National Heart Forum position paper on the elimination of industrially-produced trans fats (IPTFAs) from foods consumed in the UK.

Transcription

1 P o l i c y p o s i t i o n p a p e r National Heart Forum position paper on the elimination of industrially-produced trans fats (IPTFAs) from foods consumed in the UK June 2010

2 Contents: 1. Context and purpose of this paper 2. What are trans fats (TFAs)? 3. The impact on trans fats on health 4. International recommendations 5. Current recommendations in the UK 6. Comments on the 2010 NDNS data 6.1 Using average IPTFA intakes is misleading 6.2 Risk of widening health inequalities 7. Sources of trans fats in the food supply 7.1 IPTFAs in manufactured foods 7.2 Substitution of IPTFAs in manufactured foods 7.3 IPTFAs in fast food service 8. Actions taken in other countries/regions 9. The need for action in the UK 9.1 Manufactured foods 9.2 Fast food and takeaways 10. Conclusions 11. Recommendations Annex A: Mechanisms to reduce IPTFAs in fast food Annex B: Actions in other countries

3 1. Context and purpose of this paper Industrially produced Trans fats (IPTFAs) are harmful to health, they have no nutritional benefits and there is no known safe level of consumption. IPTFAs are widely used for functional reasons in processed foods. IPTFAs also occur in many varieties of fast food as a consequence of frying foods in re-heated oil. Some countries have successfully legislated to eliminate IPTFAs from food. The previous government policy has been currently limited to encouraging voluntary action by the manufactured food industry to remove IPTFAs from their products as part of a wider strategy to reduce saturated fat in the diet. The government s position was based on a review by the Food Standards Agency (2007) 1 and the Scientific Advisory Committee on Nutrition (2007) 2 which looked at trans fat intakes in the UK population and levels of TFAs in processed foods. According to this review, estimated average intakes of TFAs in the British population are 1 per cent of food energy, half the maximum recommended average intake of 2 per cent of food energy 3. The National Heart Forum is concerned that intakes of IPTFAs are likely to be substantially higher than suggested by the FSA review, particularly among some sub-groups and vulnerable population groups. The NHF therefore suggest that current UK policy is inadequate, and that it contributes to avoidable inequalities in health 4. UK policy should therefore be strengthened as a matter of urgency in line with action taken in other countries such as Denmark, Switzerland and Austria and some US states. 1 FSA (2007): FSA 07/12/07, Trans fatty acids. At: (accessed on 02/10/09) 2 SACN (2007): Update on trans fatty acids and health. Position statement by the Scientific Advisory Committee on Nutrition. At: (accessed on 23/09/09) 3 SACN (2007), page 2 4 Barton et al (2009): Prevention of cardiovascular disease at population level. Modelling strategies for primary prevention of cardiovascular disease, page 20. Under: %20of%20cardiovascular%20disease.pdf (accessed on 17/11/2009) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

4 There have been recent developments in the UK. In Scotland in 2009, Dr Richard Simpson MSP put forward a members bill proposing legislation to limit IPTFAs in food products. 5 However, in April 2010 the Limit on trans fats (Scotland) Bill failed to attract sufficient cross-party support and consequently the proposal fell. 6 In April 2010, two senior public health experts wrote in a British Medical Journal editorial that removing industrial trans fats from all foods is one of the most straightforward public health strategies for rapid improvement in health. 7 In England, the NICE Programme Development Group (PDG) on cardiovascular disease prevention has heard evidence on the very harmful health impacts of IPTFAs and the need to eliminate them from the diet. 8 The final public health guidance on population level interventions to prevent CVD will be published in June In January 2010, the UK Faculty of Public Health (FPH) and the Royal Society of Public Health called for a complete ban of IPTFAs in foods in their joint manifesto. 9 Further, in its final report, the Public Health Commission established by the Conservative party recommends that voluntary food reformulation commitments 5 Public consultation on Limit on trans fats (Scotland) Bill. Improving Scotland s diet and protecting public health. At: Finaltransfatsconsultation.pdf (accessed on 01 October 2009) 6 The Scottish Parliament: Proposals for members Bills. At: (accessed on 26 April 2010) 7 Mozaffarian, D and Stampfer, M J: Removing industrial trans fat from foods. A simple policy that will save lives. Published on 15 April 2010 in the BMJ (BMJ 2010;340:c1826), at: (accessed 27 April 2010) 8 NICE CVD guidance expert testimony on the public health harm caused by industrially produced Trans Fatty Acids and actions to reduce and eliminate them from the food system in the UK. (accessed on 18/09/09) 9 UKFPH: 12 Steps to better public health a manifesto. At: (accessed 27 April 2010) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

5 should be extended to the out of home food sector to eliminate industrial trans fats in all foods. 10 This is a consensus-based policy position paper by the National Heart Forum. It sets out the case for a) legislation to ban the use of IPTFAs in processed foods in the UK and b) mandatory requirements for action by the food service industry that would effectively eliminate consumers exposure to TFAs produced by frying processes. This paper examines: the evidence of harm to public health caused by IPTFAs and current recommendations regarding their consumption; the sources of TFAs in the food supply and problems with current data on intake levels; the technical issues for removing TFAs from the food supply and ensuring only healthy fat substitutions, and evidence from countries and regions which have successfully enacted legislation to eliminate TFAs from the food supply. 2. What are trans fats? Trans fats, also known as trans fatty acids, occur in Hydrogenated Vegetable Oils (HVOs) or Partially Hydrogenated Vegetable Oils (PHVOs), and are produced when liquid oils, usually vegetable oils, are turned into solid fats or are chemically stabilised through an industrial process of hydrogenation. They can also be produced when some liquid oils are heated and reheated during frying at 10 Public Health Commission (2009): We re all in this together improving the long-term health of the nation, page 11 NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

6 high temperatures. It is estimated that 0.2 1% of total fat content are converted into trans fatty acids through the deep frying process over longer periods with initially IPTFA-free vegetable oils. 11 HVOs and PHVOs have been used by the food industry since the 1970s as an inexpensive way to add bulk, texture and extend the shelf life of products (unsaturated fatty acids in vegetable oils are more easily oxidised and may go rancid more quickly). A review of IPTFAs by WHO (2009) classes them as industrial additives based on the fact that they are not naturally present in foods and have no known health benefits The impact of trans fats on health The primary health concerns relating to IPTFAs are an association between increasing IPTFA intakes, raised serum cholesterol levels and cardiovascular deaths. Increased TFA intakes raise the levels of low density lipoprotein (LDL) or bad cholesterol. TFAs also lower the levels of high density lipoprotein (HDL) or good cholesterol which otherwise protects against cardiovascular disease (CVD). The New England Journal of Medicine review (NEJM 2006) 13 and Mozzafarian (2009) 14 show that a one per cent increase in energy intake from IPTFAs increases coronary heart disease (CHD) deaths by 12% (pooled relative risk, 11 Health Canada (2006): TRANSforming the food supply: Report of the Trans Fat Task Force submitted to the Minister of Health, page Uauy R et al (2009): WHO Scientific Update on trans fatty acids: summary and conclusions. In: European Journal of Clinical Nutrition (2009) 63, S69 13 Mozaffarian D et al (2006): Trans Fatty Acids and Cardiovascular Disease New England Journal of Medicine (NEJM); 354: Mozaffarian D and Clarke R (2009): Quantitative effects on cardiovascular risk factors and coronary heart disease risk of replacing partially hydrogenated vegetable oils with other fats and oils. European Journal of Clinical Nutrition, 1 12 NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

7 1.12; 95 percent confidence interval, 1.06 to 1.18:P < 0.001). On a per calorie basis, IPTFAs therefore increase the risk of CHD more than any other nutrient, conferring a substantially increased risk even at low levels of consumption. This represents a 5% higher mortality for each gram consumed per day. The NEJM review also states that TFAs cause inflammation which is an independent risk factor for atherosclerosis, sudden death from cardiac causes, diabetes and heart failure. It concludes that: The evidence and the magnitude of adverse health effects of trans fatty acids are in fact far stronger on average than those of food contaminants or pesticide residues, which have in some cases received considerable attention International expert recommendations The 2003 World Health Organization (WHO) Technical Report on Diet, Nutrition and the Prevention of Chronic Diseases recommended a population goal of <1% of TFAs in the overall energy intake. The 2009 WHO review on IPTFAs went further, emphasizing the need to significantly reduce or to virtually eliminate industrially produced TFA from the food supply in agreement with the implementation of the 2004 WHO Global Strategy on Diet, Physical Activity and Health. 16 In November 2009, the European Parliament s policy department on economic and specific policy published a study on IPTFAs reviewing health hazards and 15 Mozaffarian D et al (2006): Trans Fatty Acids and Cardiovascular Disease New England Journal of Medicine (NEJM); 354: Uauy R et al (2009): WHO Scientific Update on trans fatty acids: summary and conclusions. In: European Journal of Clinical Nutrition 63, S68 S75. NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

8 existing legislation in and outside the EU. It recommends a ban of IPTFAs should be considered at EU level. 17 In December 2009, the US Interagency Working Group on food marketed to children proposed tentative nutrition standards for marketing foods to children aged Standard 3 limits the maximum amount of trans fat in foods which can be marketed to children to 0 grams per reference amount customarily consumed (RACC) in accordance with international recommendations to eliminate IPTFA intake in the population Current recommendations in the UK In 1994, the Committee on Medical Aspects of Food Policy (COMA) recommended that average intakes of trans fats should not exceed 2 per cent of food energy. 19 The previous government s position is based on a review by the Food Standards Agency (2007) 20 and SACN (2007) 21 which looked at trans fat intakes in the UK population and levels of TFAs in processed foods. According to the latest National Diet and Nutrition Survey (NDNS) 2010 data 22, estimated average intakes of TFAs in the UK population are 0.8 per cent of food energy, less than 17 Krettek, A et al (2008): Trans Fatty Acids and Health: A Review of Health Hazards and Existing Legislation. At: 18 Interagency Working Group on food marketed to children (15 December 2009): Tentative proposed nutrition standards. At: (accessed on 7/01/2010) 19 Department of Health (COMA) (1994): Nutritional Aspects of Cardiovascular Disease. London: HMSO 20 FSA (2007): Trans Fatty Acids. At: (accessed on 02/10/09) 21 SACN (2007), page i 22 FSA and DH (2010): National Diet and Nutrition Survey Headline results from Year 1 of the Rolling Programme (2008/2009). At: (accessed on 04/03/2010) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

9 half the maximum recommended average intake of 2 per cent of food energy (approximately 5g per day 23 ). 6. Comments on the NDNS 2010 data In February 2010, the FSA published the report of the first year of the NDNS rolling programme (February 2008 to March 2009) stating that trans fatty acid intakes were lower than in previous NDNS and were less than 2g per day for all age groups, representing 0.8% of food energy. This level of intake for adults was also lower than the re-estimated value calculated in 2007 at 1.0% food energy based on consumption data from the 2000/01 NDNS and information from the food industry on then current levels of trans fats in processed foods. 24 While intake levels appear to have made a dramatic and welcome drop compared to previous estimates, it is a matter of continuing concern that these reductions are heavily dependent on the validity of reductions in IPTFA levels in processed foods claimed by food manufacturers. No external assay has been applied to assess whether, for example, the reductions claimed by the food industry apply across the board, or may be limited to only the larger manufacturers. Consumption of pies, pastries, cakes, biscuits and deep-fried fast foods are still being consumed in significant quantities, making it essential that claimed reformulations to remove IPTFAs are independently validated. There are also concerns over sample size and composition. The FSA acknowledges that the sample size of 952 households in this first year of the NDNS rolling programme is small. It is also noteworthy that 43 per cent of households invited to participate in the survey either refused to participate or failed to complete the survey. One of the reasons given for failure to complete 23 SACN (2007), page 2 24 FSA (2010): National Diet and Nutrition Survey. Headline results from Year 1 of the Rolling Programme (2008/2009), page 45 at: (accessed 04/03/2010) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

10 was language difficulties, suggesting that some hard to reach sections of the population may not be well reflected in the data. Although the 2010 survey included reporting of food eaten outside the home, there are continuing concerns that, in line with the FSA s own dietary analyses, around 20 per cent of food is not reported in food diaries and therefore not included in the estimates of intake. 25 It is possible that unreported foods (typically snacks and fast foods) contain higher levels of IPTFAs. The TFA intakes per grams in the upper 2.5 percentile are comparatively high, ranging from 2.6g/day for 4-10 year old boys and girls to 3.5g/day for year olds. 26 Although these high intakes of TFA are below the recommended maximum intake of 5g/day or 2% of overall food energy, the NHF is concerned about how accurately this survey reflects the dietary intakes of the different subpopulation groups, such as young people. 6.1 Using average intakes of IPTFAs is misleading The FSA estimates that average population intakes are 0.8 per cent of food energy. This means that some people will have intakes above and below the mean. We are concerned that there are significant numbers of children, young people and vulnerable populations consuming IPTFA at levels well above the average and whose health and health prospects will be damaged and compromised. This occurs especially when eating food prepared outside the home where consumers do not have control over the composition and way in which the food is prepared. 25 Briefing paper for the LIDNS strategy meeting, FSA, 5 November, FSA (2010) Tables NDNS Headline results from Year 1 of the Rolling Programme (2008/2009) Page 44 (Table 5.4) at: (accessed 04/03/2010) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

11 6.2 Risk of widening health inequalities Marked differences in consumption levels between different social groups will make an important contribution to large social inequalities in cardiovascular disease rates, because every gram per day of TFAs consumed increases CVD death rates by 5 to 6 per cent. 27 An unpublished study of eating patterns in Tower Hamlets a deprived area in London - suggests that frequent consumption of fast food meals means that some individuals could consume between 6 and 12 per cent of dietary energy from IPTFAs. 28 Similarly high exposure to TFAs appears very likely in deprived communities throughout the UK a situation which should be investigated urgently. Tackling health inequalities is an accepted basis for government policy. It has also been an important justification for measures taken in Denmark to eliminate TFAs. Unlike the FSA review, the first report of the Danish Nutrition Council (1994) took into account whether some segments of the Danish population were at higher risk of consuming TFAs. It was estimated that a subgroup of about 150,000 adult Danes had an intake of IPTFAs that exceeded 5g per day. It was on the basis of this analysis and subsequent, supporting data that the Danish government acted in 2003 to ban foods containing < 2 per cent IPTFAs in the fats or oils used. (See section 8 for details) 27 Mozaffarian D and Clarke R: Quantitative effects on cardiovascular risk factors and coronary heart disease risk of replacing partially hydrogenated vegetable oils with other fats and oils. European Journal of Clinical Nutrition (2009), Lloyd S, Madelin T, Caraher M. (2009): Chicken, Chips and Pizza: fast food outlets in Tower Hamlets report. (Unpublished report). Centre for Food Policy, City University London. NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

12 7. Sources of trans fats in the food supply It is necessary to distinguish between IPTFAs and ruminant trans fatty acids (RTFAs) which occur naturally in the meat and dairy products of ruminant animals, as a result of microbial action in the rumen (see Figure 1). These RTFAs cannot be entirely removed from the diet (when meat and dairy are eaten), but the levels of these naturally occurring RTFAs are modest and do not constitute a significant risk factor for CHD. The major food groups contributing intakes of IPTFAs are: Fried food from fast food and other takeaway outlets Baked goods including cakes, biscuits, buns, pastries, meat pies and meat pastries Ice cream Chips and fried potato products Savoury snacks, including popcorn and chocolate confectionery Spreadable fats including margarine Some imported foods from these food groups may contain an even higher level of IPTFAs depending on their country of origin. Imported cooking oils and fats are of particular concern as they often seem to be cheaper but also high in IPTFAs. 29 Uauy R et al: WHO Scientific Update on trans fatty acids: summary and conclusions. In: European Journal of Clinical Nutrition (2009) 63, S69 30 Jacobsen M U et al (2008): Intake of ruminant trans fatty acids and risk of coronary heart disease. In: International Journal of Epidemiology, 37(1): NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

13 Types of trans fatty acids (TFAs) Industrially produced trans fatty acids (IPTFAs) (approximately 90%) IPTFA added to food product (eg cooking oil, pastry, cakes, cookies, fast food & re-use of oils in cooking processes) Eaten by consumer raised LDL; lowering of HDL; (higher risk of CHD) Naturally occurring ruminant trans fatty acids (RTFAs) (approximately 10%) Produced in rumen of animal RTFA in milk and meat Eaten by consumer raised LDL; Lowering of HDL (higher risk of CHD) food product (eg pies, pastry, cakes, fast food) Figure 1: Types of trans fatty acids (TFAs) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

14 7.1 IPTFAs in processed foods Estimates for TFA content in processed foods are based on published food composition data and self-reported data from food manufacturers. 7.2 Substitution of IPTFAs in manufactured food products To reduce trans fats content in products manufacturers must replace PHVOs with alternative fats. Studies indicate that the benefits would be greatest for replacement of PHVOs with polyunsaturated vegetable oils. 31 However, even replacement of PHVOs with (saturated) tropical oils or animal fats although not desirable - would result in some benefits, and does not support concerns that if trans fats were to be eradicated, but replaced with saturated fats, this would be harmful. A recent review from Denmark confirms that frying oils have mostly been replaced with healthier monounsaturated fatty acids (MUFAs) resulting in reduction or elimination of IPTFA levels in foods with originally high IPTFA content such as chips and frozen potato products. However, IPTFAs in most food products such as tortilla, pies, chocolate, sweets, cakes and cookies were mainly replaced by saturated fats such as coconut or palm oil. But the review concludes that as a result of the regulation in Denmark the intake of IPTFA is now insignificant across the population. 32 The effect of IPTFA reductions on saturated fat intakes in Denmark is still being monitored. 31 Mozaffarian D and Clarke R (2009): Quantitative effects on cardiovascular risk factors and coronary heart disease risk of replacing partially hydrogenated vegetable oils with other fats and oils. European Journal of Clinical Nutrition (2009), Bysted A et al (2009): Substitution of trans fatty acids in foods on the Danish market. In: European Journal of Lipid Science Technology, 111, page NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

15 7.3 IPTFAs in fast food service TFAs are found in many varieties of fast food. Some may be found in the ingredients; but some may result from frying the product in hydrogenated oils containing IPTFAs. Irrespective of the initial IPTFA levels of the frying oil, repeatedly re-heating and cooling oils can cause additional chemical changes in the oil which may result in high IPTFAs levels in the fried food. These changes in the composition of frying oils depend on a lot different factors such as the oil, how well frying is being managed, how long the oil is being used for and the types of oils being used for frying (for more information please see Annex A). The deep-fat fryer in a small take-away outlet is of particular concern as it may be exposed to wider temperature fluctuations and much longer turn-around times, compared to large scale commercial frying processes, which can have quite different implications for the quality of what is being absorbed (and eaten). In summary, both the quality of the oil and the frying process need to be addressed. Worryingly, there is very little independent data available on IPTFA levels in fast food, especially fried fast food in the UK. Preliminary data from local surveys suggests that some fast food and takeaway outlets are using hydrogenated oils with high levels of IPTFAs leading to foods containing high levels of IPTFAs. It is therefore necessary to look at data from other European countries with similar frying practices in order to show how IPTFAs can be eliminated in fast food service. International evidence shows that the levels of IPTFA in fast food can vary significantly and can be very high in some foods, which is a major concern. A German food analysis conducted by the Bavarian health ministry which looked at frying oils, bakery foods (pastries), baby food, olive oil and margarines found IPTFA levels of up to 49% of the overall fat content in four samples of frying oils. Whereas the highest level of IPTFA in bakery goods (including croissants, puff NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

16 pastries and cakes) and margarines was at maximum 10% of the overall fat content. 33 The analysis of fast food in Austria showed that IPTFA levels in French fries and burgers can range between 0.1 and 8.93% of overall fat content Actions taken in other countries/regions Industrially produced trans fats (IPTFAs) are a global public health concern and different countries have adopted a wide range of responses. Most initiatives are voluntary with regulatory action limited to Denmark, New York City, Switzerland and Austria (since September 2009). See Annex B for country by country examples. 9. Need for action in the UK 9.1 Manufactured foods Most food manufacturers are already taking steps to remove IPTFAs from processed food products. Some UK retailers and manufacturers already declare their products trans fat free, for example Marks & Spencer, ASDA and the Coop. The Co-op s strategy specifies that levels of saturates must not be allowed to increase as a result of eliminating trans fats. The British Retail Consortium (BRC) states that its members have been working with their suppliers to eliminate HVOs from their own-brand products. Other retailers including Budgens, Londis, Lidl, Netto and Spar agreed to remove HVOs from their own brand products. Food and Drink Federation (FDF) members are committed to reduce trans fat levels where technically possible without replacing them with saturated fats. The British Hospitality Association 33 Bayerisches Landesamt fuer Gesundheit und Lebensmittelsicherheit (2009): Untersuchung von trans-fettsaeuren in Frittierfetten, verschiedenen Backwaren, Babynahrung, Olivenoel und Margarinen 2008 (Trans fat analysis of different foods including frying oils). At (accessed on 02 October 2009) 34 Wagner, K-H; Plasser, E; Proell, C; and Kanzler, S. (2008): Comprehensive studies on the Trans Fatty Acid content of Austrian Foods: Convenience products, Fast Foods and Fats. In: Food Chemistry (2008), 108, page 1057 NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

17 (representing food service providers) say that members no longer use HVOs as ingredients in foods provided to institutions such as schools and care homes. 35 The NHF believes that a lesson from these food manufacturers is that removing trans fats is feasible. With the right incentives, what can be achieved by some, can surely be achieved by all. 9.2 Fast foods and take aways But while there has been progress in many sectors, the persistent presence of IPTFAs typically in cheaper, frequently eaten foods (such as fast food and snacks) means that some sections of the population have much higher intakes than the population average. Latest estimates suggest that the average person eats one in every six meals outside the home in the UK and that this trend is continuing to increase. 36 The value of the informal eating out market in the UK is 40.3 billion in The number of takeaway food outlets rose by 8% from 2008 to At a time when many high-street retail shops are facing closure, one area of growth in the UK is the fast food sector with many companies reporting increases in profits and plans to expand in the next couple of years. 38 The growth in this informal eating out sector is targeted at low-income consumers and middleincome price-conscious consumers. Econometric data suggests a trend where low-income groups are eating out more from fast food outlets seeking a bargain at a time when food and fuel prices are increasing FSA Board Paper 17 December Trans fatty acids. 36 FSA (2009): Calorie labelling and nutrition information in catering. Under: (accessed on 4/12/09) 37 Thompson, J: Britain s appetite for fast food proves insatiable. In: The Independent, 25/11/ McDonald s and Allegra Strategies (2009) Eating out in the UK 2009: A Comprehensive Analysis of the Informal Eating Out Market. Allegra, London. 39 Bowyer, S., Caraher, M., Eilbert, K. and Carr-Hill R. (2009). Shopping for Food; Lessons from a London Borough. British Food Journal, vol 111, issue 5, pp NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

18 Some of the big fast food restaurant chains such as McDonald s, KFC and Pizza Hut for example have started to reduce the level of IPTFAs to less than 2% of the overall fat content in their frying oils since However, the eating out market in the UK is not homogenous consisting of multinational fast food chains and independent small and medium sized businesses. This particular characteristic of the UK market could be one of the reasons why there hasn t yet been a consistent voluntary approach towards reducing IPTFAs in frying and cooking oils to less than 2% of the overall fat content. However, the lack of a consistent nationwide strategy to encourage independent fast food and takeaway shops to only use frying and cooking oils with an IPTFA content of less than 2% of the overall fat content is also apparent. Legislative bodies in other countries and cities such as Denmark, Seattle or New York have adopted different strategies ensuring that the fast food and takeaway sector is using frying and cooking oils with less than 2% IPTFAs of the overall fat content. While Denmark banned outright the use of frying and cooking oils with more than 2% of IPTFAs of the overall fat content, New York and Seattle have introduced legislation requiring fast food and takeaway chains with more than 15 outlets to only use cooking and frying oils with less than 2% of IPTFAs in the overall fat content. A Trans fats help center 41 was established providing detailed online information to food professionals on how to substitute HVOs and PHVOs with healthier oils containing a maximum of up to 2% of IPTFAs in the overall fat content. The website aims to enable food professionals of all sectors to comply with the regulation listing frying and cooking oils allowed under the regulation. 40 Information taken from the following companies websites (all accessed on 04/12/09): (McDonald s) Trans Fat Help Center New York City website under: (accessed 07/12/09) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

19 10. Conclusions Evidence and rationale for action On the basis of national and international evidence and a precautionary reading of the FSA 2010 analysis, we conclude that the risks to both public and individual health posed by IPTFAs in the UK food supply are unacceptably high. We believe that the public health goal should be to reduce IPTFA intakes in all population groups to as close as possible to zero per cent of dietary energy, in line with current international recommendations (WHO 2009). To achieve this, the policy should be to eliminate IPTFAs from the food supply while requiring that they are not replaced with saturated fats. We are particularly concerned about the failure of the current policy position to take into account the likely high intakes of IPTFAs by some population groups, especially children and low income consumers. We believe that there is an ethical obligation on the government to protect vulnerable consumers from the health risks of consuming IPTFAs, and, by doing so, to tackle inequalities in chronic diseases, especially coronary heart disease. There are strong grounds to argue for mandatory action by the UK government to achieve this objective: IPTFAs are harmful to human health; in fact IPTFAs represent a greater risk to health than some contaminants or pesticide residues 42. It follows that the removal of trans fats should be accorded the same priority and attention as food safety issues, and no longer perceived only as a matter of nutritional improvement; IPTFAs are found in many frequently consumed foods; 42 Mozaffarian D et al (2006): Trans Fatty Acids and Cardiovascular Disease N Engl J Med 2006; 354: NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

20 IPTFAs are generally not labelled in the UK which means that users (e.g. those working in food service) and consumers cannot easily avoid using or eating them; The need for a guarantee that IPTFAs are taken seriously throughout the food chain and will not be reintroduced into the food supply through imported foods for example and that vulnerable groups are protected; The need to ensure that removal of IPTFA s does not result in their substitution by saturated fats; and Countries such as Denmark and Austria have demonstrated that it is possible to legislate to remove IPTFAs, and that regulation has been successful in achieving its objective. The Danish regulation set a precedent for regulation by an individual Member State in the European Union, which the UK could follow without fear of being challenged by the European Commission. It is essential that elimination of IPTFAs should be integrated within a comprehensive approach to reducing saturated fats in the food supply. It is clear that a regulatory approach which specifies how oils and fats must be substituted is more likely than a voluntary approach to succeed in ensuring that saturated fat levels are not increased as IPTFAs are removed. Legislation would therefore be supportive of a saturated fat reduction programme. NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

21 11. Recommendations Recommendation 1 A ban on IPTFAs in manufactured foods We recognise that the food manufacturers and the FSA have been working together successfully over recent years to reduce IPTFA levels in manufactured food products. The speed of reformulation has certainly been hastened by the introduction of mandatory restrictions on IPTFAs in other countries. We know from industry examples that elimination of IPTFAs from processed foods, without replacing them with saturated fats, is feasible. But there is a danger of complacency. Experience from other countries shows that to ensure IPTFAs are removed from all foods, and that they are only replaced with healthier unsaturated fats, regulation is needed to complete and lock in what has been achieved on a voluntary basis. For pragmatic reasons and in line with other EU countries (Denmark and Austria), legislation should be introduced to require that IPTFA levels in fats and oils used in food manufacture do not exceed 2 per cent of overall fat content. Recommendation 2 Regulation and guidance to remove IPTFAs in the food service sector Despite the lack of independent data for the UK, it is clear that fast food outlets and takeaways (as in other countries) make a very significant contribution to trans fats intakes. There are specific challenges to removing TFAs from food that is fried and to date, this sector has not received sufficient attention lacking any legislative framework to provide guidance, support or enforcement. Practice in other countries demonstrates that there is considerable scope for action, NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

22 including regulation on TFA levels in frying oils in conjunction with guidelines and inspection criteria for frying practices. Legislation should be introduced to require that IPTFA levels in fats and oils do not exceed 2 per cent of overall fat content. Independent monitoring of the legislation could be carried out by Local Authorities through existing statutory powers of Trading Standards and/or Environmental Health officers. UK validated guidelines and information could be produced to assist the UK wide implementation of any legislation. (We understand that the FSA has been developing deep frying practice guidelines for the UK and plans to trial them. We recommend that as in Germany, guidance should also include information on wider processing issues such as using separate fryers for different food types and quality management of the frying oils used). We recommend exploring the possibility of introducing incentives for the fast food and taking away sector with regard to the supply, use and disposal of frying and cooking oil. For example, a free or subsidised oil collection and disposal service could incentivise regular replacement of frying oils which in turn could improve the frying processes and help to eliminate the IPTFA levels in food products. It could also help to ensure environmentally appropriate disposal of used oils and fats. Recommendation 3 Government monitoring of IPTFAs The government should switch its focus away from calculating mean average population intake levels (based on reported consumption patterns and data on food composition). Instead it should independently monitor absolute NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

23 measurements of IPTFA in the food supply to ensure that regulations requiring their removal are achieving such low levels of IPTFA that no population group is exposed to intakes greater than 0.5 per cent of dietary energy. This analysis could be aided by the use of modelling techniques such as that used in the NICE review on preventing cardiovascular disease (2009). 43 Such analysis should take into account the impact of reformulation considering not only TFA removal but also the favorable health consequences of using the most healthful fats and oils for TFA replacement during product reformulation. In addition, data should be collected on sub-groups in the population who consume high proportions of bakery foods or take-away foods as their mean TFA intakes may be considerably higher than the population mean. We recommend that the Government should consider adding a survey on the IPTFA content of fast and take away foods to their programme of mini surveys 44. This series of mini surveys aims to provide up-to-date information on the levels of sodium (salt), fat, sugar and a limited range of other nutrients, in processed foods. Conducting a mini survey on the IPTFA content of fast foods would demonstrate the effect (or otherwise) of policy regarding IPTFAs. Recommendation 4 Implementation of new regulations We recognise that there are a number of challenges to implementing regulations on IPTFAs in both the processed food and food service sectors, and it will require co-ordinated action by national authorities across England, Wales, Scotland and 43 Barton et al (2009): Prevention of cardiovascular disease at population level. Modelling strategies for primary prevention of cardiovascular disease. At: (accessed on 04/03/2010) 44 Information about the programme are on the FSA website, at: (accessed 19/01/10) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

24 Northern Ireland. Areas where further analysis or research will be needed include: Further research into the emerging mechanisms of harm from IPTFAs, including possible additional harm induced through an anti-insulin sensitivity mechanism; Further research on the possible relationship in humans between IPTFAs and abdominal obesity (a risk factor for diabetes), indicated by animal studies 45 ; Improved assay methods for accurately and easily determining the composition of foods and oils including techniques to measure odd cis isomers of fatty acids which are not captured by some of the standard colorimetric techniques used; Understanding the role and significance of grey markets in oils; An assessment of the risk posed by imported foods; Both health impact assessment (HIA) and regulatory impact assessments (RIA) to assess the impacts and costs of both action and inaction on IPTFAs; Consideration of licensing for fast food outlets and takeaways. 45 Kavanagh K, Jones K, Sawyer J, Kelly K, Wagner JD, Rudel LL. (2006): Trans fat diet induces insulin resistance in monkeys. Diabetes Care Proceedings of 66th Scientific Sessions of the American Diabetes Association: Abstract 328-OR. At: (Accessed 19/01/10) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

25 Glossary CHD CVD FSA HIA HVO IPTFA PHVO RIA RTFA SACN TFA WHO coronary heart disease cardiovascular disease Food Standards Agency Health Impact Assessment hydrogenated vegetable oils industrially produced trans fatty acids partially hydrogenated vegetable oils Regulatory Impact Assessment ruminant trans fatty acid Scientific Advisory Committee on Nutrition trans fatty acids World Health Organization NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

26 ANNEX A Mechanisms to reduce IPTFAs in fast food To effectively eliminate IPTFAs in fast food, actions are required that address: The types of oils in which foods are fried There are different types of frying oils some of which contain IPTFAs and others which do not or contain only very low levels. Using frying oils which do not contain IPTFAs and following the correct frying practices would ensure that fried food contains a very low amount or even no IPTFAs at all. Fast food owners would need help and advice on how to choose the right frying oil. The New York No trans fats help centre provides product lists of suitable frying oils, baking ingredients and other products. It also encourages food professionals to switch to healthier mono- and polyunsaturated fatty acids. 46 Evidence from Denmark suggests that the legislation on IPTFAs resulted in the substitution of frying oils with healthier monounsaturated frying oils such as vegetable oils. 47 As IPTFA free frying oils are already available in the UK, it appears that there is minimal cost involved switching to IPTFA-free frying oil. The composition of fast foods The amount of IPTFA levels in fried food depends on how much frying oil is being absorbed into the food during the frying process, which is determined by the amount of time the food is fried as well as the 46 DGF (2008), page Bysted A et al (2009) NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

27 composition of the food. For example, potato chips and puff pastry absorb different amounts of oil. 48 The City of New York established the No trans fats help centre 49, an online resource for food professionals explaining the new legislation on IPTFAs and providing extensive information materials of how to ensure that the professional was able to comply with the new rules. 50 Cooking practices including fry temperatures and how frequently cooking oils are changed or replenished Guidelines on optimal deep frying processes from the German Society for Fat Science explain how the right frying techniques, the right frying oil, the right frying temperature and the right maintenance of the deep fryer can not only prevent IPTFAs occurring in deep fried foods, but also the formation of acryl amide - a known carcinogen. A frying temperature not exceeding 180º Celsius and a short frying time, minimise the formation of acryl amide and IPTFAs. These are both formed in much higher quantities when the frying oil is heated to over 200º Celsius 51 meaning the higher the temperature the more IPTFAs and acryl amides are being formed. Throughout the frying process, the amount of frying oil in the deep fryer is being reduced through absorption into the food product and needs to be replaced. In addition to refilling the fryer with fresh oil, a daily exchange of 48 DGF (2008): Optimum deep-frying. Recommendations by the German Society for Fat Science, page 7 & 8. At: (accessed on 02 October 2009) 49 (accessed on 02 October 2009) 50 No trans fat NYC (2007): Choosing the fry products that are right for you. At: (accessed on 02 October 2009) 51 Ibid, page 9 NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

28 approximately 20 25% of used oil with fresh oil ensures overall that the oil can be used longer as its degradation is being prevented DGF (2008), page 12 NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

29 ANNEX B Actions in other countries Denmark: In March 2003, Denmark became the first country to introduce legislation to effectively eradicate TFAs. The Danish authorities considered that IPTFAs were unnecessary from a nutritional point of view and could easily be removed from the food supply without impacting upon product availability or the quality of foods, and with no/minimal cost implications for the food industry. They set an upper limit (2%) on the IPTFA content of fats and oils delivered direct to the consumer (including out of home food services) or to be used in food production. Importantly, the Danish Nutrition Council considered not only average population intakes, but also whether some segments of the population were at higher risk. A subgroup of about 150,000 adult Danes had an estimated intake of IPTFAs that exceeded 5g per day. They considered this situation unacceptable and recommended that intakes be reduced as far as possible. In 2006, a food analysis of 143 food products revealed that only one product contained more than 2% of IPTFA concluding that IPTFA in Denmark has virtually been eliminated from the food supply. Most importantly the analysis showed that the IPTFA intake at the individual and population level in Denmark is nearly zero. In 2009, another Danish study found that IPTFAs were mainly replaced with saturated fatty acids, mostly palm and coconut oil. However, healthier fat substitutes such as monounsaturated fatty acids (MUFAs) were used in frying fats resulting that the IPTFA content in chips, microwave oven popcorn and NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

30 various bakery products was significantly reduced or removed. The study concluded that IPTFAs intakes are near zero in Denmark. Canada: In 2006, the Canadian Trans Fat Task Force recommended a trans fat limit of 2% of the total fat content for all vegetable oils and soft, spreadable margarines, and a limit of 5% of the total fat content for all other foods, including ingredients sold to restaurants. In June 2007, Health Canada adopted these recommendations and gave industry two years to demonstrate progress in meeting the recommended targets. The levels of s in pre-packed foods need to be included on the mandatory Nutrition Facts table. The Canadian Trans Fat Task Force (2007) identified a range of healthier alternatives, including polyunsaturated and monounsaturated fats to replace TFAs, by food application (e.g. frying oils, soft margarines, hard margarines or shortening). Data from the Trans Fat Monitoring Program (Health Canada 2007) indicates that the trans fat reduction strategy in Canada was effective and achieved reductions in IPTFAs without increasing levels of saturated fat in the diet. Rules requiring mandatory labelling of TFAs in Canada have probably supported these reductions. Standardised Canadian nutrition labelling requires that in order for foods to be labelled trans fat free, foods must not only contain <0.2g of trans fat, but should also be low in saturated fat (<2g of saturated and trans fat, per reference amount and per serving). Health Canada is monitoring progress of this voluntary regulation through the Trans Fat Monitoring Program and is publishing the results on its website. New York In New York City the use PHVOs, shortenings, or margarines that are used for frying or as a spread and contain 0.5g or more of trans fat per serving was NHF position paper on the elimination of IPTFAs from foods consumed in the UK June

31 prohibited in foodservices from July This action followed an education campaign in 2005, targeted at caterers and consumers which called for voluntary reductions, this proved ineffective. From July 2008, food establishments can no longer store, use or serve any product that contains these fats and spreads and has 0.5g or more of trans fat per serving. The legislation does not however apply to pre-packed foods served in the manufacturer s original sealed packaging. There is a regulatory framework in New York the New York City Health Code which requires that all food service establishments including restaurants, caterers and mobile food-vending units must be licensed to operate. The New York City Department of Health and Mental Hygiene is responsible for the issue of permits. Switzerland In March 2008, Switzerland introduced legislation to limit the IPTFA content of plant derived oils and fats in food stuffs to a maximum of 2g per 100g. They allowed a 12 months grace period. However, from 1 April 2009 the IPTFA level will be limited in all food products to 2g or less of the overall fat content per 100g. It is not clear if this regulation also applies to out of home and take away foods. Austria In August 2009, Austria announced plans to follow Denmark s example introducing a legal limit of <2% for IPTFAs in food stuffs including processed and takeaway foods from September The new legislation includes a 12 months grace period allowing producers and retailers to use up their oil and fat stocks if necessary. However, it isn t clear whether this grace period was introduced to give out-of-home food services more time to implement the new legislation. Several Austrian food producers and retailers have welcomed the new legislation and announced that they already meet the legal requirements and will continue to eliminate IPTFAs in their products. NHF position paper on the elimination of IPTFAs from foods consumed in the UK June