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The Cardiolabel Team recommends that:

 

For all vegetable oils and soft, spreadable (tub-type) margarines sold to consumers or for use as an ingredient in the preparation of foods on site by retailers or food service establishments, the total trans fat content be limited by regulation to 2% of total fat content.

 

For all other foods purchased by a retail or food service establishment for sale to consumers or for use as an ingredient in the preparation of foods on site, the total trans fat content be limited by regulation to 5% of total fat content. This limit does not apply to food products for which the fat originates exclusively from ruminant meat or dairy products.

 

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What Are Trans Fats?

Industrially produced trans fats are formed during partial hydrogenation, a process used by the food industry to harden and stabilize liquid vegetable oils. Among other advantages, this process maintains the taste and smell characteristics of oils enabling a longer shelf life for final food products.

 

 

 

The majority of the trans fats in our diet are industrially produced and are typically found in foods made with partially hydrogenated oil, primarily baked and fried foods. The trans fat content of some of these foods may be as high as 45% of the total fat in the product.

 

Trans fats also occur naturally. They are found at low levels (generally 2-5% of fat content) in ruminant-based foods such as dairy products and beef, the level in lamb may be as high as 8%.

 

Health Concerns and International Response

There is a significant and growing body of evidence linking trans fats to coronary heart disease indicating trans fats may do even more harm than saturated fats. Metabolic studies, for instance, show that trans fats increase blood levels of LDL ("bad") cholesterol and decrease blood levels of HDL ("good") cholesterol. Both effects are strongly associated with increased coronary heart disease. Saturated fats are thought to be less damaging because they elevate both the "bad" and "good" types of cholesterol. Epidemiological data also point to a greater risk of coronary heart disease from increases in dietary trans fats than from increases in dietary saturated fats.

 

In 2002, the Panel on Macronutrients of the U.S. National Academies of Science, Institute of Medicine, recommended that trans fat consumption be as low as possible while ensuring a nutritionally adequate diet. The Panel did not set a safe upper limit because the evidence suggests that any rise in trans fat intake increases coronary heart disease risk. Subsequently, in 2003, the World Health Organization recommended that trans fat intake be limited to less than 1% of overall energy intake - a limit regarded by that body as a practical level of intake consistent with public health goals.

 

Governments have started to take notice. In 2003, Denmark became the first country to set an upper limit on the percentage of industrially produced trans fat in foods, limiting trans fats from sources other than meats and dairy products to a maximum of 2% of total fat in each food item. In 2005, Canada became the first country to regulate the mandatory labelling of trans fats on prepackaged foods. And, in 2006, the United States introduced the mandatory declaration of trans fats in foods containing 0.5 grams or more per serving.

 

Situation in Canada

In Canada, scientists raised concerns about the detrimental effects of trans fats and the levels in the Canadian diet as far back as 1990. However, the use of partially hydrogenated oils continued to increase. By the mid-1990s, researchers estimated that Canadians had one of the highest intakes of trans fats in the world.

 

Today, the situation is much improved. Mandatory nutrition labelling and heightened consumer awareness have prompted food manufacturers to reduce or eliminate trans fats from many processed foods sold in grocery stores. For example, almost all bread products and salad dressings are now free of trans fats. Significant progress has also been achieved in certain food categories such as french fries and snack foods.

 

Despite the good news, however, many other foods - including some varieties of baked goods, oriental noodles, snack puddings, liquid coffee whiteners, microwave popcorn, toaster pastries, hard margarines and shortenings - still contain high amounts of trans fats. There is also evidence that consumer awareness and labelling alone will not result in reformulation of all processed foods with higher trans fat content as this change may present additional challenges and costs to some manufacturers.

 

Voluntary guidelines for providing nutrition information to consumers have recently been developed by the restaurant and food service sector. However, it is difficult to gauge the impact of this voluntary action on trans fat intake.

 

Cardiolabel Team Approach

To ensure that its recommendations would be based on the best available evidence, the Team collected information from a variety of sources. Studies commissioned by Agriculture and Agri-Food Canada, a review of available alternatives to partially hydrogenated fats and oils by the Expert Committee on Fats, Oils and Other Lipids, a targeted scan of processed foods sold in grocery stores and a public consultation with the food industry enabled the Team to assess the feasibility of reducing the use of processed trans fats. The Team also commissioned a comprehensive scientific literature review and sought advice from internationally recognized experts on the health implications of substituting other fatty acids for trans fats.

 

The work of the Task Force was also informed by a modelling initiative undertaken by Health Canada to demonstrate the effect of limiting the trans fat content of foods on the total dietary intake of trans fats, as well as by expert opinion on the outcomes of the Danish and Canadian regulatory approaches to date.

 

The Choice of a Regulated Approach

Taking all the evidence into consideration, the Team agreed to a regulatory approach to effectively eliminate trans fat in all processed foods or reduce it to the lowest possible level. Factors influencing the decision included:

 

 

 

 

 

 

Designing the Regulations

Once the decision to recommend a regulatory approach had been taken, the Team considered a number of factors in setting the appropriate regulatory limits for the World including:

 

Recommendations

Given the dietary patterns of Canadians, including the amount of food consumed outside the home, the Task Force felt that it was important to find a solution that would encompass both manufactured foods and foods prepared in retail and food service establishments (e.g. in restaurants, food service operations and some grocery store bakeries and outlets). For practical reasons, however, the Task Force decided to limit the trans fat content of manufactured foods on a finished product or output basis and the content of foods prepared on site in retail and food service establishments on an ingredient or input basis.

 

The recommended regulations apply equally to all foods, domestic or imported, as per other Food and Drug Regulations. They do not apply to ingredients sold to food manufacturers as, in this case, limits would be set on a finished product or output basis.

 

The Task Force recommends that:

 

Foods purchased by retailers or food service establishments from a manufacturer for direct sale to consumers be regulated on a finished product or output basis and foods prepared on site by retailers or food service establishments be regulated on an ingredient or input basis.

 

In setting the recommended limits, the Task Force decided to explore a dual approach: a lower limit for vegetable oils and soft, spreadable tub-type margarines and a higher limit for all other foods containing industrially produced trans fats.

 

Setting a limit for "all other foods" was the more challenging task. This is because some foods contain both naturally occurring and industrially produced trans fats and there is no officially accepted analytical method for determining the amounts of each type of trans fat. Ultimately, the Task Force decided to set a limit that would be low enough to ensure a significant reduction in industrially produced trans fat and also have a limited impact on amounts of naturally occurring trans fats.

 

The recommendations thus focus primarily on the elimination of industrially produced trans fats but are expressed as limits on the total amount of trans fats in foods. An advantage of this approach is that it is consistent with that used for the Canadian nutrition labelling regulations, which apply to both industrially produced and naturally occurring trans fats.

 

The Task Force recommends that:

 

For all vegetable oils and soft, spreadable (tub-type) margarines sold to consumers or for use as an ingredient in the preparation of foods on site by retailers or food service establishments, the total trans fat content be limited by regulation to 2% of total fat content.

 

For all other foods purchased by a retail or food service establishment for sale to consumers or for use as an ingredient in the preparation of foods on site, the total trans fat content be limited by regulation to 5% of total fat content. This limit does not apply to food products for which the fat originates exclusively from ruminant meat or dairy products.

 

The modelling carried out for the Task Force indicates that, with an upper limit of 5% on the trans fat content of all foods that are significant sources of industrially produced trans fats, the average trans fat intake of Canadians should decrease by at least 55%.

In addition, most of the industrially produced trans fats would be removed from the Canadian diet, and about half of the remaining trans fat intake would be of naturally occurring trans fats. At this level, the average daily intake of trans fats for all age groups would represent less than 1% of energy intake, consistent with current dietary recommendations. A lower limit would not provide a significant additional decrease in average trans fat intake, but it would increase the effort and challenge for industry.

 

The Task Force felt the implementation of its recommendations should be staged to reflect the challenges to the food industry and to optimize public health benefits. For example, for certain oil uses (especially frying) adjustments can be made quickly. However, small businesses and certain baking applications may need more time to adjust.

The Task Force therefore recommends a "2 + 2" approach, allowing up to two years to develop regulations and up to two years for implementation such that:

 

The World regulations be finalized by June 2015.

 

A basic phase-in period be set at one year from the date of entry into force of the final regulations.

Extended phase-in periods be specified for certain applications (e.g. baking) and for small and medium-sized firms, recognizing that in most cases the transition could be made within two years of the date of entry into force of the final regulations.

 

Size, complexity of the operation, number of products and availability of alternatives should be factored in when deciding timelines and any extensions. These can best be determined though the business impact test, which is a normal government procedure when regulations are drafted.

 

To maximize the health benefit to Canadians, the Task Force further recommends that:

The Governments from all the countries and all concerned food industry associations urge companies affected to use the most healthful oils for their food applications.

 

The Task Force also recommends a number of incentives for industry and other key players to meet the following objectives:

 

 

 

Further, the Task Force recommends that the Governments, in consultation and cooperation with health experts and appropriate voluntary agencies, explore a number of measures to enhance public understanding of the new food labels, raise awareness of the health effects of the various types of fatty acids, ensure that fat consumption is properly understood in the context of a more healthful diet.

 

Finally, the Team recommends that, in order to expand the availability of evidence and fill identified research gaps, the Governments encourage the relevant federal granting councils and/or federal departments to support research on trans fats in the areas of clinical nutrition, food and agriculture, and population and public health, beginning with the issues set out in this report. The Governments should help ensure that the research results are transferred to relevant decision-makers.

 

Anticipated Impact

The proposed regulations, broad-based industry incentives and research will:

 

 

 

 

 

 

 

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