forms).
1.1) DON, the problems to face
EFSA (European Food Safety Authority), in its previous opinions on DON (2017) and modified mycotoxins, noted that:
-the estimated average chronic dietary exposure, for DON, ‘was found to be above the group TDI (Tolerable Daily Intake) in infants, toddlers and other children and, at high exposure levels, also in adolescents and adults, indicating a potential health concern’; (3)
–‘modified mycotoxins include all forms that differ in their chemical structure from the parent toxin. These include phase I and II metabolites formed in infested fungi or plants used for food and feed production, or food and feed products of animal origin. (…) In addition, modified forms include food and feed processing products and covalent adducts with matrix constituents’(4,5)
Consequently, ‘it is important to continue to collect information on the presence of modified forms, in view of a possible future definition of maximum levels for the sum of DON and modified forms’ (Frans Verstraete). (6)
2) Toxins T-2, HT-2
Regulation (EU) No 2024/1038 has in turn introduced a group guideline maximum levels for T-2 and HT/2 toxins, applicable from 1 July 2024. Not only Member States but also interested parties must communicate:
– to the European Commission, by 1 January 2028, the results of the investigations undertaken and the progress made in the application of prevention measures to reduce contamination by T-2 and HT-2 toxins in oats and oat-based products;
-to EFSA, regularly data on the presence of T-2 and HT-2 toxins in oats and oat-based products (new paragraph 5 in Article 8 of the Contaminants Regulation EU No 2023/915).
3) Ergot alkaloids
The information collected from stakeholders at the Ergot Alkaloids Forum on 13 October 2023 highlighted an increase in the prevalence of ergot sclerotia and ergot alkaloids in cereals due to climatic conditions.
It is not possible, consequently, to achieve the lower maximum levels that were expected to apply from 1 July 2024, as regards:
-ergot sclerotia in unprocessed ergot grains;
-ergot alkaloids in wheat milling products (with ash content < 900 mg/100 g of dry matter);
-products of rye milling and rye placed on the market for the final consumer.
3.1) Postponement of the application of the new limits
The European Commission has therefore decided to postpone the application of the lower maximum levels – by one and four years, respectively – for:
-ergot sclerotia in unprocessed rye grains;
-ergot alkaloids in wheat milling products (with ash content < 900 mg/100 g of dry matter), in rye milling products and in rye placed on the market for the final consumer (EU Regulation No 2024/1808).
4) Alternaria toxins
The recommendation of Commission (EU) 2022/553 limited itself to prescribing the monitoring of the presence of Alternaria toxins in foods (as well as those of glycoalkaloids, furans and PFAS), as seen. (7)
Indicative levels for alternariol (AOH), alternariol monomethyl ether (AME) and tenuazonic acid (TeA) in certain foods have therefore been identified.
The greatest presence of Alternaria toxins in food and feed has also led the European Commission to ask EFSA to review its previous opinion on its toxicity (2011), expected by September 2026.
5) Mycotoxins, emerging risks
The emerging risks relate to the increased exposure of the population to mycotoxins, due to the increasing consumption of ‘plant-based foods’.
Max Rubner Institute (MRI) and BfR (Bundesinstitut für Risikobewertung) have published a study and a scientific risk assessment, respectively, on mycotoxins in plant-based beverages (e.g. almonds, soy, oats). (8,9) Noting that:
-more data are needed on contamination levels and average chronic dietary exposure of various population groups;
-regular consumption of almond drinks with the identified levels of aflatoxins can lead to health damage with a medium probability of onset in children in the age group 0,5 to < 6 years.
6) Methods of sampling and analysis
Methods of sampling and analysis for the control of mycotoxin levels in foodstuffs are defined in Regulation (EU) 2023/2782, as amended by Regulation (EU) 2024/885 with regard to dried herbs, herbal infusions and teas (dried products), and powdered spices.
The new methods shall apply from 1 April 2024. However, the specific requirements for the analytical methods referred to in Regulation (EC) No 1/2029 (Annex II, point 401) already established for methods validated before the entry into force of the Regulation shall continue to apply until 2006 January 4.3.
7) Other mycotoxins, work in progress
Risk analysis linked to dietary exposure to other mycotoxins, Brussels is also working on other mycotoxins:
-enniatine, mandate conferred to EFSA;
-beauvericina, new mandate;
-Phomopsins, new mandate for EFSA;
-sterigmatocystin, sent to EFSA;
-modified forms of DON, etc.
8) Provisional conclusions
To the person of Frans Verstrate, as well as to the institution that he has represented for many years, is credited with playing a leading role in sharing the serious risks – genotoxicity and carcinogenesis (10,11) – associated with the exposure of populations to mycotoxins. Also with the representatives of the numerous countries that participate in the Codex Committee for Food Contaminants. (1)
It is desirable at the same time that the European Commission:
– increases investments in human biomonitoring, to better understand the levels of exposure to various contaminants – mycotoxins and heavy metals, dioxins and PCBs, microplastics, etc. – and the related health risks for different sections of the population;
– expresses courage in adopting the maximum levels of contamination necessary to protect, in particular, children over the age of three who today represent the segment of the population most exposed to such serious risks. (11)
Dario Dongo
Footnotes
(1) EU expert Frans Verstrate on why Codex sets maximum levels for contaminants. Codex Committee on Contaminants in Foods meeting. April 27, 2023 https://youtu.be/51d4lR2ZSbc?si=GhixBL5kmcoTWAeM
(2) Dario Dongo, Alessandra Mei. Food Contaminants Regulation (EU) No 2023/915. FT (Food Times). July 28, 2023
(3) EFSA CONTAM Panel (EFSA Panel on Contaminants in the Food Chain), 2017. Scientific Opinion on the risks to human and animal health related to the presence of deoxynivalenol and its acetylated and modified forms in food and feed. EFSA Journal 2017;15(9):4718, 345 pp. https://doi.org/10.2903/j.efsa.2017.4718
(4) EFSA CONTAM Panel, 2018. Scientific opinion on the appropriateness to set a group health-based guidance value for fumonisins and their modified forms. EFSA Journal 2018;16(2):5172, 75 pp. https://doi.org/10.2903/j.efsa.2018.5172
(5) Giulia Pietrollini. Emerging risks, modified mycotoxins. GIFT (Great Italian Food Trade). 24.11.22
(6) Frans Verstraete. Recent developments and outlook of EU policy on contaminants and related analytical challenges. RAFA, 11th Annual Symposium at Prague (CZ), November 2024
(7) Dario Dongo, Andrea Adelmo Della Penna. PFAS, furans, glycoalkaloids, Alternaria. European Commission ‘recommends’ rather than bans. FT (Food Times). September 23, 2022
(8) MRI. Initiale Charakterisierung ausgewählter Pflanzendrinks hinsichtlich ihrer Qualität und mikrobiologischer sowie chemischer Sicherheit. December 2023 https://tinyurl.com/2avu8pwb
(9) BfR. Mykotoxine in Pflanzendrinks: mehr Daten erforderlich. Stellungnahme 029/2024, 25 June 2024. Doi: 10.17590/20240625-093113-0
(10) Marta Strinati. Mycotoxins, the invisible evil. The ABC. GIFT (Great Italian Food Trade). 24.5.19
(11) Marta Strinati. Mycotoxins, interview with Carlo Brera, ISS expert. GIFT (Great Italian Food Trade). 31.5.19
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
