“That’s where Öko-Test needs to work cleaner!”
Herewith we would like to comment as a long-time producer of hemp foods, on the article published by Öko-Test, especially the evaluation of the hemp oils “tested” there. Our brand quality “Hemp Farm” hemp oil was (unfortunately) not included in this test. Therefore, we are (unfortunately) not directly affected and can therefore also legally (unfortunately) no counter-representation claim.
However, we would like to take this opportunity to thank the statements already made by other well-known manufacturers and endorse their comments.
Product tests should give customers a reliable impression of product quality. In our opinion, Öko-Test has not succeeded in this in any way.
There are strict requirements on the part of the legislator for the production and marketing of foodstuffs. We consider this to be reasonable and sensible. Öko-Test, on the other hand, based its product test on much stricter evaluation criteria than those specified by the legislator. While this may be appropriate for an ambitious ecological stance, it is generally not within the bounds of reality, correctness and reasonableness.
This applies in particular to the evaluation of the tested foods with regard to the presence of mineral oil residues (MOSH/MOAH).
Currently, only a guidance value of 13 mg/kg MOSH applies to edible oils. MOAH (classified as carcinogenic) should not be detected. Orientation values are in no way the same as limit values. Why Öko-Test considers even a value of less than 4 mg/kg MOSH to be “elevated” for the evaluation of products is incomprehensible. Here apparently in addition the recommendation value for seeds is falsely applied to oils. Especially since only a simultaneous presence of MOSH and MOAH suggests a contamination with mineral oil residues. To make matters worse, it is currently not possible to distinguish between contamination with MOSH and POSH (Polyolefinic Oligomeric Saturated Hydrocarbons). This means that higher measurement results can also falsify the real value.
Similarly, we consider the devaluation of products by one grade when exhausting 25-50% of the legal limits for PAHs (Polycyclic Aromatic Hydrocarbons) to be completely excessive. Legal limits are set to protect consumers and always include appropriate safety factors.
From our point of view, both criteria falsely convey a risk to the consumer’s health.
We as a food producer are already sensitized to this topic, take this aspect into account in the risk assessment and have our hemp oils tested by regular analyses.
With regard to THC in hemp seeds, the article also publishes simply false statements. Contrary to what is presented, there are also traces of cannabinoids, including THC, in the hemp seed itself (Ross et al., 2000)[1]. Furthermore, “contamination” by other plant components (flowers and leaves) occurs during harvesting, drying and cleaning.
It is therefore unavoidable that hemp seeds naturally contain traces of cannabinoids, THC and CBD.
Of course, we carefully select our raw materials (hemp seeds) to keep the content of cannabinoids, including THC, as low as possible. But despite our most intensive cleaning (ALARA principle) of all hemp seed batches before processing, minimal traces of both (fat-soluble) cannabinoids remain in the hemp seed products, with an 8-10 times higher proportion of CBD to THC.
For foodstuffs, there will finally be legally prescribed EU-wide THC limits for the finished foodstuff (i. d. F. Hemp oil: 7.5 mg/kg) from January 2023. These can also be taken into account for already existing stocks.
Öko-Test again refers to a completely outdated and unnecessarily strict recommended value for THC daily intake (1 microgram per kilo body weight) of the EFSA. This value bears no relation to the scientifically sound THC intake calculations of other industrialized nations and recognized experts (Beitzke & Pate, 2022)[2], (EIHA, 2021)[3].
In this reference, Öko-Test has also made a serious error in the assessment of THC intake here. EFSA refers the reference value (ARfD) to ∆9-THC (psychoactive substance) and not to the value of total THC (sum of THC and THCA), as Öko-Test has only measured and reported. In hemp seeds and cold-pressed hemp oils, the value of THCA (the non-psychoactive acid precursor of THC) is significantly higher than the value of ∆9-THC.
And if the recommendation value of the European Food Safety Authority (EFSA) is used, then the average body weight of a European (70 kg) used by EFSA must also be used in the calculation, and not the (German) average body weight of 60 kg introduced by BfR for Germany a long time ago.
Our arguments are confirmed by the renowned German food laboratory ÖHMI Analytik GmbH (ÖHMI, 2022)[4].
Due to false statements and incomprehensible evaluation criteria on the part of Öko-Test, we see the image of hemp food producers damaged. Customers are given a completely distorted picture by this article regarding the actual high quality of hemp oils.
Hemp seed oil is undoubtedly and scientifically proven to be one of the highest quality edible oils available. The high content of unsaturated fatty acids, such as alpha-linolenic acid (ALA, an omega-3 fatty acid) as well as vitamin E are an important contribution to healthy nutrition.
The ecological advantages, which especially the hemp plant offers (no use of pesticides, no irrigation, soil improvement, and much more) are concealed from the customer.
Unfortunately, it is true that in the meantime we have to observe a ubiquitous basic pollution on our planet due to an ever increasing contamination of pollutants since the industrial revolution. But to blame this sad situation on hemp oil with self-invented devaluation limits that are completely pulled out of thin air is more than absurd.
Maybe this is a business model? So that people buy the copyrighted tests and their results for €2.50? They are not worth this money.
Perhaps it would be a great contribution to environmental protection to stop printing this magazine. Since printing ink is also based on mineral oils, with the mineral oil components MOSH.
“This product test deserves the grade insufficient. There Ökotest must work cleaner!” says Daniel Kruse, experienced hemp food producer and president of the European Hemp Industry Association (EIHA) in reference to the accusation of Öko-Test against the manufacturers of hemp seed oils.
[1] Ross, S. A. et al., GC-MS Analysis of the Total Ag-THC Content of Both Drug- and Fiber-Type Cannabis Seeds, J. Analytic Tox. 24, 715-17.
[2] Bernhard Beitzke & David W. Pate (2022): A broader view on deriving a reference dose for THC traces in foods, Critical Reviews in Toxicology, DOI:10.1080/10408444.2021.2008867
[3] EIHA. (2021, Juni). EIHA contribution on maximum levels for THC in food. https://eiha.org/wp-content/uploads/2021/06/EIHA-contribution-on-THC-maximum-levels-in-food-1-5.pdf
[4] ÖHMI Analytik GmbH. (2022, 12. Oktober). Stellungnahme zu der Veröffentlichung des Tests „Hanfprodukte” veröffentlicht im Öko-Test Magazin 10/2022. https://www.hempro.com/wp-content/uploads/2022/10/Stellungnahme-Oeko-Test-Hanfprodukte-OeHMI-Analytik.pdf