Government Response to the Interim Recommendations of the Trans Fat Task Force

Introduction

The Government of Canada welcomes the Interim Report of the Trans Fat Task Force and commends the members of the Task Force for their hard work. We would also like to thank all those who contributed to the Task Force's consultation on alternatives for the replacement of trans fats.

The Government of Canada is pleased by the Task Force's findings that within the agriculture and food industry there is a strong awareness of the nature and importance of the trans fat issue, an acceptance of the need for change, and a commitment to change. Furthermore, some parts of the industry have already made considerable progress in addressing this issue.

This does not mean that all challenges have been overcome. The Task Force's Interim Report acknowledges the obstacles currently faced by industry in moving towards the elimination of processed (industrially produced) trans fat from Canadian foods. In developing its recommendations, the Task Force has considered, among other things, sectors that will experience more difficulty in achieving the expected outcome.

As with other recent government initiatives, openness and transparency is a cornerstone of this process. The Task Force's consultation process permits the engagement of all interested parties. W e encourage all stakeholders, particularly the consumer, nutrition and health research sectors, to participate in the next consultation on the health impacts and consumer implications of the proposed alternatives to trans fats. This consultation is expected to take place in fall 2005.

There are many stakeholders who have a responsibility in implementing the recommendations of the Task Force. We also recognize the importance of providing consumers with information. The release of this Interim Report provides initial recommendations for action that can be initiated now to tackle the issue of industrially produced trans fat. The Government of Canada encourages all parties to start these actions now, instead of waiting for the Task Force's final recommendations. This report details some of the immediate steps the Government of Canada will take in response to the Task Force recommendations. All documents related to the work of the Task Force.

Task Force on Trans Fats

On November 18, 2004, following a discussion on trans fat in the House of Commons, Health Canada announced that it would work, in conjunction with the Heart and Stroke Foundation of Canada, through a multi-stakeholder Task Force to develop recommendations and strategies for reducing trans fats in Canadian foods to the lowest levels possible.

The Task Force is building upon findings of a consultation process with scientists and industry initiated by the Heart and Stroke Foundation of Canada. It is exploring healthy alternatives to fats and oils high in trans fats, examining available regulatory options, and considering ways to educate the public on trans fat. The Task Force gathers people with various strengths and perspectives and includes participants from the food producing, processing and manufacturing industries, the restaurant and food service industry, governments, health and consumer interest organizations, and academia.

The Task Force was charged to provide the Minister of Health, by the end of fall 2005, with recommendations for both an appropriate regulatory framework and strategies for the introduction and widespread use of healthy alternatives to achieve the objective of reducing trans fat content in foods sold in Canada to the lowest levels possible.

In keeping with the Trans Fat Task Force Terms of Reference, the interim report focuses on providing guidance mainly for the food processing industry to take action to reduce industrially produced trans fats in Canadian foods to the lowest level possible. The report also provides guidance to consumers and the restaurant and food service industry to enable them to play a role in reducing trans fat intake.

In the coming months, the Task Force will continue to gather information in order to complete its analysis and develop its final recommendations for fall 2005.

Government Response to the Interim Report of the Trans Fat Task Force

The Government of Canada is already implementing some of the Task Force's recommendations and we will work with our partners to determine what additional actions can be taken to further support the implementation of the recommendations.

The following is a summary of the Interim Recommendations of the Task Force and an outline of the various activities underway or being planned by the Government in response to those recommendations.

Guidance Related to Food Processing and Food Service Industries

1) Regarding the declaration of the trans fat content in nutrition labelling and claims, the Task Force recommends that:

• the federal government:
  
  
  • underscore the importance to the food industry, including manufacturers and distributors of domestic and imported food products, of meeting the approaching deadlines for modifying their labels;
  • refer the food industry to organizations such as the American Oil Chemists' Society (AOCS) or the Standards Council of Canada (SCC), which set standards for analytical procedures and can provide names of laboratories with established competency for the analysis of trans fatty acids; and
  • work with the above-mentioned organizations to encourage laboratories to participate in their accreditation programs.
    
    
• industry associations and industry-specific journals and newsletters aid in the dissemination of this information; and
  
  
• manufacturers and distributors of domestic and imported food products respect the regulations for making claims related to trans fatty acids. For example, a "trans-free" product must contain less than 0.2 g of trans fatty acids in the reference amount (portion size) specified by regulation for that food category, and also in the portion size stated on the label's Nutrition Facts table. The food must also be low in saturated fats to carry this claim.

In response, the Government of Canada will

• finalize a " Trans Fatty Acids and Nutrition Labelling Fact Sheet" for posting on the website of the Canadian Food Inspection Agency (CFIA). This Fact Sheet will provide specific guidance to industry about correctly declaring trans fat in the Nutrition Facts table; making acceptable nutrient content claims and diet-related health claims on labels; and determining the amount of trans fat in a food by referencing the CFIA's Nutrition Labelling Compliance Test, which is already posted on its website;
  
  
• publish a Guide to Developing Accurate Nutrient Values (spring 2006);
  
  
• finalize a notification letter to the domestic food industry about the December 12, 2005 deadline ( December 12, 2007 for small manufacturers) for nutrition labelling compliance; and
  
  
• finalize a World Trade Organization (WTO) notification about the December 12, 2005 deadline (December 12, 2007 for small manufacturers) for nutrition labelling compliance for distribution to interested parties via the WTO's Committee on Technical Barriers to Trade, targeting foreign food industries that wish to export food products to Canada.

2) Regarding support to small and medium enterprises (SMEs), the Task Force recommends that:

• the federal government work with stakeholders to develop a national list of food processing development centres that can help SMEs reformulate their products to reduce or eliminate trans fats and/or develop alternative products with little or no trans fats; and
  
  
• industry associations and industry-specific journals and newsletters aid in the dissemination of this information.

3) Regarding the food service industries, the Task Force recommends that:

• the national food service industry association, in collaboration with government and other stakeholder groups as appropriate, develop and disseminate a guide on how food service operators can reduce trans fat content. Suggestions would include modifying recipes, and selecting ingredients and ready-to-serve food products containing less trans fat, based on the nutrient information that will be required to be provided by suppliers under the Nutrition Labelling regulations.

In response, the Government of Canada will:

• develop a cross-Canada list of not-for-profit food processing development centres which can assist small- and medium-sized food companies in reformulating their products to reduce or eliminate trans fats and/or in developing alternative products with little or no trans fat;
  
  
• continue its ongoing research on the health effects of dietary fats and the measurement of their levels in the Canadian diet, the factors that influence the fatty acid content of foods, and the development of analytical methods to characterize fatty acids;
  
  
• continue to collaborate with industry on breeding development of low trans fat (low linolenic-acid, high oleic-acid) lines of canola; and
  
  
• provide support to the agriculture and food sectors for certain types of action-oriented trans fat-related initiatives (provided they meet specific eligibility criteria) under existing federal government programs, such as:
  
  
  • Advancing Canadian Agriculture and Agri-Food (ACAAF)
  • The Matching Investment Initiative (MII)
  • The Canadian Agriculture and Food International Program (CAFI)
  • The Agricultural Policy Framework Broker and Agri-Innovation Program
    contact: Lorne Heslop at heslop@agr.gc.ca or 613-759-7798

4) The Task Force recommends that:

• the federal government pursue discussions with the U.S. through existing forums such as the NAFTA Technical Working Group on Food Labelling, Packaging and Standards to raise awareness of the public health imperative underpinning the November 2004 direction from the Canadian House of Commons¹. It should also determine the U.S. position and share data that could inform any revision of the mandatory declaration of trans fat in the Nutrition Facts table, including what can be declared as "zero" as well as the definitions of trans-related nutrient content claims; and
  
  
• Canadian industry associations and Canadian subsidiaries of multinational firms raise awareness among their American and Mexican counterparts regarding the position of the Canadian House of Commons which calls on the government to "enact regulation...that effectively eliminates processed trans fats, by limiting the processed trans fat content of any food product sold in Canada ".

In response, the Government of Canada will:

• continue to support discussions with the United States with the goal to promote increased harmonization of activities and measures to address the health risk presented by trans fat. This is consistent with the September 2004 report of the External Advisory Committee on Smart Regulation that promotes a more deliberate and strategic approach to regulatory co-operation within North America; and
  
  
• identify appropriate fora to pursue these discussions. While the NAFTA Technical Working Group on Food Labelling, Packaging and Standards has been identified as a possible forum for this discussion, it may be more appropriate to consider other groups or to establish a new mechanism. This is addressed in the workplan of the Food and Agriculture Working Group of the Security and Prosperity Partnership of North America, which was publicly released on June 27, 2005². In order to enhance public protection from food hazards while facilitating trade and promoting economic efficiency, the workplan outlines an initiative to establish or identify a North American food safety co ordinating mechanism. Among other things, this mechanism would allow co-operation in the design and development of common standards and the sharing of information on food safety matters.

¹ "That, in the opinion of this House, the federal government should acknowledge processed trans fatty acids are harmful fats, which are significantly more likely to cause heart disease than saturated fats; And that this House hasten the development of replacements to processed trans fats by urging the government to enact regulation, or if necessary legislation within one year, guided by the findings of a multi-stakeholder Task Force, including the Heart and Stroke Foundation of Canada and following the consultation process with scientists and the industry currently underway; Therefore, this House calls on the government to enact regulation, or if necessary present legislation that effectively eliminates processed trans fats, by limiting the processed trans fat content of any food product sold in Canada to the lowest level possible." (Canadian Parliament House of Commons, Adopted motion, November 23, 2004)

² http://www.fac-aec.gc.ca/spp/spp-menu-en.asp

Guidance Related to Consumers

Regarding public education, the Task Force recommends that:

• all parties (e.g. the Network on Healthy Eating, health professionals and the media) involved in communicating to consumers about food and nutrition:
  
  
  • reflect the following Task Force messages:
    
    
    • Any dietary change that focuses on reducing trans fat intake should be made in the context of a healthy lifestyle as outlined in Canada's Food Guide to Healthy Eating and Canada's Guide to Healthy Eating and Physical Activity.
    • Some fatty acids (e.g. omega-3 and monounsaturated) are beneficial to heart health and should be included in a healthy diet, while others (e.g. trans and saturated fatty acids) can increase the risk of heart disease and should be reduced in the diet.
    • The new Nutrition Facts table and fat-related claims can assist consumers in selecting products such as margarines, snack foods, french fries, cookies and crackers that contain less trans fat while avoiding items with significantly higher saturated fat content.
    • It is not yet easy for industry to replace industrially produced trans fats in all food categories. However, low-fat versions of partially hydrogenated fat-containing products, such as microwave popcorn, coffee whiteners and croutons, are often available. Even if they contain hydrogenated oil, the amount is so small that these products can still be declared trans free which means the product contains less than 0.2 g of trans fat in the specified amount of food.
    • Choosing lower-fat dairy products and leaner meats, as recommended in Canada's Food Guide to Healthy Eating, is a good way to reduce naturally occurring saturated and trans fat in the diet.
    • Making healthy food choices means more than lowering or eliminating trans fat. Other nutrients and Calories should also be considered. For example, trans-free foods can still be high in sodium or Calories.
      
      
  • direct individuals to evidence-based information sources that already exist, such as:
    
    
    • Health Canada's It's Your Health Web page on trans fats
    • The Heart and Stroke Foundation of Canada
      (note: conduct a search using the term "trans fat")
    • The Canadian Health Network, and
    • The Canadian Restaurant and Foodservices Association Internet link to restaurant chains that provide nutrition information online;
      
      
  • educate the public on how to use the Nutrition Facts table to select foods that are low in trans fats and saturated fats using such material as Health Canada's information on nutrition labelling (http://www.hc-sc.gc.ca/fn-an/label-etiquet/nutrition/index-eng.php) and the Canadian Diabetes Association and Dietitians of Canada's Nutrition Labelling Education Web site ( www.healthyeatingisinstore.ca); and
  • ensure that Canada's Food Guide to Healthy Eating http://www.hc-sc.gc.ca/fn-an/food-guide-aliment/index-eng.php and Canada's Guide to Healthy Eating and Physical Activity ( www.phac-aspc.gc.ca/guide) are broadly disseminated.

In response, the Government of Canada will:

• add an interactive component to its consumer education tools on nutrition labelling. This Interactive Nutrition Label will be available on Health Canada's website in fall 2005, and
  
  
• continue to integrate information and education for consumers on using nutrition labelling in Health Canada and Public Health Agency activities such as the revised Food Guide (spring 2006) and the Healthy Living and Sport Participation Campaign (fall 2006).
  
  
• consider the recommendations of the Trans Fat Task Force Interim Report in future updates of national dietary guidance.
  
  
• continue public health efforts on health promotion and disease prevention such as the Integrated Strategy on Healthy Living and Chronic Disease as announced in Budget 2005. An example of activities under the Integrated Strategy include those that promote healthy eating and that can help to prevent and control chronic diseases, such as cardiovascular disease.