Food Industry Perspective on Eliminating Trans Fats in Food Products
March 31, 2005
In early 2005, Agriculture and Agri-Food Canada contracted the JRG Consulting Group [Note 1] to explore the possible impacts on the Canadian food industry of a significant reduction or elimination of industrially produced trans fatty acids (TFAs) in food products. The project also provided an opportunity to gather information on industry's readiness to declare the amount of trans fat on pre-packaged foods as part of the revised nutrition labelling requirements. This report is based on 48 of the 50 interviews conducted with food industry representatives from the areas of food retail, food service (including distribution), edible oil and margarine manufacturers, ingredient manufacturers and suppliers, snack food manufacturers, bakery and related, breaded meat products, other food manufacturers (including entrée manufacturers), suppliers to agriculture and associations.
Sources of Trans Fats
Partially hydrogenated vegetable oils and vegetable shortenings, because of their stability, functionality, low levels of saturated fat and absence of cholesterol, have been used as an alternative to animal-based saturated fats. They are the major source of TFAs in the North American diet and are now known to pose a potentially greater health risk than the saturated fats they replaced. About half of the 805,000 tonnes of vegetable oils used in Canada in 2001 were partially hydrogenated and thus a source of TFAs. The levels of TFAs in a typical North American diet have increased markedly during the past decade, largely driven by higher consumption of shortenings, mainly as an ingredient in processed foods.
Estimates of the per capita (adult) intake of total TFAs in the North American diet range from 6.0 to 15.0 grams/person/day. The average Canadian daily intake is 9.5 grams TFAs/person/day with 8.5 grams being industrially produced (1.8 grams from margarine products; 4.0 grams from processed foods; 2.7 grams from restaurant meals) and 1.0 gram being naturally produced by ruminant animals.
Industry Awareness of Trans Fats and Labelling Legislation
Awareness of the Issue
There is a high awareness among Canada's food industry of the issues associated with trans fat.
- Mandatory label declaration-98% of the food industry respondents were aware of the labelling regulations that require mandatory declaration of trans fats in the Nutrition Facts panel of pre-packaged food products by mid-December 2005.
- Parliamentary motion-96% were aware of the parliamentary motion introduced in 2004 concerning the reduction or elimination of industrially produced TFAs in food products.
- Issues raised by customers and suppliers-82% of food manufacturers indicated that their customers (retailers, food service, other processors) or their suppliers had raised the TFA issue, with more customers than suppliers having done so.
Compliance with Labelling Legislation
Only 19% of the food companies indicated that introduction of mandatory nutrition labelling had been a major factor in the company's decision to reduce or eliminate TFAs.
- Most (76%) expected to be in compliance with mandatory trans fat labelling requirements by the end of 2005, whereas 7% did not expect to meet the deadline.
- Compliance obstacles include: labelling-related issues (cost of nutritional analysis, cost of new labelling equipment and printing); availability of non-TFA solutions; lack of information; and limited time available for compliance.
- Leading food companies were either in compliance, or expected to be by the deadline, having started on this initiative well in advance of the requirement.
- While small companies with under $1 million in sales have an additional 2 years to comply, small companies with sales over this threshold face significant challenges.
Adaptation Strategies for Reducing Trans Fat in Processed Foods
While trans fat reduction is seen to be an issue for a number of pastry products, the plan most food companies (68%) have to reduce TFAs in food products varies according to the product line.
- 47% were planning to reduce TFAs to a level that would allow a
"trans fat free"claim;
- 29% were aiming to be in compliance with regulations on labelling, but not necessarily to reduce or eliminate TFAs;
- 23% were planning to eliminate TFAs, or to eliminate them where possible; and
- 3% were reducing TFAs but not low enough to make a "trans fat free" claim.
Sources of Information
- 71% of the food companies interviewed have a technical team working on the TFA issue. The rest either do not have a team, or have only one person such as the owner-operator working on the issue (particularly true with smaller food manufacturers).
- 60% of the manufacturers indicated that their suppliers of fats and oils have assisted with solutions to reduce the amount of trans fats.
Approaches Being Used or Considered
Many of the food companies indicated that elimination or substantial reduction of trans fats would result in a change in their products or in their product line, with 22% expecting a major change and 19% expecting a potential or possible change.
Companies were found to be using a combination of the three tactics probed: producing line extensions (continuing to produce the traditional product as well as a
"trans fat free" reducing TFAs only in existing products; and focusing only on reducing TFAs in new products.
Several approaches are available to reduce trans fats. The respondents indicated that:
- 67% would use different fats and oils;
- 20% would use primarily different processes and/or formulations;
- 8% would use a combination of fats or blends, processes and input materials; and
- 5% would use different input materials.
Canola oil and palm or modified palm oil were by far the most likely mentioned replacements for trans fats, followed distantly by 11 other types including non-hydrogenated canola and soybean oil. Almost one quarter (24%) indicated they were planning to investigate non-fat substitutes in some of their formulations; emulsifiers, modified starch and gums were specifically mentioned.
Potential Impacts of Removal or Reduction of Trans Fat
- All companies interviewed see this as an important business issue, with 38% considering it to be a
"top priority", 23% calling it
"very important", and 38%
- They view reduction of TFAs as being necessary to remain competitive, but with all companies moving in the same direction, 49% did not believe it would provide a competitive advantage, whereas 24% did.
- 44% are not planning to specifically introduce a new product with reduced TFAs. Yet, for some companies any new product launched will be a TFA-reduced product.
TFAs are a significant business concern for Canada's food industry. For the food companies surveyed (excluding fat and oil suppliers):
- On average, 52% of product lines (or business volumes) are affected by TFAs.
- For 29% of the companies, the TFA issue affects over 90% of their business volume.
Respondents indicated other impacts related to reduction or elimination of TFAs:
- 62% mentioned having to change product formulation; a few mentioned only having to change the fats and oils used.
- 31% have had to invest in, or expect to invest in, new equipment (such as handling equipment, processing equipment, and labelling and printing equipment).
- While 31% did not expect to make a change in food manufacturing procedures (such as longer baking time, or different temperatures) with formulations that have reduced TFAs, an additional 60% were still unsure.
The TFA issue is expected to increase costs for food manufacturers: 75% indicated that TFA-reduced products have higher input costs; only 4% indicated no cost effect. The major areas of higher costs include the fats and oils, supply chain costs, and loss of production efficiencies.
The main problems encountered by food industry can be grouped into the following areas:
- food product attributes (matching the existing products for taste, colour and texture);
- functionality (finding non-trans alternatives that work);
- availability of TFA alternatives (insufficient volumes available);
- new processes associated with TFA alternatives (reformulation, storage adjustments);
- labelling issues (labelling input costs, supporting analytical tests);
- marketing and product positioning; and
- costs incurred.
Availability of TFA Alternatives
Just under two thirds (63%) have been able to find TFA alternatives through their suppliers, while 22% indicated they have not. Comments centred on availability or functionality of alternatives, responsiveness of suppliers, and length of time spent on resolving the TFA issue.
The ease of replacing TFAs with substitutes (in terms of functionality and product attributes) was reported to differ by product.
Ease of Finding TFA Alternatives by Product
Breads and rolls
Cookies and muffins
Products with no texture issues
Laminates (bakery products with layers of shortening and dough)
Products with naturally occurring TFAs
By reducing TFAs, respondents expected to face product-related impacts in the areas of flavour, texture, shelf life issues and product stability.
Many of the food companies (58%) indicated encountering challenges related to labelling of trans fats. The comments centred on:
- knowledge of the standards associated with labels;
- costs associated with labelling (reanalysis, printing equipment, printing costs);
- complexity of the task;
- harmonization with the U.S.; and
- labelling and communicating with consumers (difficulty labelling products made in-store; consumer perception that trans fat content must be zero).
Trans Fat-Issues for Consideration
The survey of Canadian food industry representatives raised a number of issues.
- TFA Alternatives and Food Product Attributes
- Increase in use of saturated fats (such as palm, fully hydrogenated)
- Difficulty of replacing TFAs in some products, such as bakery products
- Product shelf life can decrease
- TFAs present in deodorized oil in small quantities
- TFAs created in some food manufacturing processes, such as frying
- Transition Issues to Mandatory Label Declaration
- Some TFA alternatives are not readily available
- Difficulty in having labelling and packaging ready for December 2005
- Better solutions are being developed, and time is required for testing and labelling
- Reluctant to move too quickly as cheaper solutions may become available
- Labelling Issues
- Inclusion of naturally occurring TFAs with the declaration of industrially produced TFAs
- Potential misuse of
"free of trans fats"claim in multi-serving products that exceed a total of 0.2 grams of TFAs
- Identification of labelling equipment appropriate for in-store bakery use
- Cost of printing software and equipment
- Cost of nutritional analysis per product
- Repeated nutrition analysis and label reprints as TFA-free solutions are developed
- Harmonization with the U.S.
- Different criteria for
"trans fat free"claim in U.S. (less than 0.5 grams per serving) versus Canada (less than 0.2 grams per serving)
- Different criteria for
- Enforcement and Compliance Issues
- Enforcement of mandatory labelling requirements on imports
- Degree of precision on testing is ± 0.3 grams, whereas requirement to make a
"trans fat free"claim is less than 0.2 grams per serving
- Those who delay may have an economic advantage
- Supply Chain Issues
- Higher costs in the supply chain to handle liquid product (storage tanks, staff training)
- Higher costs due to shorter shelf life (more frequent ordering of smaller quantities)
- Cost-Related Areas
- Higher supply chain costs
- Higher costs of alternative fats and oils
- Higher equipment costs (storage, piping, alterations to equipment)
- Labels and associated packaging and printing equipment
- Nutrient analysis to support label declarations (~ $500 to $800/product); possible need to analyze more than once as new solutions come into the market
- More staff, or contracts, to find solutions and comply with labelling requirements
- Impact on Smaller Food Manufacturers
- Do not have in-house resources, or technical capacity
- Suppliers of fats and oils are focusing efforts on larger accounts
- Significant capital costs for small operators (cannot benefit from high volume discounts)
- Shorter shelf life means lot purchases too small to qualify for minimum order discounts
- Need to be absolutely certain before making changes
- Impact on Domestic Oilseed Industry
- Reduction in demand for domestically grown oilseeds
- Increase in use of imported oils (such as palm oil)
- Opportunity for new varieties for specialty oils (such as high oleic sunflower oil, low linolenic/high oleic canola oil)
- Costs of identity preservation programs to deliver specialized seed varieties
The study of Canadian food industry on which this report is based identified a number of issues associated with a move to significantly reduce or eliminate TFAs in foods. These issues range from the functionality of the alternative fats and oils, to the attributes of the food product (including sensory evaluation), to an associated set of labelling and harmonization issues. Addressing these issues in a short period of time will be more difficult for food companies that do not have the scope and resources of some larger multi-national food manufacturers.
For further information, contact the Food Regulatory Issues Division.
- Footnote 1
The study team comprised Dr. John Groenewegen of the JRG Consulting Group, Mr. Alan Beswick of A.H. Beswick & Associates, Dr. Bruce Holub associated with the University of Guelph, and Mr. Bruce Johnson of Windrow Consulting.
Return to footnote 1 referrer