The Phenomenon of Export Rejections in the European Market
The phenomenon of export rejections in the European market began with notifications from the European Union Rapid Alert System for Food and Feed (RASFF) in 2020 regarding the detection of ethylene oxide (EtO) residues in sesame seeds originating from India at extremely high levels of 186 mg/kg. This value far exceeded the European Union’s Maximum Residue Limit (MRL) of 0.5 mg/kg.
These notifications continued in the following years, including findings of EtO in locust bean gum in 2021 and in instant noodles and ice cream in 2022. In addition to EtO, several Indonesian tea products also faced export rejections due to the presence of 2,6-diisopropylnaphthalene (2,6-DIPN) and 9,10-anthraquinone (9,10-AQ) residues exceeding the MRLs set by importing countries. In a specific case, in 2017 Indonesian tea products were rejected by the European Union due to the presence of 9,10-anthraquinone (9,10-AQ) at 0.04 ppm, exceeding the EU MRL of 0.02 ppm.
In 2021, Indonesian instant noodles were rejected by Germany due to the detection of 2-chloroethanol (2-CE) calculated as total EtO. In 2022, Taiwan rejected Indonesian instant noodles and tea after detecting EtO, 2,6-DIPN, and 9,10-AQ. In July 2022, there was also a EURASFF notification regarding Indonesian jasmine tea due to anthraquinone content. Similar rejections occurred in Hong Kong, Singapore, and Malaysia. The sources of contamination are suspected to originate from imported raw materials treated with EtO (such as chili, cumin, and onions from India), recycled paper packaging, as well as the production environment. Sumber: (BPOM)
Hazards of EtO, 9,10-AQ, and 2,6-DIPN
- Ethylene Oxide (EtO)
Ethylene oxide is a toxic, colorless gas that is highly reactive and flammable, commonly used as a fumigant and sterilizing agent. From a health perspective, EtO exposure may cause irritation to the eyes, skin, and respiratory tract, as well as symptoms such as dizziness and nausea. Toxicologically, EtO is genotoxic and mutagenic and has been classified by the International Agency for Research on Cancer (IARC) as Group 1 (Carcinogenic to Humans). Due to its genotoxic carcinogenic nature, EtO does not have an Acceptable Daily Intake (ADI) or Acute Reference Dose (ARfD). The European Union therefore applies the precautionary principle, restricting its residue to the limit of quantification (LOQ). - 9,10-Anthraquinone (9,10-AQ)
9,10-Anthraquinone belongs to the polycyclic aromatic hydrocarbon (PAH) group. This compound is used in the paper industry and as a bird repellent pesticide, and may also form through incomplete combustion processes. Based on animal studies, anthraquinone has been shown to cause tumors in the kidneys, liver, bladder, and thyroid. IARC classifies 9,10-AQ as Group 2B (Possibly Carcinogenic to Humans), while the US EPA categorizes it as “Likely to be Carcinogenic to Humans.” The European Union sets the MRL for anthraquinone in tea at 0.02 mg/kg.
- 2,6-Diisopropylnaphthalene (2,6-DIPN)
2,6-DIPN is a compound used as a sprout inhibitor in potatoes and may migrate from recycled paper packaging materials into food. Toxicological evaluations indicate that 2,6-DIPN is not considered carcinogenic to humans and has low acute toxicity, with an oral LD50 greater than 5000 mg/kg body weight. The United States Environmental Protection Agency (US EPA) has established a Reference Dose (RfD) of 1 mg/kg/day. Nevertheless, the compound is considered hazardous to aquatic environments. Sumber: (BPOM)
Applicable Regulations
- In Indonesia, Minister of Agriculture Regulation No. 43 of 2019 prohibits the use of ethylene oxide. Meanwhile, 2,6-DIPN and 9,10-AQ have not yet been specifically regulated as pesticides in national regulations, although 9,10-AQ is permitted as a paper modifier under BPOM Regulation No. 20 of 2019.
Regulations in Various Countries:
- European Union: Residue regulations refer to Regulation (EC) No. 396/2005, as well as Regulation (EU) No. 1146/2014, which sets the MRL for anthraquinone in tea. EtO is restricted to the LOQ level and calculated as total EtO plus 2-CE.
- United States: Regulations are outlined in 40 CFR 180.151, with limits of 7 mg/kg for EtO and 940 mg/kg for 2-CE, along with regulations for 2,6-DIPN in CFR 180.590.
- Canada: Applies the Pest Control Products Act and sets different MRLs for EtO and 2-CE, with a general MRL of 0.1 mg/kg when no specific limit exists.
- Japan and Korea: Apply a uniform limit of 0.01 mg/kg for pesticides not specifically regulated.
- Taiwan: Requires that unregistered pesticides must not be detected.
Sumber: (BPOM)
How SIG Can Help
As an SNI ISO/IEC 17025–accredited laboratory, SIG can assist you in quantitatively mitigating the following contaminants:
- Ethylene Oxide (EtO)
- 2-Chloroethanol (2-CE)
- 9,10-Anthraquinone (9,10-AQ)
- 2,6-Diisopropylnaphthalene (2,6-DIPN)
These services support the quality assurance of your products, including food products, seasonings, spices, coffee & tea, and even medical devices, using GC-MS/MS and GC-FID instrumentation, internationally recognized analytical methods.
For further information regarding PFAS contamination testing services and other consultations, please contact us at 082111516516 and visit our official website at siglaboratory.com , or visit us directly at Graha SIG, Jl Rasamala No. 20, Taman Yasmin, Bogor, Jawa Barat 16113.
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