Regulation (EU) 2022/2002 - in force since 1 January 2023, as a partial reform of reg. EC 1881/2006 on food contaminants – introduces new thresholds for dioxins and dioxin-like PCBs on certain meats and meat-based products, crustaceans, eggs of all poultry species, milk and dairy products. (1)
Behind high-sounding words and triumphalistic press releases, the crisis in the management of food safety and democracy in the European Union.
1) Dioxins and dioxin-like PCBs, persistent environmental pollution
Dioxins and polychlorinated biphenyls (polychlorinated biphenyls, PCBs) are toxic chemicals that spread through the air and accumulate in water and soil, 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 the dioxins are still generated by some thermal and industrial processes, as unwanted and often unavoidable by-products, i PCB they have been widely used in numerous industrial applications (e.g. plasticizers, sealants and plastics, non-combustible liquids in heat exchangers, electrical transformers and capacitors).
Twelve PCBs have similar mechanisms of action and biological effects to dioxins (Dioxin-like PCBs). Although their use was banned in many countries in the late 80s, the total global production of PCBs is estimated (underestimated) at 1,2-1,5 million tons.
2) Chemical food safety and public health
Chemical safety of food is still exposed, even in Europe, to serious risks associated with contamination by dioxins and dioxin-like PCBs. Carcinogenic and genotoxic chemicals, i.e. capable of damaging DNA, as well as toxic to the nervous and immune systems. They are also endocrine disruptors, capable of compromising reproductive function.
EFSA Panel on Contaminants in the Food Chain (CONTAM), starting in 2008, started evaluating human and animal exposure to dioxins and dioxin-like PCBs. Considering:
- data from EU Member State monitoring of food and feed,
- the exposure of specific groups of the population (e.g. infants, children, people following specific diets),
- the levels of exposure of animals (farm and domestic) and of carry-over of dioxins 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 has published the first overall risk assessment on dioxins and dioxin-like PCBs in food and feed, confirming 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) poses a health concern,
- you need to establish a TWI (tolerable weekly intake) equal to 2 pg of TEQ (toxic equivalent) per kg of body weight, for the sum of dioxins and dioxin-like PCBs. Dose seven times lower than that hitherto established,
- certain equivalent toxicity factors established by WHO should be re-examined (World Health Organization) in 2005, to take into account new in vivo and in vitro data,
- data from European countries indicate that the new EFSA level of tolerable intake has been exceeded in all age groups. (3)
2.2) Food safety
Food exposure exposure to dioxins and dioxin-like PCBs – according to EFSA estimates (2018), based on data collected by the Member States – is much higher than 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), cheeses and meat from farmed animals.
3) Dioxins and PCBs, the new EU thresholds
The reg. EU 2022/2002on maximum levels of dioxins and the sum of dioxins and dioxin-like PCBs in foodstuffs:
- introduces contamination thresholds on food for sporadic consumption. Meat and meat products from goats, horses, rabbits, wild boars, game birds, deer; liver of goats and horses; feathered game,
- applies to all poultry eggs (with the mysterious exception of goose eggs) the maximum level already established for hen's 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 for dioxins and the sum of dioxins and dioxin-like PCBs on milk fats and dairy products. From 2,5 pg/g and 5,5 pg/g, respectively, to 2,0 pg/g and 4,0 pg/g.
4) Public health at risk
Le lobby agricultural and industrial, in all evidence, had the upper hand on DG Sante (Directorate-General for Health and Food Safety) of the European Commission. Which tried to justify its inaction, as has already been reported, did not give any effective follow-up to the risk analysis carried out by EFSA in 2018. (4)
The 'new thresholds' of food contamination, which entered into force five years after a serious public health problem was identified, are wholly inadequate with respect to the need to restrict consumer exposure to toxic chemicals within the limits set by the European Food Safety Authority.
5) Provisional conclusions
The most vulnerable groups of population – YOPI. Young, Old Pregnant Immunosuppressed – are exposed to genotoxic carcinogens exponentially higher (+500-1500%) than the 'tolerable' weekly doses. Nevertheless:
- the maximum levels on milk and dairy products, one of the first sources of dietary exposure to dioxins and dioxin-like PCBs, have barely faded (-20%),
- the thresholds on fish, meat and eggs are unchanged. And the feed?
Dario Dongo and Maria Ada Marzano
Footnotes to the story
(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 big joke. 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.
Maria Ada Marzano
Veterinarian specialist in inspection of food of animal origin and research doctor in animal nutrition and food safety.
 2022/2002 introduce dal primo gennaio 2023 nuove soglie di diossine e PCB diossina-simili su alcune carni e prodotti a base di carne, crostacei, uova di ogni specie avicola, latte e latticini.){kind=link}