Reformulating partially hydrogenated vegetable oils to maximise health gains in India: is it feasible and will it meet consumer demand?

The potential for SFA to increase when TFA is reduced was not seen as a widespread concern by manufacturers. One interviewee did note that increasing use of palm stearin would make “the saturated fat acid go up and that is not a healthy oil”, whereas others said palm was a “healthy oil” and an “agreeable choice” for product reformulation.

Overall, industry respondents were accepting of the proposed national TFA regulation (particularly a 10% (by weight) TFA limit in PHVOs), and some were even critical of the lengthy policy process. Interviewees from multinational companies indicated that the regulation would lead to a more level playing field, which could potentially benefit them. All interviewees mentioned the need to align Indian regulation with international standards (i.e., CODEX). Specifically they were concerned about the current cap on the melting point, the classification of palm stearin as inedible oil, and the inability to use enzymatic and chemical interesterification. However, interviewees from both industry and government noted that it was likely that these “archaic laws” would be removed when the government enacts the proposed TFA regulation, as suggested during consultations, given that the melting point cap results in a reliance on use of TFA in order to ensure product acceptability. Although palm stearin is currently not permitted as input oil for PHVOs, it was suggested that many companies were using it to make a very hard product that was described as being “like stone” or a “brick”.

There was a concern that there would be challenges with the implementation, monitoring and compliance of the proposed new regulation. Several interviewees stated that companies were already “violating the norms” for the melting point cap and palm stearin so compliance may remain a problem in the future: “today people violate and tomorrow they will violate”.

One interviewee noted the need for greater transparency and suggested publishing the results of food inspector monitoring of vanaspati quality in order to empower consumers to make informed decisions. Interviewees noted that although by law, their product should be tested once per month by food inspectors, their products are often not tested regularly. Moreover, one interviewee indicated that there had been no reported violations of the melting point regulation in the past few years even though, with the exception of a few companies, the interviewee suggested they were all exceeding the melting point cap regulation. One multinational company who had been abiding by the regulation said that they were producing a product that was not acceptable to consumers because they could not make it hard enough without violating the regulation, something that they would not do given their own company’s “ethics” leading them “to comply with every law in the land”. Table 2 provides supporting quotes regarding the aforementioned regulatory issues.

One interviewee stated that the palm oil lobby pushed TFA onto the Indian agenda. Because palm oil is semi-solid it could replace PHVOs in some products. As industry moved towards use of palm oil as the main input oil in vanaspati and bakery shortening, interviewees noted that the total TFA in vanaspati decreased. When industry was using “soft oils” as the input oils into vanaspati they had to hydrogenate the products more to ensure that it became the desired texture (i.e., semi-solid). Given that palm oil is already semi-solid it does not require the same degree of hydrogenation as more liquid vegetable oils, interviewees indicated that it has led to changes in consumption patterns; palm oil and SFA consumption are increasing and TFA consumption from vanaspati is stabilising or even decreasing.

Most interviewees did not see the availability of alternative oils as being problematic, since they planned to continue to use palm oil as the input oil in their reformulated products. However, one interviewee did suggest the need to establish a supply of cheap oil for the masses that was healthier, such as canola, and another interviewee proposed the restructuring of agriculture policies to enable a shift to oils other than palm. Supporting quotes regarding the availability of oils are reported in Table 3.

The use of full hydrogenation, interesterification, fractionation and blending of soft oils with harder fractionations were the main ways that manufacturers planned to decrease TFA in their products. Interviewees often noted that they would use these different technological approaches in combination and based the appropriateness of the different technologies on cost and perceived consumer acceptability. More specifically, there were various pros and cons to using the different technologies attributed to the product cost, hardness, stability and shelf life, and potential health effects. The use of interesterification was identified as a way to increase the use of “soft oils” (i.e., PUFA); however, it was noted that this would still result in increased costs from both the use of the technology itself and the input oils. There was disagreement about whether interesterification would result in hard enough products – some interviewees deemed this to be problematic while others did not. In terms of fractionation and blending, there was a concern by a few interviewees that this would lead to overuse of palm stearin, which would increase SFA content of food products and negatively affect heart disease rates in the future. However, other interviewees did not see any problem with the use of palm oil or its fractions. Enzymatic interesterification was seen as being more appropriate than chemical interesterification since it was believed to be more economically feasible and used a better catalyst as compared to chemical interesterification, which one interviewee described as being potentially hazardous to human health.

One of the key points made by all interviewees was the need to “minimise costs”. Interviewees consistently stated that reducing the TFA in their products would not significantly increase their costs and would not result in lower profit margins. However, there were also industry players, particularly the multinational companies, who indicated there would be additional capital costs if they planned to use interesterification to bring down the TFA in their products without increasing SFA content.

Several interviewees noted a lack of capacity for smaller sized manufacturers, leading to “hanky panky business” by some. This lack of capacity has led multinational companies to buy-out some of the successful smaller brands, consolidating the industry, and to the closure of some vanaspati plants. Given the lack of capacity of smaller manufacturers, a few interviewees postulated that they would not abide by the TFA regulation once it is implemented. However, noting this should not lead to delays in the enactment of the regulation: “Even if they [smaller companies] don’t abide by the law it will not make much difference”, since the big players have the majority of the market. Despite the lack of capacity for smaller manufacturers, most of the interviewees did not think that the government should provide additional support to them to help facilitate product reformulation, except for a few interviews that suggested that the government could provide subsidies, tax rebates and/or machinery. Table 4 provides supporting quotes regarding the economic feasibility.

The removal of PHVOs from the food supply is likely to lead to a shift in palm oil consumption [20]; this is promoted by a strong palm oil lobby. Although the surge in palm oil use has likely resulted in a decrease in TFA levels in PHVOs such as vanaspati, SFA levels may have increased concomitantly. As Indian industry moves to further reduce TFA in PHVOs, it is likely that they will continue to rely on palm oil. Although this will result in modest improvements in heart disease risk, greater effects would be observed with replacement using PUFA [1, 23]. In 1987, the Mauritian government intervened to switch cooking oil from palm to soybean oil, resulting in a significant decrease in SFA and increase in PUFA, corresponding to improvements in serum total cholesterol levels [24]. Moreover, a recent study found a link between palm oil consumption in low and middle-income countries and increased risk of mortality due to heart disease [25]. Other studies, including two meta-analyses, have also found adverse effects of consuming SFA such as palmitic acid [26‐28]. Nonetheless, there continues to be support for its use in product reformulation by industry.

Interestingly, the French government recently proposed setting a 300% tax on palm oil import which led to considerable opposition from the Malaysian Palm Oil Council [29]. There is an emerging trend for companies to resist using palm oil in some high-income countries due to the environmental and health impact of its consumption [30]. In fact, front-of-package logos indicating palm oil-free products are now available in Europe [30]. This growing trend may be the impetus for greater investment in alternatives to both PHVOs and palm oil; however, it is likely that palm oil will continue to be used in low and middle-income countries until consumers increase demand for products that are both low in TFA and SFA. Because there has been considerable interest in the environmental impact of palm oil production [31], highlighting the environmental as well as health concerns related to palm oil production and consumption may get more consumer buy-in.

Although there is limited information about product reformulation to reduce trans fat in low and middle-income countries, a study examining industry’s response in Latin American countries found similar challenges to those reported in this study. For example, challenges in the availability and cost of PUFA and concern about consumers sensory preference for some products [32]. Ensuring that TFA reduction does not lead to an increase in SFA will require active engagement and collaboration among the government, the agriculture sector and Indian industry. Previous research has suggested that leadership and commitment from senior management of industry, collaboration across the supply chain and adequate supply of alternative oils, increased demand for healthy products, increased media coverage and regulation are needed to enable healthier product reformulation [18]. Currently there is insufficient demand for low TFA and SFA products in India, which gives industry little incentive to reformulate in a more healthful way, especially considering the increased costs associated with use of PUFA. Nevertheless, it is important to note that energy intakes remain low for a significant portion of the Indian population and food security remains a problem for many, making the need for low priced fats essential [33].

Although industry and technical experts indicated that it was technologically feasible to reformulate PHVOs in India to reduce TFA, they will need to invest in research and development to reduce TFA levels to 5%. In high-income countries, industry replaced PHVOs with different types of oils and fats based on the product functionality required [7, 18, 20]. For example, PHVOs for frying were often replaced with high MUFA or PUFA liquid oils, whereas interesterification of hard fractions with unsaturated oils has been used for solid fats such as bakery shortening [18, 20, 34]. We suggest adopting a similar approach in India; however, this will require educating the consumers, and perhaps industry members, about the healthiness of “soft” unsaturated oils and strengthening supply chains to increase availability and decrease costs of these oils. In the past, Indian industry was required to use a proportion of domestic oil in vanaspati production. We recommend that the government consider re-enacting similar regulation to incentivise the use of PUFA in product reformulation, given that most domestically produced oils are high in these fats. There is currently a limited supply of suitable alternative oils to PHVOs that are low in SFA [20]; however, if the Indian government required industry to use domestic oils, it is likely that supply chains would be strengthened.

Multinational companies tend to have better capacity to adopt new technology as compared to smaller manufacturers. Many large companies have research and development facilities in North America or Europe, and have already begun adopting technology such as interesterification in those countries. In fact, multinational companies have developed zero TFA low SFA bakery shortenings catering to their American and European markets [35, 36], suggesting that it is possible to bring similar products to India. Moreover, a food technology study conducted in Iran (where no current trans fat regulation exists) demonstrated that low TFA vanaspati could be produced using a combination of blending and interesterification creating a product with reasonable SFA levels and the same organoleptic properties demanded by Indian consumers [37]. However, smaller companies may not have the resources to invest in the necessary technology to create a product that is both low in TFA and SFA. Surprisingly, this study found little support for government initiatives to help smaller businesses with this process. New York City and the province of British Columbia, Canada provided support to small businesses to help enable the shift towards TFA free cooking oils and fats in response to regulation in those jurisdictions [38‐40]. Moreover, in the United States, smaller companies were given extra time to comply with labelling regulation given the added difficulty they would face as compared to larger companies [39]. For Indian companies who do not have the financial means to adopt new technology, they may be forced to sell consumers a product that is less acceptable, fail to comply with the regulation, or sell or close their businesses. Interestingly, there was a trend towards multinational companies purchasing the more successful smaller PHVO businesses. One of the potentially positive aspects of this trend is that multinational companies may be less likely to stray from regulation. Therefore as more and more smaller PHVO businesses are purchased by the larger companies, this may help facilitate compliance with regulation and ease the potential enforcement strains that the country may face when the TFA regulation is enacted [8]. On the other hand, it is important to support smaller manufacturers and we suggest providing incentives to help them to better comply with regulation.

One of the main limitations of this study was the small sample size; however, our respondents included the companies with the highest market share for PHVOs in India, which strengthens the transferability of the study findings. Another limitation of this study was our use of a non-validated interview guide. Nevertheless, we ensured that the interview guide was reviewed by experts in the field prior to using it in this study.