DefinePK

Abstract

Trans-fatty acids (TFAs) are unsaturated constituents of fat found in foods obtained from ruminants, such as dairy products and meat, and in industrially produced partially hydrogenated vegetable oils (PHOs). Since 1991, peer-reviewed research has accumulated that demonstrates the link between high intake of industrially produced trans-fatty acids (iTFAs) and a variety of non-communicable diseases (NCDs), including coronary heart disease. Pakistan’s trans-fat intake is estimated to be the 2nd highest in the WHO-EMRO region after Egypt. In recent years, several countries around the world have implemented policies to eliminate industrially produced TFA from their diet, with remarkable degrees of success. The World Health Organization has called for the global elimination of TFA from the food by 2023 and has developed the REPLACE framework to remove and replace trans-fats from country diets. This report is a situational analysis of trans fatty acids (TFAs) in Pakistan that looks at the incidence and particular sources of TFA in the Pakistani diet, examines existing literature on TFA elimination from around the world and the policy and regulatory landscape in Pakistan to suggest possible steps to eliminate it from the Pakistani diet.

A wide variety of approaches for TFA elimination have been employed by governments around the world; these include mandatory labelling, mandatory limits, voluntary limits, bans on food products, TFA replacement initiatives and a combination of the above. The literature shows that mandatory limits backed by credible penalties are the most effective way of reducing TFA, with the remarkable success achieved by governments that have applied such limits. Mandatory labelling is also another key intervention that has the result of moving the industry toward reformulating TFA-heavy products. Successful TFA elimination policy efforts often tend to be characterized by strong  stewardship of the process by key government institutions, extensive coverage by electronic and print media, multi-sectoral approaches that involve industrial, academic and civil society stakeholders, joint public-private research efforts for TFA replacement, strong monitoring capacity and the ability of governments to assess both TFA content in food and its intake by the population. In developing country contexts similar to Pakistan’s, policymakers also face the added dilemma of ensuring a reduction in TFA while maintaining adequate calorie and fat intake among disadvantaged segments of society.

In Pakistan, the main dietary sources of TFA include vanaspati ghee, margarines, bakery shortenings and cooking oil. As these oils and fats are widely used for cooking and baking purposes in Pakistan, including widespread usage in homes, they lead to high TFA levels across a wide variety of food products, including biscuits, chocolates, pastries, breakfast foods, French fries, and breakfast cereals.1 The main industries that are the source of TFAs in the Pakistani context are edible oil, margarine, and the bakery and confectionary industry. The bulk of TFA consumed in Pakistan (about 98%) is produced within the country.

Pakistan’s food regulation framework has historically been weakly enforced (owing to both lack of state capacity and flouting of regulations by food producers) and continues to suffer from a lack of enforcement capacity or institutional harmonization, with multiple laws, bodies and standards operating in different regions and tiers of governance. However, progress in food regulation has been made in recent years and some steps toward limiting TFA content in food have also been taken. The key institutions responsible for food safety regulation in the country include the provincial food authorities and the Pakistan Standards and Quality Control Authority (PSQCA). Authorities in Punjab and Khyber Pakhtunkhwa have enacted mandatory TFA limits for several food products, while PSQCA has adopted limits for vanaspati ghee only. However, with the exception of Punjab, none of the limits imposed are within WHO-recommended levels or cover the entire array of products high in TFA. The Punjab Food Authority (PFA) has also taken the added step of banning vanaspati ghee by 2020. Sindh and Balochistan have not yet enacted any policies or limits for TFA elimination and suffer from much more basic capacity constraints that inhibit their ability to regulate TFA within their jurisdiction. The PSQCA’s standards are currently the most permissive out of all the standards bodies.

Other key government institutions relevant for the elimination of industrial TFA in Pakistan include the Ministry of National Health Services, Regulation and Coordination (NHSR&C), the provincial health departments, the Ministry of Commerce (Customs), the Pakistan Council of Scientific and Industrial Research (PCSIR), the Ministry of Planning, Development and Reform, the Ministry of National Food Security and Research (MNFSR) and the National Institute of Health (NIH) Pakistan. 

A number of considerations need to be borne in mind by policymakers to achieve TFA elimination in Pakistan in the coming years. These include the existence of overlapping and contrasting standards across different provincial and federal jurisdictions, maximum TFA limits, the need for uniform labelling and nutrition profiling requirements in compliance with WHO-recommended levels and legal loopholes for producers to circumvent regulations. Credible penalties need to be enacted and popularized for violation of TFA regulations. This needs to be tied to the clear definition of federal and provincial food regulation responsibilities to ensure an appropriate constellation of roles and effective enforcement across various tiers of governance.

There are a few capacity constraints among government institutions that hinder the fight against TFA. The capacity of provincial food authorities to assess TFA content needs to be strengthened; this includes both building laboratory capacity, recruitment and training of human resource personnel, and changes in rules of inspectors to monitor TFA in products and impose penalties for non-compliance. Data on TFA consumption has also never been collected at the population level in Pakistan, which hinders a more concrete understanding of the TFA intake for different sub-sections of the population; this needs to be collected (potentially as part of the National Nutrition Survey) both as a baseline to assess progress toward TFA elimination and to tailor policy interventions and public messaging appropriately.

A lack of awareness among the public, retailers and policymakers about the consequences of high TFA-intake remains a broader environmental concern that inhibits quicker action toward TFA elimination, pointing toward the need for targeted communication efforts to build public demand; such efforts must involve electronic, print and social media, and target population sub-groups with high TFA intakes. Research around TFA replacements and reformulation of TFA- rich products, such as vanaspati ghee, must be carried out in collaboration with academia and industry stakeholders to ensure a shift toward the production and consumption of heavier fats and oils. The federal and provincial government also need to take the lead to promote healthier alternatives through changes in procurement policies, nutrition guidelines and public messaging about healthier dietary habits

 

1.      Introduction

 

Trans fatty acids (TFAs) are integral components of unsaturated fats found in foods obtained from ruminants, such as dairy products and meat, and in industrially produced partially hydrogenated oils. According to the WHO’s definition, TFAs are fatty acids with at least one carbon–carbon double bond in the trans configuration.2 For unprocessed natural food, the content of naturally occurring TFA is generally low (