Policy
position
paper
National Heart Forum position paper
on the elimination of industrially-produced
trans fats (IPTFAs) from foods consumed in the UK
June 2010
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
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 energy3.
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
health4. 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:
http://www.food.gov.uk/multimedia/pdfs/board/fsa071207.pdf (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:
http://www.sacn.gov.uk/pdfs/sacn_trans_fatty_acids_report.pdf (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:
http://www.nice.org.uk/nicemedia/pdf/Modelling%20strategies%20for%20primary%20prevention
%20of%20cardiovascular%20disease.pdf (accessed on 17/11/2009)
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
June 2010
3
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 2010.
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: http://www.scottish.parliament.uk/s3/bills/membersbills/documents/
Finaltransfatsconsultation.pdf (accessed on 01 October 2009)
6
The Scottish Parliament: Proposals for members‟ Bills. At:
http://www.scottish.parliament.uk/s3/bills/MembersBills/ (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:
http://www.bmj.com/cgi/content/full/340/apr15_1/c1826 (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.
http://www.nice.org.uk/nicemedia/pdf/CVDEP9TransFats.pdf (accessed on 18/09/09)
9
UKFPH: 12 Steps to better public health – a manifesto. At:
http://www.fph.org.uk/12_steps_to_better_public_health_%E2%80%93_a_manifesto (accessed
27 April 2010)
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
June 2010
4
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 2010
5
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.12
3. 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 26
12
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: 1601-13
14
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 2010
6
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.”15
4. 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: 1601-13
16
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 2010
7
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 2-17. 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.18
5. 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 data22, 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:
http://www.europarl.europa.eu/activities/committees/studies/download.do?file=23531
18
Interagency Working Group on food marketed to children (15 December 2009): Tentative
proposed nutrition standards. At: http://cspinet.org/new/pdf/ftcnewstandards.pdf (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:
http://www.food.gov.uk/multimedia/pdfs/board/fsa071207.pdf (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:
http://www.food.gov.uk/science/dietarysurveys/ndnsdocuments/ndns0809year1 (accessed on
04/03/2010)
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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half the maximum recommended average intake of 2 per cent of food energy
(approximately 5g per day23).
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
FSA (2010): National Diet and Nutrition Survey. Headline results from Year 1 of the Rolling
Programme (2008/2009), page 45 at:
http://www.food.gov.uk/multimedia/pdfs/publication/ndnsreport0809year1results.pdf (accessed
04/03/2010)
24
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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9
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 19-64 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, 2007
FSA (2010) Tables – NDNS Headline results from Year 1 of the Rolling Programme
(2008/2009) Page 44 (Table 5.4) at:
http://www.food.gov.uk/multimedia/pdfs/publication/ndnstables0809year1results.pdf (accessed
04/03/2010)
26
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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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), 1–12
28
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 2010
11
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.29 30
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):173-82.
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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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
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 2010
13
raised LDL;
Lowering of HDL
(higher risk of CHD)
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), 1–12
32
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 574-583.
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
June 2010
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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 2010
15
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.34
8. 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
http://www.lgl.bayern.de/lebensmittel/trans_fett_2008.htm (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
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(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 2009. The
number of takeaway food outlets rose by 8% from 2008 to 2009. 37
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.39
35
FSA Board Paper 17 December 2007. Trans fatty acids.
FSA (2009): Calorie labelling and nutrition information in catering. Under:
http://www.food.gov.uk/healthiereating/healthycatering/cateringbusiness/calorie (accessed on
4/12/09)
37
Thompson, J: Britain‟s appetite for fast food proves insatiable. In: The Independent, 25/11/2009
38
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 452-474.
36
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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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 2007.40 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):
http://www.makeupyourownmind.co.uk/tfa.html (McDonald‟s)
http://www.pizzahut.co.uk/restaurants/menus--deals/dietary-information.aspx
http://www.kfc.co.uk/about-kfc/news-and-pr/1023/kfc-removes-trans-fats-from-products-sold-inkfc-stores-in-the-uk-and-ireland/
41
Trans Fat Help Center New York City website under:
http://www.citytech.cuny.edu/notransfatnyc/english/frying.html (accessed 07/12/09)
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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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 residues42. 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: 1601-13
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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
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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
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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
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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
surveys44. 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:
http://www.nice.org.uk/nicemedia/live/11881/45710/45710.pdf (accessed on 04/03/2010)
44
Information about the programme are on the FSA website, at:
http://www.food.gov.uk/science/dietarysurveys/minisurveys/ (accessed 19/01/10)
NHF position paper on the elimination of IPTFAs from foods consumed in the UK
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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
studies45;

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 2006. Proceedings of 66th Scientific Sessions of
the American Diabetes Association: Abstract 328-OR. At:
http://professional.diabetes.org/Abstracts_Display.aspx?TYP=1&CID=47221 (Accessed 19/01/10)
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Glossary
CHD
coronary heart disease
CVD
cardiovascular disease
FSA
Food Standards Agency
HIA
Health Impact Assessment
HVO
hydrogenated vegetable oils
IPTFA
industrially produced trans fatty acids
PHVO
partially hydrogenated vegetable oils
RIA
Regulatory Impact Assessment
RTFA
ruminant trans fatty acid
SACN
Scientific Advisory Committee on Nutrition
TFA
trans fatty acids
WHO
World Health Organization
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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
47
DGF (2008), page 12
Bysted A et al (2009)
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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
Celsius51 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: http://www.dgfett.de/material/optimum_frying.pdf (accessed on 02 October 2009)
49
http://www.citytech.cuny.edu/notransfatnyc/ (accessed on 02 October 2009)
50
No trans fat NYC (2007): Choosing the fry products that are right for you. At:
http://www.citytech.cuny.edu/notransfatnyc/english/frying/chooseaproduct.pdf (accessed on 02
October 2009)
51
Ibid, page 9
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approximately 20 – 25% of used oil with fresh oil ensures overall that the
oil can be used longer as its degradation is being prevented.52
52
DGF (2008), page 12
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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
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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
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prohibited in foodservices from July 2007. 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 2009.
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.
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