Smoked meat and fish: benzo(a)pyrene limits and how to stay below them in the smokehouse

Pršut, dried meat, sausages and smoked fish from a traditional smokehouse are subject to legal limits for polycyclic aromatic hydrocarbons (PAHs). The limits apply to anyone who sells smoked meat or fish, serves it to guests or exports it.

In short

• Smoked meat and smoked meat products: at most 2.0 µg/kg benzo(a)pyrene and 12.0 µg/kg for the sum of four PAHs (benzo(a)pyrene, benz(a)anthracene, benzo(b)fluoranthene and chrysene). These limits have applied in BiH since 1 September 2014.
• Smoked fish: the same limits, applied to the muscle meat, or to the whole fish if it is eaten whole.
• Smoked sprats and grilled or barbecued meat sold to the consumer: 5.0 and 30.0 µg/kg.
• The EU sets the same values in Regulation (EU) 2023/915. Its "traditionally smoked" exception (5.0 and 30.0) covers only a few member states, for products smoked there and intended for their own market. For meat, Croatia is one of them; for fish, only Latvia, Finland and Sweden. The BiH rulebook has no such exception.
• Neither text sets a separate PAH limit for smoked cheese.

Who it applies to

Every food business that places smoked meat or fish on the market, including a household that sells pršut to guests or at the market.

What to do

The Food Safety Agency of BiH (Agencija za sigurnost hrane BiH) published a translation of the Codex code of practice CAC/RCP 68-2009 on reducing PAH contamination from smoking. For a smokehouse, it means the following:

1. Fuel. Use clean, seasoned hardwood. Conifers have more lignin and resin, so avoid them. Never burn treated or painted wood, tyres, diesel, waste oil or plastic, not even in small amounts. Wood that is too dry burns fast and raises PAH levels.
2. Smoke without flame. Smoke should come from smouldering wood (sawdust, chips, logs) at roughly 300 to 400 °C. Set the air supply so there is no open flame and the oxygen supply is neither too low nor too high.
3. Distance from the fire. The farther the food is from the smoke source, the lower the PAH. Put a perforated metal sheet between the meat and the embers so fat does not drip into the fire.
4. Smoke from a separate chamber. Indirect smoking, where the smoke is produced outside the chamber holding the meat, generally gives less PAH than direct smoking. If you can, cool the smoke or pass it through a filter or a pipe that traps tar.
5. Equipment. The code lists cleanliness and maintenance of equipment among the factors that affect PAH levels, so clean and maintain the smokehouse and its equipment regularly.
6. After smoking. Soot can be rinsed off meat, but not off fish. Smoke fish with the skin on and remove the skin before eating.
7. Do not shorten smoking blindly. The code says smoking time is not a decisive factor if the smoke source is well managed, and that smoking for too short a time can affect food safety and shelf life. Change one step at a time and check the result by analysis.
8. Check by analysis. The code itself says there is no generally accepted recommendation on temperature or wood species. Send a sample of the finished product to an accredited laboratory for benzo(a)pyrene and the sum of four PAHs. Record the result together with the wood and method used, and keep it in your HACCP file (see the article on HACCP for small producers).

Where to go

• Food Safety Agency of BiH, Kneza Višeslava bb, Mostar, tel. +387 36 336 950, agencija@fsa.gov.ba: fsa.gov.ba
• Inspektorat Republike Srpske (Inspectorate of Republika Srpska, supervision of food on the market): inspektorat.vladars.rs

Laws and sources

• Pravilnik o maksimalno dozvoljenim količinama za određene kontaminante u hrani (Službeni glasnik BiH br. 68/14), Annex, part VI, points 6.1.4 to 6.1.6
• The rulebook was amended in Službeni glasnik BiH 79/16, 9/17 and 84/18. The amendments in 79/16 and 84/18 did not change points 6.1.4 to 6.1.6 (smoked meat and fish). The 79/16 amendment did change part VI on PAHs, but only point 6.1.2 (cocoa) and the new points 6.1.11 to 6.1.15: amendment 79/16, Food Safety Agency of BiH, list of regulations in force, Food Safety Agency of BiH
• Commission Regulation (EU) 2023/915, points 5.1.6 to 5.1.8 of Annex I and Article 7
• Code of practice for the reduction of PAH contamination from smoking and direct drying (CAC/RCP 68-2009), translation by the Food Safety Agency of BiH