IMACE Q&A on Trans Fatty Acids (TFA)
IMACE Q&A on Trans Fatty Acids (TFA)
Brussels, November2017
What are trans fatty acids (TFA)?
Trans fatty acids (TFA) are unsaturated fatty acids that have at least one double bond in the trans configuration.
In chemical terms, trans fatty acid are fat molecules that contain one or more double bonds in trans geometric configuration. A double bond may exhibit one of two possible configurations: trans or cis. In trans configuration, the carbon chain extends from opposite sides of the double bond, whereas, in cis configuration, the carbon chain extends from the same side of the double bond. The trans molecule is a straighter molecule. The cis molecule is bent (see examples below).
At the 26th Session of Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU)in November 2004, the Codex Alimentarius Committee agreed to use thechemical structure and the AOCS method for determiningTFA and agreed that: “For the purpose of the CodexGuidelines on Nutrition Labelling and other related CodexStandards and Guidelines, trans fatty acids are defined as allthe geometrical isomers of monounsaturated and polyunsaturatedfatty acids having non-conjugated interrupted by at least one methylene group (-CH2–CH2-) carbon–carbondouble bonds in the trans configuration”.
What are the dietary sources of TFA?
As explained in the “EFSA Scientific Opinion related to the presence of trans fatty acids in foods and the effect on human health of the consumption of trans fatty acids (2004)”, TFA in foods originate from three main sources:
- Bacterial transformation of unsaturated fatty acids in the rumen of ruminant animals;
- Industrial hydrogenation (used to produce semi-solid and solid fats that can be used for the production of foods such as margarines, shortenings, and biscuits) and deodorization (a necessary step in refining) of unsaturated vegetable oils (or occasionally fish oils) high in polyunsaturated fatty acids;
- During heating and frying of oils at high temperatures.
Dairy and beef fat typically contain around 3-6% TFA (wt. % of total fatty acids), while levels in lamb and mutton can be somewhat higher. The TFA content in margarines and fat spreads may vary considerably, depending on the proportion of partially hydrogenated oils used.
Already in 2004, EFSA acknowledged that the intakes of TFA have decreased in a number of EU countries, mainly due to reformulation of food products, e.g. fat spreads, to reduce the TFA content.
What are ruminant TFA?
Ruminant TFA are produced in the stomach of ruminants (cows, sheep, etc.) and are present in milk, cheese, butter, other milk products, meat and meat products. Dairy fat contains up to 4-6% TFA.
The quantity and composition of ruminant TFA depend on the season and the feeding practices of ruminant animals. For example, grass-fed ruminants produce more TFA and the TFA content in milk is higher during summer.
What are non-ruminant TFAor industrial TFA?
Non-ruminant TFA are found in partially hydrogenated vegetable oils and fats, resulting from the partial hydrogenation process (as opposed to the full hydrogenation process, which does not produce TFA).
The quantity and composition of non-ruminant TFA depend on the process parameters (e.g.: temperature, time, pressure, type of oil, etc.).
What are the results of the efforts of the margarine industry to reduce the TFA content in its products?
Over the past 20 years, IMACE members have been supporting industry initiatives to reduce TFA in vegetable margarines and spreads, including reformulation and optimisation of refining processes in accordance with the IMACE Code of Practice on TFA.
To estimate the extent of this reduction for the vegetable oil and fat sector, IMACE undertakes yearly data collection and analysis. In retail margarines and spreads sold to the final consumers, non-ruminant TFA levels are well below 2% on fat basis. The data collection on Business-to-business (B2B) vegetable fats also shows that the average non-ruminant TFA content has decreased over the last 10 years from 7.1% on fat basis to well below 2% on fat basis (on average 1.2 % in 2015).
What do the latest data show onthe success of the margarine industry reformulation progresses?
The yearly collection of data by IMACE on the composition of B2B products produced by its members highlights the success of the margarine industry reformulation progresses. Margarine manufacturers are committed to producing the best possible products for consumers through innovation and blending of healthy vegetable oils and fats. Recipes are regularly reviewed and reformulated to fit the latest nutritional evidence, whilst keeping functional properties. More specifically:
- Between 2004 and 2016, the percentage (%) of product tonnes complying with IMACE’s recommended maximum 2% TFA level (on fat basis) increased from 29% (in 2004) to 93% for the B2B fats and to 92% for the shortenings (between 2014 and 2015);
- Considerable improvement has been made since 2004 with the total average TFA level on fat basis in B2B fats decreasing from 7.1% in 2004 to 1.2% in 2015, in line with the IMACE Code of Practice. For the shortenings, a reduction of 25% of the total average TFA level on fat basis to 2.4% was achieved in 2015;
- This TFA reduction was moreover achieved, while keeping SFA content on fat basis as low as possible, which represents a technological challenge. The total average combined TFA+SFA content (on fat basis) in B2B vegetable fats was reduced from 50.1% in 2004 to 45.3% in 2015. The total average combined TFA+SFA content (on fat basis) in shortenings was further reduced to 38% in 2015.
What is the current dietary intake of TFA in Europe?
Due to a steep reduction in production and intake of non-ruminant TFA, in most Western EU Members States, up to 60-70% of the current TFA intake is now coming from ruminant sources.
- Intake data from 2008 shows that TFA intakes in France represent on average 1% total energy (EN) intake in adults, including 0.6% EN ruminant TFA and 0.4% EN non-ruminant TFA;
- In UK, TFA intakes were estimated in 2008-2009 at, on average, 0.8% EN. Similar to France, the major contributors to TFA intake in the UK were mainly meat and meat products, butter and milk and milk products;
- In Germany, in 2009 already, 67% of TFA intake came from ruminant TFA (25% from butter, 24% from other milk products and 16% from meat and meat products).
Data of population trans fat intakes from the Transfair study (1999) and recent data from the Netherlands, UK, France, Denmark, Germany and Finland show that nowadays the largest part of trans fat intake originates from animal food sources.
Notably, the low non-ruminant TFA levels in Western Europe show that voluntary reformulation has already lead to significant reductions in TFA levels. EFSA’s 2004 and 2010 opinions clearly acknowledge the voluntary efforts made by the vegetable oil and fat industry.
What is the current dietary intake of TFA in general population worldwide?
A recent systematic review (2017) investigating the intakes of trans fat and its dietary sources in general populations worldwidehas concluded thatnowadays, in the majority of countries for which data are available, averagetrans fat intake is lower than the recommended maximum intake of 1%EN (i.e. totalenergy intake) with intakes from animalsources being higher than from industrial sources.
In the past 20 years, substantial reductions inindustrial trans fat have been achieved in many countries.
What is the current regulatory state of play related to TFA?
The EU is currently investigating the possibility of introducing regulations with the aim to further reduce the intake of TFA in the EU population.
For technical and political reasons, the focus is on non-ruminant TFA.
The key measures possible to reduce TFA consumption in the EU could be:
a)the introduction of an EU mandatory TFA content declaration;
b)an EU legal limit on the TFA content of food;
c)voluntary agreements towards reducing TFA in foods and diets at EU level;
d)EU guidance for national legal limits on the TFA content of food;
e)EU ban of partially hydrogenated vegetable oils
Alternatively, action could be left at national level and/or to voluntary reduction efforts.
The Commission report from December 2015 states that a legal limit on non-ruminant TFA will be most effective. This option is receiving the support from Consumer organizations, EU Parliament, the World Health Organisation (WHO), FEDIOL (European Vegetable Oil and Protein Meal Association), IMACE (The European Margarine Association) and a coalition of several big food industry companies.
The European Commission is currently carrying out an Impact Assessment, where IMACE is actively involved both via direct consultations and through FoodDrinkEurope.
What is IMACE’s view on the regulatory focus tackling only non-ruminant (i.e. industrial) sources?
IMACE considers that the proposed policy option (see question above), which is only applicable to one source of TFA (non-ruminant TFA), does not address the public health issue concerning the TFA intake properly.
Given the fact that both TFA sources are equally detrimental to public health, as also confirmed by the recent WHO Report, and that intakes of ruminant TFA are higher than industrial TFA in many countries, IMACE is of the opinion that, on the basis of non-discriminatory measures as provided for in the EU General Food Law (Regulation (EC) No 178/2002), specific consumer information/education on TFA and/or specific measures to limit the total TFA intake should address both TFA sources equally and simultaneously as they are equally harmful, and as ruminant TFA have become the main source of TFA intake in Western Europe.
IMACE is of the opinion that setting up a policy only impacting the vegetable oil and fat sector, not addressing the same issue simultaneously in other concerned sectors, can be questioned from a better regulation perspective, being biased, incoherent and lacking sound evidence.
In addition, IMACE is of the opinion that the current mandatory “fully/partially hydrogenated” labelling, pursuant to Regulation (EU) No 1169/2011, will become obsolete, if legal limits for non-ruminant TFA are established. It has been demonstrated that the hydrogenation labelling is not appropriate in helping consumers make an informed and healthy food choice.
Therefore, the coming into force of a legal limit on non-ruminant TFA should be linked to the coming into force of the deletion of the mandatory labelling of “fully/partially hydrogenated”.
What are the risks of a policy focusing only on industrial TFA?
a. Acting only on the non-ruminant sector implies a potential risk of increasing further the intake of ruminant TFA due to the replacement of the regulated margarines and vegetable fats (lower than 2% TFA on fat basis) by the non-regulated butter (up to 5% TFA on fat basis, naturally present);
b. Substitution of margarines and vegetable fats by butter will also have detrimental effects on the intake of saturated fatty acids, which poses an extra risk for cardiovascular health, when taken in excess;
c. Ignoring the presence and potential effects of ruminant TFA is misleading the consumers, who cannot be aware of the harmful ruminant TFA content of butter, dairy and meat products in their diets, making it impossible to take an informed health choice concerning TFA. In addition, ignoring these elements in combination may lead to increased intakes of ruminant TFA.
Hence, IMACE urges the adoption of a non-discriminatory policy (based on objective and scientific grounds) that is fit for purpose to address the issue of TFA from all sources based on the facts and concerns expressed above.
What is IMACE’s view regarding setting legal limits on non-ruminant TFA?
IMACE acknowledges the fact that “a legal limit on non-ruminant TFA” would allow to consolidate and maintain the voluntary progresses made concerning non-ruminant TFA and would ensure a harmonised non-ruminant TFA approach in Europe.
Regarding the legal limits two approaches can be identified:
1)The Danish 2% on fat basis in the final product.The Danish legislation also includes the option of an exemption for higher TFA in products with a low total fat content;
2)The Austrian (Hungarian and Latvia) staggered approach:
•<2g TFA/100g fat, if final product contains more than 20% total fat
•<4g TFA/100g fat, if final product contains between 3% and 20% total fat
•<10g TFA/100g fat, if final product contains less than 3% total fat
Further to IMACE’s review of the two approaches described above, IMACE can support a 2% TFA ruling on fat basis in the final consumer products (i.e. the Danish approach) but IMACE will also clearly voice and illustrate the general limitations and potential disproportional effect of the Danish approach for products that contain low levels of fat in the final product (e.g. <3-4%), to make the regulator aware of those specific issues and to consider specific measures for these products.
What is IMACE’s view on PHVO/FHVO current mandatory labelling requirement?
IMACE considers an EU definition of Partially Hydrogenated Vegetable Oils (PHVO) and Fully Hydrogenated Vegetable Oils unnecessary. In the event TFA limits are set by an EU legislation, the mandatory declaration for partially and fully hydrogenated vegetable oils following the Food Information to Consumers (FIC) Regulation (EU) No 1169/2013 will become redundant and necessary. Hence, there will be no needs to define what hydrogenation is. Today, consumers can only get information on the potential presence of non-ruminant TFA via the presence of “fully or partially hydrogenated oils and fats”. However, this labelling does not give them the real TFA content of the product. Even more so, it misleads them in thinking that fully hydrogenated oils have higher TFA content than partially hydrogenated oils (while, fully hydrogenated oils do not contain TFA, only traces due to deodorization process like any other oil) and does not inform them on the presence of ruminant TFA. Hence, consumers cannot make informed food choices.
Hence, in case a legal limit for non-ruminant TFA would be the policy measure preferred by the majority of the stakeholders, such measures (i.e. a legal limit for TFA) should be linked to the coming into force of the requested deletion of the mandatory labelling of PHVO/FHVO in Regulation (EU) No 1169/2011), as this labelling request will be totally redundant with any statutory measures on non-ruminant TFA.
Why the US TFA regulatory approach is not fit for purpose in EU?
IMACE is aligned with FEDIOL and believes that the US approach on TFA is not fit for purpose. Notably, the definition of partially hydrogenated oils based on Iodine Value will not work in the EU:
-The notion of IV is not known outside the refining sector, and is particularly unknown to consumers;
-The iodine value does not measure directly the level of TFA and hence does not always imply a reliable specific TFA level;
-It is difficult to apply to food products, where in most relevant cases, vegetable oils/fats are only one ingredient in the final food and it is complex to use for enforcement purposes in the EU.
What is the consumer understanding ofTFA?
There is limited information on European consumers’ knowledge of TFA and even less on whether such knowledge affects consumers' food choice. The little information available suggests that the majority of Europeans do not know about TFA, industrial TFA or ruminant TFA and partially hydrogenated or fully hydrogenated vegetable oils. Also, only a small fraction of people seems to be concerned about TFA intake.
In addition, the industry has no means to communicate, and thus to educate consumers, about TFA content, neither through FIC in the nutrition table nor under the Nutrition & Health claims legislation, since the “Low TFA”/”TFA free” claims are not on the list of authorised nutrition claims. In addition, the current mandatory labelling on partially and fully hydrogenated oils is misleading consumers.
It is important to highlight that consumers are also often not aware that many other foods, such as dairy products and meats from ruminant animals can contain significant levels of TFA. Research does not show that ruminant TFA and industrial TFA differ in their impact on health;in fact publications by EFSA and WHO Europe even suggest that the impact is probably the same.
Making real improvements to consumer health requires more than product reformulation or legal limits, it also requires educating consumers, chefs, teachers, journalists, bloggers to help stimulate positive behaviour change.
Can we technically differentiate between the two TFA sources?
Both in animal and vegetable fat sources, there is not a single TFA type present, but always a mixture of different TFA.
The TFA in animal and vegetable fat sources are the same, but they differ in their respective quantities.