On 13 April 2022, the French Ministry of Ecological Transformation approved the directive Arrêté du 13 avril 2022 - "Prohibition of the use of mineral oils on packaging and printed matter intended for public use" - which was published in the French Official Gazette on 3 May 2022, and the first phase of the directive requires that it will be implemented on 1 January 2023. The first phase of the Directive will be implemented on 1 January 2023.

  Compared to the Draft, the types of mineral oil restricted by the Directive on the Prohibition of the Use of Mineral Oils in Packaging and Printed Matter intended for Public Use remain unchanged, i.e. the mineral oils prohibited include:


  Aromatic hydrocarbon mineral oils containing 1 to 7 aromatic rings MOAH

  Saturated hydrocarbon mineral oils containing 16 to 35 carbon atoms, MOSH


  The limits and implementation times have been revised compared to the Draft Directive, with the following requirements.


  Phase I: Aromatic hydrocarbon mineral oils MOAH content in inks should be ≤ 1% by 31 December 2024.


  Phase II: From 1 January 2025, the MOAH content of aromatic hydrocarbon mineral oils containing 1 to 7 aromatic rings should be ≤ 0.1% and the content of aromatic hydrocarbon mineral oils containing 3 to 7 aromatic rings should be ≤ 1 ppm in inks; the MOSH content of saturated hydrocarbon mineral oils in inks should be ≤ 0.1%.


  The Directive does not apply to inks containing mineral oils that have been licensed for use in advertising printing and packaging in the EU.


  Implementation date: The Directive enters into force on 1 January 2023. Packaging and printed matter manufactured or imported before the date of entry into force of the Directive is given a period of no more than 12 months for disposal of stock.


  Packaging and printed matter manufactured or imported before 1 January 2025 will also be given a period of no more than 12 months to dispose of stocks if they comply with the provisions of the previous authorisation.


  In view of the high level of concern and intensive legislation on mineral oils in the EU market, especially in Germany and France, it is recommended that relevant companies focus on monitoring mineral oil contamination in food contact packaging, especially the risk of mineral oil in printed products and use of adhesive products.