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 Other Codex Committees New Work for the Definition of Trans-Fat.

ICGMA, a recognized INGO 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 elimination or preventing artificial barriers to trade.

ICGMA supports new work to define “trans-fatty acids” and supports the following definition:

"Trans fat is defined as only the trans fatty acids with nonconjugated double bonds (fully hydrogenated oils and partially hydrogenated oils); conjugated linoleic acid (naturally occurring in meat and dairy products) would be excluded from the definition of trans fat.

This proposed definition for trans-fat is takes into account the fact that the identification of trans-fatty acids is based on the actual chemical structures of the fatty acids. ICGMA supports this definition because it would exclude fatty acids with conjugated bonds; fatty acids that are metabolized differently than those with non-conjugated bonds. ICGMA appreciates the opportunity to submit these comments.

Mari Stull
Director, International Regulatory Policy
Grocery Manufacturers Association




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