The proposal to introduce a regulation for Trans Fat in PHVO was first tabled in 2004 at the Oils & Fats Subcommittee of CCFS India. Over the past five years, there have been numerous deliberations on this topic. However, no conclusive research was undertaken to estimate the dietary intake of TFA in Indian population and no scientific analysis was conducted to determine the ‘safe’ maximum limit of TFA in PHVO.

It is important to note that Food regulation in India mandates a maximum slip melting point limit of 41°C for all PHVO including Bakery Shortenings. This limit restricts the Industry to use partial hydrogenation of soft oil to achieve desired hardness in PHVO. In addition, the food regulation does not include Palm Stearin in the list of edible oils & fats. Hence the Industry is not able to use Palm Stearin to produce fats having low TFA.

In Jan 2009, Center for Science and Environment published a report on ‘Fatty Acids profile of Edible Oils and Fats in India’, which again highlighted the issue of high TFA present in PHVO. Following this report there has been a more concerted effort by the newly formed Food Safety & Standards Association of India (FSSAI) to regulate the TFA level in Vanaspati.

In March 2009 FSSAI requested the Vanaspati Industry to conduct two studies:

1. Determine different ways to reduce Trans Fatty Acid (TFA) level in PHVO.
2. Determine per capita Fats and TFA intake consumption level in India.

The Vanaspati Industry evaluated following different options available to industry to produce low TFA products.

1. Improved conditions and extent of Hydrogenation

2. Use of blending of fully hydrogenated hard fractions with soft oils

3. Use of naturally occurring hard fractions like Palm Stearin

4. Interesterification (Chemical and Enzymatic)

The various technical experiments conducted have indicated that it is possible to reduce TFA level in Vanaspati to less than 10% and still meet consumer preferences across different seasons and various parts of the country. However, slip melting point will required to be removed/relaxed from current maximum limit of 41°C. Detailed report in included as Annexure 2.

Indian food regulation mandates a maximum melting point of 41°C for Vanaspati. It is important to note that:

1. Scientific studies have confirmed that there is little correlation between melting point and digestibility of fats.

2. High melting point fats occur in nature as well. Humans have been consuming animal fats in different parts of the world through ages and no deleterious effects have been reported so far.

3. Digestion involves enzymatic splitting into constituent Fatty Acids and is not related to melting point of the fat.

4. CODEX Standards for PHVO (Vanaspati) do not include an upper limit on melting point.

5. CODEX includes hard fractions like Palm Stearin with melting point of 44°C - 52°C in list of edible oils & fats.

6. Countries like Denmark, Canada, USA and others that have implement Trans Fat regulation follow CODEX standards and do not mandate any maximum melting point limit.

In addition to the technical experiments, the Industry commissioned Frost & Sullivan to conduct a study to determine the per capita dietary intake of TFA in India. The study was based on secondary sources of information such as Government of India websites, National Survey results, WHO, other internet databases, etc.

The study has shown that India’s per capita Fat intake is 44 g/day of which the per capita TFA intake (including ruminant sourced of TFA) is 1.6 g/day. This level of TFA intake translates to 0.6% of total energy, which is well below the WHO recommended level of less than 1%. TFA intake from industrially produced sources i.e. PHVO is less than 1 d/day or 0.26% of Energy. Detailed report in included as Annexure 3.

The findings of these two studies were shared with FSSAI in Oct 2009. As a follow up, FSSAI requested the Industry to constitute a technical committee comprising of eminent scientists from fields of lipids and oils & fat technology. This technical committee will review the findings of experiments conducted by the Industry and submit a recommendation to FSSAI.

In Nov 2009, the Industry constituted this committee comprising of:

Dr DN Bhowmick, Dean-Academic Programmes & Professor, ICT (formerly UDCT)
Dr RBN Prasad, Dy Director and Head, Lipid Science & Technology Division, IICT
Dr JS Pai, Executive Director, Protein Foods & Nutritional Development Association of India
Dr G Subbulakshmi, Former Professor and HOD, Food Science & Nutrition, SNDT Women’s University
Mr PK Sardar, Ex Chief Director Directorate of Vanaspati, Vegetable Oils & Fats.

The committee has met twice on 30th Nov and 16th Dec where they reviewed the results of the studies conducted by the Industry. This Committee has observed that there is merit in Industry’s recommendation to remove melting point limit and align the standards with CODEX, so as to reduce TFA level to less than 10%. Draft minutes of the meeting are included as Annexure 4.

In Dec 2009, FSSAI has requested National Institute of Nutrition to conduct a national consultation to discuss the proposed Trans Fat regulation. This meeting has been scheduled for 7th Jan 2010. A tentative list of attendees for this meeting is included as Annexure 5.

FSSAI intends to release a draft notification on the regulation post this national consultation.

Annexure:

CSE report of Jan 2009
Summary of Technical Experiments conducted by the Industry
Frost & Sullivan report on dietary intake of TFA in India
Draft meeting minutes of Technical Committee
Tentative List of attendees for National Consultation on proposed Trans Fat regulation in India