Consumer tips on health and food safety
In Germany, pursuant to section 13 (5) of the Food and Feed Code (Lebensmittel- und Futtermittelgesetzbuch) (previously section 9 (4) of the Foodstuffs and Commodities Act [Lebensmittel- und Bedarfsgegenständegesetz]), the Federal Environment Ministry is the lead authority responsible for preventing risks to consumers arising from food that has been exposed to air, water and soil contaminants (known as environmental contaminants).
These contaminants, also called “undesirable substances”, include environmental contaminants such as the heavy metals lead and mercury, polychlorinated biphenyls (PCBs), dioxins and other organochlorine compounds. Under German law, only food that is safe may be sold in Germany. Responsibility for the safety of food lies with food business operators who produce, transport, store or sell this food. The competent food inspection authorities of the Länder regularly monitor compliance with the relevant legal provisions.
However, not all food that is consumed is subject to official monitoring. This includes food that is not sold commercially, such as fruits and vegetables from household gardens, mushrooms picked in the wild or freshwater fish caught for personal consumption. However, consumers can play their own part in reducing individual intake of undesirable substances through food.
A balanced and varied diet is often the best way to minimise the unavoidable intake of undesirable substances through food.
The following consumer tips provide additional guidelines for the general public to help individually reduce the intake of environmental contaminants through food:
Limit consumption of wild mushrooms
The lead, cadmium, mercury and even radionuclide content in wild mushrooms can be much higher than in farmed mushrooms like button mushrooms or in other plant-based food. People who eat wild mushrooms regularly should not consume more than 200 to 250 grams per week (based on the fresh weight). Children should eat even less depending on their body weight. However, even larger quantities of fresh wild mushrooms do not pose a risk if only consumed on occasion.
Eat fish with relatively low mercury content if pregnant or breastfeeding
Fish is an important source of nutrients and should be an integral part of our diet. Fish can be contaminated with mercury to varying degrees depending on water pollution levels, the age and the species of fish. Mercury levels in predatory fish are generally higher than in non-predatory fish. EU legislation defines maximum levels of mercury for fish and fisheries products. As long as these maximum levels, which are monitored by the food inspection authorities of the Länder, are not exceeded, health risks for the general public with typical eating habits are very unlikely. However, women who are pregnant or breastfeeding as well as their unborn and new-born babies are especially at risk from the toxic effects of mercury. For this reason, women who are pregnant or breastfeeding are advised to mainly consume fish with comparatively low mercury levels and to avoid the following types of fish (and products made from them) that potentially contain more mercury on the German market: shark (also sold as "Schillerlocken", or strips of smoked dogfish), escolar, eel, spined loach, swordfish, Atlantic and Greenland halibut, pike, monkfish, tuna and Atlantic redfish.
Follow regional advice on freshwater fish caught for personal consumption
Stable compounds such as dioxins and PCBs have been accumulating in riverbeds for many years. As a result, wild fish in rivers can still ingest considerable amounts of harmful dioxins and PCBs through the food chain. This is why freshwater fish still contain high levels of contaminants even though significantly fewer dioxins and PCBs are discharged into the environment today than in the past. Dioxins and PCBs accumulate in the fatty tissue of fish as they are particularly persistent and highly soluble in fat. Eels are particularly fatty fish. Levels above the maximum set by law for dioxins and PCBs are relatively common in freshwater fish. People who fish (and their families) should therefore check the contamination level of fish in the respective river sections with the competent Länder authorities.
Current data from official monitoring activities are now being examined to assess whether and how the consumer tip should reflect the potential levels of per- and polyfluoroalkyl substances (PFAS) in these foods. In 2020, EFSA published a health assessment and a specification of the tolerable weekly intake (TWI) for the PFAS compounds perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA) and perfluorohexane sulfonic acid (PFHxS). On the basis of new scientific studies, a TWI of 4.4 nanograms per kilogram (ng/kg) of body weight was identified for the sum of the four PFAS compounds which EFSA considers to have the greatest impact in terms of exposure through food. The Federal Institute for Risk Assessment (BfR) has reviewed the TWI of 4.4 ng/kg per week as derived by EFSA for the sum of the four long-chain compounds PFOS, PFOA, PFNA and PFHxS and recommends using this TWI for future assessments of PFAS levels in foods (BfR Opinion no. 020/2021 of 28 June 2021 “PFAS in food: BfR confirms critical exposure to industrial chemicals”). In addition to meat and meat products, fish and fisheries products are among the food types with the highest exposure levels. To date, there is no legislation laying down maximum levels for PFAS in foodstuffs. As is the case with dioxins, freshwater fish tend to exhibit comparatively high levels of PFAS. This is why anglers (and their families) in particular should check the contamination level of fish in the respective river sections with the competent Länder authorities. A number of Länder provide guidance to fishers on their websites.
What to be aware of if you eat offal
Offal from wild game
In contrast to the offal of many farm animals, which show decreasing levels of heavy metal contamination, offal from wild game, such as rabbits, deer and wild boar, may be significantly contaminated with heavy metals, dioxins and polychlorinated biphenyls (PCBs). As a general rule, the offal of wild animals should only be consumed on occasion. In particular, wild boar liver or other offal of wild boar may also show high levels of per- and polyfluoroalkyl substances (PFAS), such as perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), and can significantly contribute to overall exposure to these substances. This is why the Federal Environment Ministry advises against eating offal from wild boar on a regular basis. As a precaution, women of childbearing age, including women who are pregnant or breastfeeding, and children should avoid eating offal from wild boar.
The term sheep liver is a collective term which refers to liver from lambs and adult ewes and rams. To date, the Federal Institute for Risk Assessment (BfR) has collected 140 results of sheep liver samples from six different Länder. The levels of dioxins and PCBs are very high in most of the samples, with the majority exceeding the maximum levels applicable in the EU. The BfR therefore recommends refraining from the consumption of sheep liver as a precaution.
Canned cod liver in oil
Studies have shown that canned cod liver in oil often contains high levels of dioxins and PCBs. In early July 2008, an EU-wide maximum level (limit value) of 25 picograms per gram wet weight in total was introduced for dioxins and dioxin-like PCBs in fish liver and fish liver products. This maximum level was replaced in January 2012 with a limit value of 20 picograms per gram wet weight, also in total, for dioxins and dioxin-like PCBs. However, even this lower maximum level does not ensure consumer health protection in cases of regular consumption of cod liver in oil, since at current exposure levels an exceedance of the tolerable intake for dioxins and dioxin-like PCBs cannot be ruled out. In the interest of preventive health protection, the consumption of cod liver in oil (usual size of a portion of 150g) should therefore be restricted to a maximum of every two months.
This consumer tip is under review as the European Food Safety Authority (EFSA) established a new health-based guidance value for dioxins and PCBs in 2018 in response to new toxicological findings. In addition, current data from official monitoring activities are also being used to assess whether and how the consumer tip should reflect the potential levels of per- and polyfluoroalkyl substances (PFAS), including perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA), for this type of food. In 2020, EFSA derived a tolerable weekly intake (TWI) for per- and polyfluoroalkyl substances (PFAS). For the sum of the four PFAS compounds perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), perfluorononanoic acid (PFNA) and perfluorohexane sulfonic acid (PFHxS), a TWI of 4.4 nanograms per kilogram of body weight applies. The Federal Institute for Risk Assessment has reviewed the TWI of 4.4 ng/kg per week as derived by EFSA for the sum of the four long-chain compounds PFOS, PFOA, PFNA and PFHxS and recommends using this TWI for future assessments of these PFAS levels in foods.