On 5 February, the NVLR (Dutch Association for Food Law) organised an afternoon seminar on contaminants in food: what have 33 years of European framework legislation delivered? Representatives from the government, laboratories, trade and legal practice discussed how legislation, analytical data and day-to-day practice intersect - and at times clash. MVO took part in the meeting, which was held in Arnhem.

33 years of contaminant policy

Over more than three decades, European contaminant policy has evolved into a refined but also complex system. What began as a framework for food safety now touches on measurement uncertainty, international trade and differing enforcement practices. The NVLR seminar highlighted how closely these elements are intertwined - and why continued dialogue between all parties involved remains essential.

Perspectives from the speakers

Bob Duijnhouwer (NVWA) provided an overview of contaminants and the relevant legislation, stressing that food safety is rarely a black-and-white matter. One comparison stood out: just as a police officer does not look at the speed limit in isolation but also considers the circumstances, enforcement requires context, risk-based judgement and proportionality.

Gerard Kramer (Nutrilab) explored what lies behind a measurement result. Measuring is knowing - but it also involves taking a representative sample, homogenising it, selecting the appropriate analytical method and correctly interpreting measurement uncertainty. Particularly around maximum levels or action limits, that uncertainty can have significant consequences for interpretation and decision-making.

Marijn Albus (Verstegen Spices & Sauces) shared experiences from the international spice trade, pointing to practical bottlenecks such as differences in sampling methods, drying factors, timelines and varying national approaches within the EU.

Finally, Marco Balhuizen (Nysingh) discussed relevant case law. Action limits are signal values, not binding legal standards. Decisions must always be properly substantiated and proportionate, with explicit attention to measurement uncertainty and exposure.

Discussion

The discussions acknowledged that enforcement is sometimes viewed critically, but also that supervisory authorities are seeking workable instruments in situations where fixed legal standards are lacking. The oils and fats sector was cited as an example of constructive exchange on issues such as MOSH/MOAH and 3-MCPD, aimed at realistic approaches that effectively protect public health.