Regulation (EU) 2022/2002 – effective January 1, 2023, partially reforming Reg. EC 1881/2006 on food contaminants-introduces new thresholds for dioxins and dioxin-like PCBs on certain meat and meat products, shellfish, eggs of all poultry species, and milk and dairy products. (1)
Behind lofty words and triumphalist press releases is the crisis of food security management and democracy in the European Union.
1) Dioxins and dioxin-like PCBs, persistent environmental pollution.
Dioxins andpolychlorinated biphenyls (PCBs) are toxic chemicals that spread through the air and accumulate in water and soils, with a long persistence in the environment. The term ‘dioxins’ refers to two groups of compounds, polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs).
While dioxins are still generated by some thermal and industrial processes as unwanted and often unavoidable byproducts, PCBs have been widely used in numerous industrial applications (e.g., plasticizers, sealants and plastics, noncombustible liquids in heat exchangers, electrical transformers and capacitors).
Twelve PCBs have mechanisms of action and biological effects similar to dioxins(dioxin-like PCBs). Although their use was banned in many countries in the late 1980s, the total global production of PCBs is estimated (by default) at 1.2-1.5 million tons.
2) Chemical safety of food and public health
The chemical safety of food is still exposed, even in Europe, to serious risks from dioxin and dioxin-like PCB contamination. Chemicals that are carcinogenic and genotoxic, that is, capable of damaging DNA, as well as toxic to the nervous and immune systems. They are also endocrine disruptors, which can impair reproductive function.
EFSA Panel on Contaminants in the Food Chain (CONTAM), starting in 2008, began assessing human and animal exposure to dioxins and dioxin-like PCBs. Considering:
- Data from EU member states’ food and feed monitoring,
- exposure of specific population groups (e.g., infants, children, people on specific diets),
- exposure levels of animals (farm and domestic) and dioxin carryover from feed to food of animal origin. (2)
2.1) EFSA, risk assessment on dioxins and dioxin-like PCBs in food and feed.
In 2018, EFSA published the first comprehensive risk assessment on dioxins and dioxin-like PCBs in food and feed, where it confirmed the conclusions of previous scientific opinions to highlight that:
- dietary exposure to dioxins and dioxin-like PCBs (environmental pollutants present at low levels in food and feed) is a health concern,
- a TWI(tolerable weekly intake) of 2 pg of TEQ (toxic equivalent) per kg of body weight should be established for the sum of dioxins and dioxin-like PCBs. Seven times lower dose than hitherto established,
- some toxicity equivalent factors established by WHO(World Health Organization) in 2005 need to be reviewed to take into account new in vivo and in vitro data,
- data received from European countries indicate an overshoot of the new EFSA level of tolerable intake in all age groups. (3)
2.2) Food safety
Chronic human dietary exposure to dioxins and dioxin-like PCBs-estimated by EFSA (2018), based on data collected from member states-is well above the tolerable weekly intake for all age groups:
- the TWI established by EFSA in 2018 is exceeded 5 to 15 times in children, adolescents, adults and the elderly,
- the foods that contribute most to the average dietary exposure for most age groups, in European countries, are fish (particularly fatty fish), cheese, and meat from farm animals.
3) Dioxins and PCBs, the new EU thresholds.
Reg. EU 2022/2002, on maximum levels of dioxins and the sum of dioxins and dioxin-like PCBs in foodstuffs:
- Introduces contamination thresholds on foods of sporadic consumption. Meat and meat products from goats, horses, rabbits, wild boar, game birds, deer; liver from goats and horses; game birds,
- applies to all poultry eggs (with the mysterious exception of goose eggs) the maximum content already stipulated for chicken eggs,
- extends to the muscle of the abdomen of crabs and crustaceans the threshold already established for the muscle of their appendages,
- Reduces the thresholds of dioxins and the sum of dioxins and dioxin-like PCBs on fats in milk and dairy products. From 2.5 pg/g and 5.5 pg/g, respectively, to 2.0 pg/g and 4.0 pg/g, respectively.
4) Public health at risk
The agricultural and industrial lobbies , in all evidence, had the upper hand over the European Commission’s DG Sante(Directorate-General for Health and Food Safety). Which has tried to justify its inaction, as previously reported, has not followed up effectively on the risk analysis performed by EFSA in 2018. (4)
The ‘new thresholds’ for food contamination, which came into effect five years after a serious public health problem was established, are wholly inadequate with respect to the need to restrict consumer exposure to toxic chemicals within limits set by the European Food Safety Authority.
5) Interim Conclusions
The most vulnerable segments of the population – YOPI. Young, Old Pregnant Immunosuppressed – are exposed to genotoxic carcinogens exponentially higher (+500-1500%) than ‘tolerable’ weekly doses. Yet:
- maximum levels on milk and dairy products, a prime source of dietary exposure to dioxins and dioxin-like PCBs, are just shaded (-20 percent),
- Thresholds on fish, meat, eggs are unchanged. What about the feeds?
Dario Dongo and Maria Ada Marzano
Notes
(1) Commission Regulation (EU) 2022/2002 of 21 October 2022 amending Regulation (EC) No 1881/2006 as regards maximum levels of dioxins and dioxin-like PCBs in certain foodstuffs https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32022R2002&qid=1675341448718
(2) EFSA. Dioxins and PCBs https://www.efsa.europa.eu/en/topics/topic/dioxins-and-pcbs
(3) EFSA, CONTAM Panel (2018). Risk for animal and human health related to the presence of dioxins and dioxin-like PCBs in feed and food. EFSA Journal 2018;16(11):5333. doi:
https://doi.org/10.2903/j.efsa.2018.5333
(4) Dario Dongo. Dioxins and PCBs in food, the great hoax. GIFT (Great Italian Food Trade). 4.12.22
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.