New proposed maximum limits for polycyclic aromatic hydrocarbons (PAH) in fish

Published by SIPA

7 January 2026: The European Commission has proposed new maximum limits for polycyclic aromatic hydrocarbons (PAH) in smoked fishery products.

Background: In January 2025 the Commission ran a targeted consultation on new, reduced, maximum PAH limits. SIPA responded to the proposal through FRUCOM. The points raised in the FRUCOM response included 1) that the proposal to half the maximum limits (MLs) was arbitrary and not based on science (the Commission did not provide any new data), and 2) that a large proportion of the traditionally smoked non-salmonid fish was likely to be non-compliant with the new reduced MLs.

The latest proposal: Following discussions in the Working Group on Industrial and Environmental Contaminants, the Commission has now (December 2025) proposed maximum limits as follows:

Current MLs (µg/kg) MLs proposed
in January 2025
(µg/kg)
Latest proposal
December 2025
(µg/kg)
 B(a)P PAH4  B(a)P PAH4 B(a)P PAH4
 5.1.7 Smoked fishery products except products listed in 5.1.8  2.0  12.0  1.0  6.0  1.5  10.0
 5.1.8 Smoked sprats and canned smoked sprats (Sprattus sprattus)  5.0  30.0  3.0  18.0  4.0  24.0
 5.1.9 Smoked bivalve molluscs  6.0  35.0 3 .0  18.0  5.0  30.0 

The MLs in row 5.1.7 will also apply to fishery products containing smoked ingredients.

You can access the full text of the latest proposal below.

PAH proposal December 2025
2025-12-PAH-text.pdf
Download
PAH proposal December 2025 annex
2025-12-PAH-annex.pdf
Download