Comments and Correspondence
ICGMA COMMENTS ON DEFINITION OF TRANS-FAT
Dr. Rolf Grossklaus
Chairman of the Codex Committee on Nutrition and Foods for the Special
Dietary Uses
Bundesinstitut Fur Risikobewertung (BfR)
P.O. Box 33 00 1314191
Berlin, Germany
Dear Dr. Grossklaus:
The International Council of Grocery Manufacturers Associations
(ICGMA) is pleased to provide input on Matters Referred to the Committee
by the Codex Alimentarius Commission and/or Codex Committees Discussion
Paper on Definition of Trans-Fat.
ICGMA, a recognized NGO before the Codex Alimentarius Commission,
represents the interests of national and regional associations who
collaborate with all sectors of the consumer packaged goods industry.
ICGMA promotes the harmonization of scientific standards and policies
concerned with health, safety, packaging, and labeling of foods,
beverages, and other consumer packaged goods. ICGMA also works to
facilitate international trade in these sectors by eliminating or
preventing artificial barriers to trade.
ICGMA urges Codex Committee on Nutrition and Foods for Special
Dietary Uses (CCNFSDU) to adopt a clear definition of trans fatty
acid.
The definition proposed in the Codex Discussion paper appears to
exclude naturally occurring, non-conjugated trans fat from the definition
when in fact, these trans fats should be included in the definition.
The current draft text proposes that trans fatty acids will be defined
based on both analysis and on the origin of the trans fatty acids.
However, some trans fatty acids produced by bio-hydrogenation will
have the same structure as some trans fatty acids produced “by
partial hydrogenation in the presence of a suitable chemical catalyst”.
In addition, there is no scientific basis for the distinction between
trans fatty acids produced by industrial hydrogenation and by bio-hydrogenation,
as the available epidemiological data suggest that industrial and
ruminant trans fatty acids have the same effect on heart health
(Weggemans et al. “Intake of ruminant versus industrial trans
fatty acids and risk of coronary heart disease. What is the evidence?”
Eur.J. Lipid Sci. Technol. 106 (2004) 390-397). Furthermore, this
distinction would create analytical difficulties, because it would
be necessary to check the origin of the analyzed trans fatty acids.
Those trans fatty acids resulting from industrial processes using
“chemical catalyst” would count as trans fatty acids,
whereas those obtained from fats from ruminant origin would not
count as trans fatty acids. ICGMA does not support this position
as the proposed definition seeks to legitimize the definition based
on the way trans fats are made rather than the chemical composition
of the trans fat.
ICGMA believes the definition of trans fatty acids should be harmonized
in conjunction with other established definitions. Several countries
have existing regulatory definitions that include naturally occurring
non-conjugated trans fats. This language is based on careful deliberations
about the scientific appropriateness of the definition.
ICGMA supports a definition on trans fatty acids based on the amount
of trans fatty acids determined by the total amount of trans fatty
acid analyzed minus the factions known as conjugated linoleic acids—CLA’s.
ICGMA supports the following definition for trans fatty acids:
For the purpose of the Codex guidelines on Nutrition Labelling
and other related Codex Standards and Guidelines, trans fatty acids
are defined as all unsaturated fatty acids having non-conjugated
double bonds in the trans configuration. Conjugated linoleic acid
would be excluded from the definition of trans fat.
ICGMA opposes the use of “Background Information on Trans
Fatty Acids” as part of the discussion document. The creation
of a background paper on the health effects of trans fatty acids
is not within the scope of the request made of the CCNFSDU working
group in establishing a definition for trans fatty acids, therefore
it should not be included in the discussion of this issue.
ICGMA urges the CCNFSDU to pursue a definition that will promote
the harmonization of scientific standards and policies concerned
with health and labeling of foods and beverages. ICGMA urges CCNFSDU
to facilitate international trade in the food and beverage sector
by eliminating or preventing artificial barriers to trade with our
global partners through adoption of an accurate scientific definition
that can be consistently implemented worldwide.
ICGMA appreciates the opportunity to provide these comments to
Codex. Please contact me at (202) 337-9400.
Sincerely,
Alison Kretser
cc: Codex Alimentarius Commission, Rome, Italy
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