Until 2024, T-2 and HT-2 were only subject to a recommendation. Since 1 July 2024, they have been maximum levels, and oats is the most severely affected crop.
T-2 and HT-2 are trichothecenes from Fusarium, primarily an issue in oats and to a lesser extent in barley. They are not new toxins, but until 2024 they were only subject to a recommendation. Regulation (EU) 2024/1038 turned them into statutory maximum levels as of 1 July 2024, and the values are stringent.
| Product | Value |
|---|---|
| Unprocessed cereals, general | 50 |
| Unprocessed malting barley | 200 |
| Unprocessed barley, other than malting | 150 |
| Unprocessed maize and durum wheat | 100 |
| Unprocessed oats with husk | 1 250 |
| Cereals for the final consumer | 20 |
| Oats for the final consumer | 100 |
| Oat flakes and oat bran | 100 |
| Cereal-based baby food | 10 |
The lower-bound approach applies to the sum: values below the limit of quantification count as zero.
Oats are often harvested with the husk, and the husk contains a large proportion of the contamination. The maximum level of 1,250 µg/kg therefore applies to unprocessed oats with husk, even if that husk is inedible. After dehulling and milling, the level decreases, but not automatically to below the 100 µg/kg applicable to oat flakes. The ratio between raw oats and the finished product is therefore not a matter of a fixed factor.
Changes are also underway in animal nutrition. Until now, only the guidance values of Recommendation 2013/165/EU applied to T-2/HT-2. From 1 July 2027, those of Recommendation (EU) 2026/1801 will apply: oats with husk 1.5 mg/kg, other cereals 0.2 mg/kg, oat products 3.0 mg/kg and compound feed 0.2 mg/kg. Anyone supplying oats or oat by-products to the feed industry will therefore test for two figures from now on.
The ROSA T2/HT2 test is a quantitative lateral flow test with a range of 25 to 200 µg/kg in the first dilution and 100 to 2,000 µg/kg in the second. The test takes ten minutes, uses 70% methanol and has been validated by Charm for commodities including barley, oats, oat bran, maize, wheat and soya meal.
Oat and malting supply chains must add a parameter that they did not routinely measure prior to 2024. This requires not only a new strip, but also a new sampling and acceptance strategy: which consignments are tested at intake, which only on suspicion, and which go directly for confirmation. In addition, a separate value of 200 µg/kg applies to malting barley, which is only relevant if the consignment is actually intended for malting.
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