New contaminant limits in oils and processed foods EU 2026: what manufacturers and refiners must do

Key data

Manufacturers and refiners of vegetable oils operating in the EU have a new compliance obligation: to adapt their production processes and analytical controls to the revised thresholds established by Regulation (EU) 2026/1825, published on 30 July 2026. This regulation modifies Regulation (EU) 2023/915, which is the general framework for maximum limits of contaminants in food in force in the European Union.

The change is significant: the regulated contaminants—3-MCPD, 3-MCPD esters of fatty acids and glycidyl esters of fatty acids—are inevitably generated during high-temperature refining of vegetable oils and fats. This makes the entire value chain of the sector, from the refinery to the final product manufacturer, a direct subject of this regulation.

What does this regulation establish?

Regulation (EU) 2026/1825 updates the maximum permitted limits of three families of process contaminants in certain foods. These contaminants do not come from added ingredients, but form during high-temperature processing of vegetable oils and fats, especially during the refining phase.

The regulation modifies Regulation (EU) 2023/915, which has been the reference text for contaminant limits in food in the EU. The update is based on the latest scientific assessments by the EFSA (European Food Safety Authority), which have reviewed dietary exposure and the risk associated with these compounds.

The three regulated contaminants are:

• 3-monochloropropanediol (3-MCPD): a compound that forms during the refining of vegetable oils, especially palm oil. Classified as possibly carcinogenic.
• 3-MCPD esters of fatty acids: bound forms of 3-MCPD present in refined oils and derived products.
• Glycidyl esters of fatty acids: compounds with genotoxic and carcinogenic potential that also form during high-temperature refining.

Food products for which maximum limits are established or updated include:

• Palm oil and other refined vegetable oils
• Margarines and vegetable fats for food use
• Infant foods (starter formulas, follow-on formulas and cereal-based foods)
• Snacks and processed foods containing refined vegetable oils or fats

The regulation establishes that non-compliance with these maximum limits may result in product withdrawal from the European market, with the reputational, logistical and economic costs that this entails.

Economic and operational impact

The impact of this regulation is not measured in fees or published direct sanctions, but in the cost of operational adaptation and the risk of product withdrawal. For affected companies, the main cost vectors are:

• Adaptation of production processes: refiners will need to review and possibly modify their temperature, time and pressure parameters during refining to reduce the formation of these contaminants.
• Strengthening of analytical controls: it will be necessary to implement or intensify analyses of 3-MCPD, 3-MCPD esters and glycidyl esters in production batches, with the associated laboratory costs.
• Review of suppliers and raw materials: processed food manufacturers will need to require their oil and fat suppliers to comply with the new limits, which may involve changes in the supply chain.
• Risk of market withdrawal: the cost of a product withdrawal in the EU—including reverse logistics, destruction, communication and reputational damage—can far exceed the cost of preventive adaptation.

Companies that already complied with Regulation (EU) 2023/915 must verify whether the new thresholds of Regulation 2026/1825 are stricter and whether their current contaminant levels remain within the permitted margin.

Who does it affect?

• Vegetable oil refiners (especially palm, sunflower, rapeseed and soy oil) operating or trading in the EU.
• Manufacturers of margarines and vegetable fats for food and industrial use.
• Infant food producers (starter formulas, follow-on formulas and cereals for babies), a sector with typically stricter thresholds due to consumer vulnerability.
• Manufacturers of snacks and processed foods that use refined vegetable oils or fats in their recipes.
• Importers and distributors of these products in the European market, who must ensure the compliance of products they introduce into the EU.
• Quality and food safety managers (QA/QC) in sector companies, who will need to update their control plans and technical purchasing specifications.

Practical example

A Spanish manufacturer of industrial biscuits and pastries that uses refined palm oil as the main ingredient is at the center of the scope of this regulation. Their specific situation would be as follows:

Until now, this manufacturer purchased refined palm oil from a supplier with certification compliant with Regulation (EU) 2023/915. With the entry into force of Regulation 2026/1825, they will need to:

1. Request from their palm oil supplier the new analysis certificates proving compliance with the updated limits for 3-MCPD and glycidyl esters.
2. Review whether their final product (the biscuit or pastry) exceeds the new maximum limits applicable to "processed foods containing refined vegetable oils or fats".
3. If the final product exceeds the new thresholds, they will need to reformulate the recipe (by reducing the percentage of palm oil, replacing it with another oil with lower contaminant content, or requiring the supplier to provide oil with a higher degree of purity).

Failing to act in time exposes this manufacturer to an inspection by the competent authority that could result in the withdrawal of their products from European shelves.

What should companies do now?

1. Identify if your product is within the scope: check if you manufacture or market refined vegetable oils, margarines, infant foods or processed foods with vegetable fats in the EU.
2. Compare your current levels with the new limits: request analyses of 3-MCPD, 3-MCPD esters and glycidyl esters from your laboratory or supplier and compare them with the thresholds of Regulation 2026/1825.
3. Update technical purchasing specifications: include the new limits as a mandatory requirement in contracts with vegetable oil and fat suppliers.
4. Review and update your HACCP plan: incorporate the new limits as a critical control point if not already considered, especially in refining or frying processes.
5. Communicate with your quality team and legal advisor: ensure that QA/QC managers and regulatory compliance advisors are aware of the new thresholds and their implications.
6. Monitor the entry into force date: the regulation does not specify a specific application date; stay alert to official communications from the European Commission or the national competent authority (AESAN in Spain).

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601825