Regulation (EU) 2026/1825
3-MCPD and glycidyl esters: new MLs from 1 January 2027

The Commission act of 29 July 2026 — CELEX 32026R1825 — rewrites subsections 5.3 and 5.4 of Annex I to Regulation (EU) 2023/915 and adds point (r) to Article 10(1) (stock transition to minimum durability / use-by). It was published in the OJ on 30 July 2026 and enters into force on the twentieth day after publication (19 August 2026). Legal base: Council Regulation (EEC) No 315/93, Article 2(3). This is a contaminants measure — not additives, novel food or health claims.

1. What the act decides

Commission Regulation (EU) 2026/1825 (OJ L, 2026/1825, 30.7.2026; ELI: http://data.europa.eu/eli/reg/2026/1825/oj; CELEX 32026R1825) amends Regulation (EU) 2023/915 in two places:

• Article 1(1) — Article 10(1): updated introductory phrase covering points (a) to (r), plus new point (r): 1 January 2027 for the MLs in Annex I points 5.3.2, 5.3.4, 5.4.2 and 5.4.4;
• Article 1(2) / Annex — full replacement of subsections 5.3 (sum of 3-MCPD and 3-MCPD fatty acid esters, expressed as 3-MCPD) and 5.4 (glycidyl fatty acid esters, expressed as glycidol).

2. Dates: entry into force vs ML application

• Act date: 29 July 2026.
• OJ publication: 30 July 2026.
• Entry into force: twentieth day after publication = 19 August 2026 (Article 2).
• Application of lowered / new MLs in points 5.3.2, 5.3.4, 5.4.2, 5.4.4: from 1 January 2027.
• Article 10(1)(r) transition: food lawfully placed on the market before 1 January 2027 for those four points may remain until the date of minimum durability or use-by date.

Other entries in the rewritten 5.3 / 5.4 sections (general oils, IF/FOF, compound foods) apply in the Annex wording from entry into force — without a separate “from 1 January 2027” note in the level column.

3. Table: baby-food oils and new product MLs

Recital (5): product MLs rest on newly available occurrence data; oil MLs for production were lowered for consistency with typical vegetable-oil content of those foods.

4. General oils and the refined olive-oil clarification

• 5.3.1.1 — coconut, maize, rapeseed, sunflower, soybean, palm kernel and olive oils (refined + virgin mix): 1,250 μg/kg (except virgin olive oils).
• 5.3.1.2 — other vegetable oils/fats, fish and marine oils: 2,500 μg/kg, including refined olive oil and pomace olive oils (clarification in recital 7).
• 5.3.1.3 — mixtures: composition rule under Article 3(1)(c); if quantitative composition is unknown — not more than 2,500 μg/kg.
• 5.4.1 — glycidyl esters in general oils: 1,000 μg/kg (except virgin olive oils).

5. Compound foods >5% fat

Points 5.3.5 and 5.4.5 answer enforcement difficulties under Article 3 of Reg. 2023/915 for foods with added oils (recital 6). Limits refer to fat content (as labelled or as extracted for analysis):

• 5.3.5.1 — only oils listed in 5.3.1.1: 1,250 μg/kg fat;
• 5.3.5.2 — only oils listed in 5.3.1.2: 2,500 μg/kg fat;
• 5.3.5.3 — mixtures: same rule as 5.3.1.3;
• 5.4.5 — glycidyl: 1,000 μg/kg fat.

Excluded from 5.3.5: products in 5.3.3 and 5.3.4, and pre-fried and fried coated meat and fish. Excluded from 5.4.5: products in 5.4.3 and 5.4.4.

6. Analytical point: 3-MBPD and 3-MIPD

The remark to section 5.4 states that the maximum level refers to the sum of glycidyl esters, 3-MBPD fatty acid esters and 3-MIPD fatty acid esters. Recital (8): with indirect methods used by official control laboratories, those compounds are determined together with glycidyl esters due to analytical conversions — particularly in marine oils. For a direct method, lower-bound concentrations apply (values below LOQ treated as zero).

7. What the act does not cover

• No 3-MCPD MLs for pre-fried and fried coated meat and fish — formation factors undetermined; not expected before 2027 (recital 6). A deliberate gap, not a drafting omission.
• The act is not a health-claims, additives or novel-food decision.
• It does not attach a separate 1 January 2027 date to the IF/FOF levels in 5.3.3 / 5.4.3 beyond rewriting the section.

8. Operational checklist for FBOs and importers

1. Map the SKU to the correct 5.3.x / 5.4.x point (bulk oil vs oil “destined for baby food” vs finished baby food vs compound food).
2. For baby-food oils and products under 5.3.4 / 5.4.4, plan compliance from 1 January 2027; document lawful placing on the market for point (r).
3. Check supplier CoAs against 500/250 μg/kg (from 2027) and the 5.3.1.2 clarification for refined olive oil.
4. For >5% fat foods with added oil — apply fat-basis MLs; keep labelled fat consistent with control sampling.
5. Align with the laboratory that glycidyl reporting includes 3-MBPD/3-MIPD per the 5.4 remark.
6. Do not derive health claims or novel-food status from a contaminant ML.

Glossary

ML

Maximum level under Regulation (EU) 2023/915.

3-MCPD

3-monochloropropanediol; the ML covers the sum of free 3-MCPD and its fatty acid esters, expressed as 3-MCPD.

Glycidyl esters

Expressed as glycidol; the ML also includes 3-MBPD and 3-MIPD esters.

IYC

Infants and young children — definitions linked to Regulation (EU) No 609/2013.

Conclusion

Regulation (EU) 2026/1825 tightens protection of infants and young children against 3-MCPD and glycidyl esters: from 1 January 2027, oils for baby-food production drop to 500 / 250 μg/kg, and baby food / cereal-based products receive their own MLs of 50 / 25 μg/kg. In parallel, the act hardens enforcement for compound foods (>5% fat), clarifies refined olive oil and expands the analytical definition of the glycidyl ML. It deliberately leaves coated fried meat and fish without 3-MCPD MLs until formation factors are known.

Primary sources

1. Commission Regulation (EU) 2026/1825 — CELEX 32026R1825; ELI eli/reg/2026/1825/oj; OJ L, 2026/1825, 30.7.2026.
2. Regulation (EU) 2023/915 — maximum levels for certain contaminants in food.
3. Council Regulation (EEC) No 315/93 — Article 2(3) (legal base).
4. EFSA CONTAM 2016 — MCPD and glycidyl esters (EFSA Journal 2016;14(5):4426).
5. EFSA CONTAM 2018 — update on 3-MCPD (EFSA Journal 2018;16(1):5083).