Trans fat regulation

Banning or labeling

There are two ways to regulating trans fat: banning the use of oils that contain trans fat, or obliging manufacturers to label trans fat information on the food packages. The labeling is applicable to foods sold at stores, but it cannot cover the dishes served at restaurants. Meanwhile, the ban on trans fat itself is effective as all the foods can be regulated. With labeling, though, consumers can learn the information about trans fat, leading them to make healthier food choices. If oils with a little trans fats are tolerated to exist, without facing a sudden exclusion, the labeling method will assume more significance.

Regulations overseas

Denmark has introduced a ban on trans fat for the first time in the world in 2003. It was to outlaw the use of oils whose trans fat contents were more than 2%, which in effect denied partially hydrogenated oil. The United States introduced in 2006 a mandatory labeling of trans fat content on the food packages. In New York City, the use of oils containing trans fats has been barred in restaurants since 2007. Other countries, including Switzerland, Canada, Australia, South Korea, and Brazil, also started some regulations on trans fat. Japan is lagging behind these countries, with neither banning nor labeling in sight as of 2012.

The Japanese authorities concerned

In 2012, Consumer Affairs Agency and Food Safety Commission are dealing with the problems of trans fat. Both bodies belong to Cabinet Office. Another agency, Ministry of Agriculture, Forestry and Fisheries, also has some concern. This disperse structure is producing such maladies as a wasteful overlapping work and irresponsible attitude.

Consumer Affairs Agency

Information on trans fatty acid provides what Consumer Affairs Agency is doing regarding trans fat issue. Let me examine below Policy on disclosing trans fat information (pdf file in Japanese) that is available at that page.

According to the report, the agency "decided to urge food manufacturers to voluntarily try to disclose information on oils that contain trans fatty acid." That is to say, it has no intention to introduce some regulation as ever, not following other nations where trans fat regulations are put in place. What an irresponsible it is to do nothing while relying on the manufacturers' efforts!

Without ban or mandatory labeling on trans fat, there should be companies that disregard the agency's request. Also, it would be no use introducing regulations devoid of penalties. Even if penalties were included in a law, illegal practice would remain without an occasional checking system. Three factors, obligation, penalties, and checking, are required to assure that the regulation is working effectively. From the viewpoint of consistency with other social systems in Japan, it cannot be accepted to assume that people are born good.

Here is another problematic excerpt, "we do not differentiate trans fatty acids that are naturally occurring (ruminant) and those industrially manufactured because it is impossible to exactly discern between the two." The problem is artificial trans fat only, and natural one has some health benefits. It is plain wrong to treat poison and nutrient as the same thing. The reason "because it is impossible to exactly discern between the two" is too trivial to be valid. Does the writer of the report believe that materials were born from the words that had first existed in the universe? This fundamental misunderstanding must be corrected.

Food Safety Commission

The commission has a group in it to treat trans fat problem. Recently, there was news that the Food Safety Commission has compiled a report in which it reached a decision that Japan need not regulate trans fat. The reason it claims is the fact that most Japanese meet the WHO's standard: the intake of trans fatty acid is less than 1 percent of the total calories.

I glanced trough the report (pdf file in Japanese) that is linked from the 83rd meeting of the New Food Investigation Panel. The panel consists of 14 members. The report is titled "the new food review: trans fatty acid in foods", and was released February 21, 2012. It is packed with a lot of information about trans fat including the chemical structure, health risks, and regulations overseas. However, it does not say anything about trans fat regulation in the summary sentence (page 6) or in the conclusion (page 73).

The review notes "the average ratio of trans fat to the total calories the Japanese consume." Table 14-1 provides data based on 32,470 people investigated. The energy ratio averages around 0.3 to 0.4 percent, well below the WHO standard of 1 percent. It is unclear how many Japanese exceed the 1 percent threshold as there is no variance data in the review.

The word "99 percentile" is found in page 35. This is about table 17-2, which has explanation in page 25. You can see the 99 percentile is based on the population of daily consumption. But this logic is off the point because trans fat deposits in the body in months or years to do harm to our health. The 99 percentile, then, should be based on the population of consumptions among people. It deserves nothing to argue the wrong 99 percentile is higher or lower than energy ratio of 1 percent. The sensibility or intelligence of the writer is extremely terrible.

This mad 99 percentile is cited in "presumption of intake" (page 71) and in conclusion (page 73). Besides, the error affects the summary at page 6 that reads "most Japanese meet the WHO criterion." The word "most" means "more than 99 percent" in this context. The review was significantly disgraced as important parts, the summary and the conclusion, embrace the fault. Furthermore, the reason for the commission's final decision has lost its ground.

Even if the 99 percentile was proper data based on the population of consumptions among people, it is basically wrong to think this way. In other words, the idea implies that we should take care of 99 percent of Japanese, but the rest 1 percent (about 1.3 million) of unhealthy people need not.

Certainly, we should not follow the diet of those who eat junk foods laden with trans fat. Such people may deserve to be denounced, though, the authorities concerned should save them and urge them to lead healthier life instead of disregarding them. It can be achieved by banning the use of trans fat to make it impossible for people to get it higher than 1 percent, or by imposing a mandatory labeling to inform people of the evil fat. From this viewpoint, it was not right of the Food Safety Commission to have reached the conclusion that Japan needs no regulation on trans fat. Should 99 percent Japanese meet the WHO criterion, it cannot warrant introducing no regulation.

At present, processed foods sold in stores may contain trans fat, so may dishes served at restaurants because there is no restriction in Japan on the use of oils containing trans fat. Then consumers are exposed to the risk of trans fat as long as they live in Japan. Compulsory labeling on food packages could lower the risk as we could check trans fat content before buying the product. But no such system is in place. Japanese consumers continue to be at risk while being deprived of the avoiding measure.

As government agencies are responsible for the nations' health, they must remove the risk or provide the risk-evading measure to people who need it. Hence, they must introduce the ban or mandatory labeling regarding trans fat. This is far important issue than the WHO's number. But the Food Safety Commission is missing the big picture, urging manufacturers to voluntarily tackle with the problem as well as neglecting consumers. I denounce what the commission did: reaching the conclusion that undermines the nations' benefits, citing a dismal excuse. It would be better to do nothing than to do a negative work. The Food Safety Commission should bring itself into extinction to better serve the public.

Fatty Acids and Health

What is a fatty acid?
Trans fatty acid
Trans fat regulation
Avoiding trans fat
Taking omega-3 fatty acid


Consumer Affairs Agency
Food Safety Commission

© 2007 Takashi Shimazaki
Updated: April 14, 2013