IMACE position on trans fatty acids Brussels, April 2015

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IMACE position on trans fatty acids Brussels, April 201 Context IMACE is the European federation representing the interests of the European margarine producers.

1 IMACE position on trans fatty acids Brussels, April 201 Context IMACE is the European federation representing the interests of the European margarine producers. Directly and indirectly, IMACE covers about 2 companies with numerous plants throughout EU28, Norway and Switzerland. It is estimated that over 80% of the EU margarine production is covered by the IMACE membership structure. Trans Fatty Acids (TFA) in foods, as defined by Annex I, point 4 of Regulation (EU) No 1169/2011, originate from two main sources and can be of animal (ruminant TFA) or vegetable origin (non-ruminant TFA), as highlighted by the European Food Safety Authority (EFSA) 1, 2. According to scientific studies, the consumption of diets containing TFA consistently increases LDL cholesterol, decreases HDL cholesterol and hence, increases Total to HDL cholesterol ratio, which is associated with an increased risk of cardiovascular disease. According to EFSA, a difference between ruminant TFA and non-ruminant TFA has not been determined 1, 2 : evidence is insufficient to establish whether there is a difference between ruminant and non-ruminant TFA consumed in equivalent amounts on the risk of coronary heart disease. Yet a recent study shows that in equal amounts, the major ruminant trans fatty acid is as bad for LDL cholesterol as non-ruminant TFA. Hence, there is no reason to believe that ruminant TFA have a different effect on human health than non-ruminant TFA. Current EU law labelling requirements 1 EFSA opinion of the scientific panel on dietetic products, nutrition and allergies on a request from the Commission related to the presence of trans fatty acids in foods and the effects on human health of the consumption of trans fatty acids (Request EFSA-Q ) adopted on 8 July EFSA Scientific Opinion on Dietary Reference Values for fats, including saturated fatty acids, polyunsaturated fatty acids, monounsaturated fatty acids, trans fatty acids, and cholesterol. EFSA Journal 2010; 8():1461. [107 pp.]. doi:10.290/j.efsa Gebauer S. et al (201), Vaccenic acid and trans fatty acid isomers from partially hydrogenated oil both adversely affect LDL cholesterol: a double-blind, randomized controlled trial. American Journal Of Clinical Nutrition, 201; doi:10.94/ajcn Avenue de Tervueren 168/ Brussels Entreprise nr Tel Fax imace.ifma@imace.org

2 According to Annex VII of Regulation (EU) No 1169/2011, vegetable oils or fats have currently to be labelled on food products, indicating whether full or partial hydrogenation was performed. This regulation prohibits the voluntary mentioning of the TFA content on the label. IMACE is of the opinion that the current full/partial hydrogenation labelling pursuant to Regulation (EU) No 1169/2011, does not bring any added value in helping consumers to make informed and healthy choices. Indeed, it is shown 4 that it misleads consumers as they do not understand and confuse both terms, making them think that a product labelled as fully hydrogenated contains substantially more TFA as compared to partially hydrogenated products, while it actually does not contain any TFA at all. Given the limited/wrong understanding of the consumers and the negative perception on the Partially Hydrogenated Vegetable Oils (PHVO)/Fully Hydrogenated Vegetable Oils (FHVO) information, the current mandatory labelling stigmatizes the margarines & spreads sector wrongfully, whilst major improvements and efforts have been made by the European margarine sector, for more than 20 years, bringing the non-ruminant TFA levels down to a level, where there is no longer a public health concern as confirmed in the EFSA scientific opinions of 2004 and IMACE voluntary initiatives to reducing TFA in margarines and spreads Over the past 20 years, IMACE members have been supporting industry initiatives to reduce TFA in margarines and spreads, including reformulation, optimisation of refining processes in accordance with the IMACE Code of Practice on TFA. Following these numerous industry actions, significant overall reductions in the non-ruminant TFA content of food products sold to the final consumers have been achieved. Consequently, the intake of non-ruminant TFA in the EU has decreased considerably over recent years to a level, where there is no longer a general public health concern. As said above, this decrease was also highlighted by EFSA in its opinions of 2004 and 2009, based on data analysis at national level. To estimate the extent of this reduction for the vegetable oil and fat sector, IMACE undertook a 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 A&B Danish study on consumer understanding of PHVO/FHVO, MIFU 2014 See footnotes 1 and 2. Evidence from a number of countries indicates that the intake of TFA in the EU has decreased considerably over recent years, owing to reformulation of food products, e.g. fat spreads, sweet bakery products and fast food. More recent reported intakes in some EU Member States are close to 1 to 2 E% (EFSA, 2004). For example, in the UK the average intake of TFA has been halved to less than 1 E% (SACN, 2007). In France, intake data from 4079 individuals to 79 years of age collected with 7-day food diaries and calculated with tables of TFA content of foods from 2008 show that TFA intakes have decreased by 40 % and are, on average, 1 E% in adults (1.4 E% at the 9th percentile), including 0.6 % for TFA from ruminant sources and 0.4 % for TFA from other sources (AFSSA, 2009). Average intakes of TFA in Denmark, Finland, Norway and Sweden have decreased to around 0. to 0.6 E% (Johansson et al., 2006; Lyhne et al., 200; Männistö et al., 200; Becker et al., 200). Avenue de Tervueren 168/ Brussels Entreprise nr Tel Fax imace.ifma@imace.org

3 % Value on B2B margarines also shows that the average non-ruminant TFA content in B2B margarines has decreased over the last 10 years from 7.1 to 1.4% on fat basis. Moreover, between 2004 and 2014, the percentage (%) of product tons of B2B margarines complying with IMACE s recommended maximum 2% TFA level (on fat basis) increased from 29% to 92.6%. Reduction of trans fatty acids (TFA) in B2B margarines Average TFA level (on product basis) Average TFA level (on fat basis) Current TFA intake in Western Europe and way forward to further reduce intakes of TFA As noted and recognized by several authorities, thanks to the successful voluntary reformulation efforts from the Margarines & Spreads sector, the intake of non-ruminant TFA are below the limits of public health concern in the majority of EU Member States. The current main TFA source in Western European diets is coming from ruminant TFA 6 (up to % TFA on fat basis, naturally present). Given the fact that both TFA sources are equally detrimental to public health (see footnotes 2 and ), IMACE is of the opinion that, on the basis of non-discriminatory measures as provided for in the General Food Law, specific consumer information/education on TFA and/or specific measures to limit the TFA intake should Because of the steep reduction in the production and intake of non-ruminant TFAs, ruminant fats are now the major source of TFAs in most European countries and will likely become so in the US. Brouwer IA, Wanders AJ, Katan MB (2010) Effect of Animal and Non-ruminant Trans Fatty Acids on HDL and LDL Cholesterol Levels in Humans A Quantitative Review. PLoS ONE (): e944. doi:10.171/journal.pone Avenue de Tervueren 168/ Brussels Entreprise nr Tel Fax imace.ifma@imace.org

4 address both TFA sources equally and simultaneously as they are equally harmful and as ruminant TFA has become the main source of TFA intake in Western Europe. IMACE is of the opinion that we should also continue to support consumer messages about the importance of quality of fats in the diet. Encouraging consumers to reduce saturated fatty acids (SFA) intake and replace them by unsaturated fatty acids (UFA) is important for public health. This will automatically also result in the reduction of TFA intake. IMACE views on TFA policy IMACE favors further voluntary initiatives given the success of the IMACE voluntary Code of Practice. IMACE Members are committed to continue their voluntary efforts and to keep improving the nutritional quality of their products, while maintaining their technical performance. IMACE is in favour of labelling all TFA (ruminant and non-ruminant), exceeding the level of 2% on fat basis of food products sold to the consumers. IMACE is of the opinion that consumers should be informed on the TFA content to facilitate informed choices. Labelling all TFA (ruminant and non-ruminant) above 2% on fat basis in food products sold to the final consumer is the most straight forward, comprehensive, transparent and correct way to allow consumers to make informed choices related to the intake of ruminant and non-ruminant TFA. Setting a labelling threshold will also stimulate the various sectors to reduce further the TFA content below the labelling limit. IMACE requests the deletion of the current mandatory full/partial hydrogenation labelling pursuant to Regulation (EU) No 1169/2011 as IMACE is of the opinion that the current labelling does not bring any added value for consumers. Indeed, it is shown 7 that it misleads consumers as they do not understand and confuse both terms, making them think that a product labelled as fully hydrogenated contains substantially more TFA as compared to partially hydrogenated products, while it actually does not contain any TFA at all. Given the limited/wrong understanding of the consumers and the negative perception on the Partially Hydrogenated Vegetable Oils (PHVO)/Fully Hydrogenated Vegetable Oils (FHVO) information, the current mandatory labelling stigmatizes the margarines & spreads sector wrongfully, whilst major improvements and efforts have been made by the European margarine sector, for more than 20 years, bringing the non-ruminant TFA levels down to a level, where there is no longer a public health concern as confirmed in the EFSA scientific opinions of 2004 and The current mandatory labelling of PHVO/FHVO also informs indirectly only on one TFA source (non-ruminant), while no information is provided to the consumer on the content of ruminant TFA in the products. This is misleading for the consumer and discriminating for our sector. 6 A&B Danish study on consumer understanding of PHVO/FHVO, MIFU 2014 Avenue de Tervueren 168/ Brussels Entreprise nr Tel Fax imace.ifma@imace.org

5 IMACE is of the opinion that the coming into force of any new policy regulation on TFA should be linked to the coming into force of the requested deletion of the mandatory labelling of PHVO/FHVO in the Regulation (EU) No 1169/2011. *************************************************** Avenue de Tervueren 168/ Brussels Entreprise nr Tel Fax imace.ifma@imace.org

Impact of trans fats on health EFSA s work related to trans Fatty acids

Setting the scene Impact of trans fats on health EFSA s work related to trans Fatty acids Prof. Ambroise Martin Member of the EFSA WG on DRVs (former chair 2006-2015) and NDA Panel 2006-2015 (former chair