Call for Elimination of Loopholes in United States’ Trans Fatty Acid Labeling Regulations

Mengting Qiu

Abstract

Consumption of trans fatty acids increases risk for cardiovascular disease with a directly proportional relationship. To reduce the public’s intake of this harmful substance, the U.S. Food and Drug Administration mandates that trans fat content of processed foods be indicated on nutrition labels. It has also proposed a ban on partially hydrogenated oils (the main source of industrially-produced trans fat). This ban has been the subject of much debate due to its coercive nature. However, both advocates and critics of the ban have failed to recognize that current policies for labeling trans fat are deceptive: trans fat content can be claimed to be 0g in the US as long as there is fewer than 0.5g of trans fat per serving. This allows trans fat content to be presented as zero grams when it is not actually zero grams. Misrepresentations of trans fat content due to rounding error and serving size, while seemingly insignificant, are actually very clinically significant because the World Health Organization recommends that a person consume less than 2g of trans fat per day. With the current trans fat labeling, people can quickly consume more than this recommended amount while believing they are consuming none. Thus, labeling needs to be more accurately representative of actual amounts of trans fats in foods. This can be achieved through means such as reducing the rounding threshold or making serving sizes more representative of quantities consumed per sitting.  In short, trans fats content must not be allowed to be represented as zero when it is not such, so that consumers can actually judge their intake of this harmful substance. This policy change would also enable advancement in the debate about a ban on trans fats by maximizing the benefits of labeling practices.

 

Consumption of trans fatty acids (TFAs) derived from industrial partially hydrogenated oils (PHOs) has been shown to have a significant positive correlation with risk of cardiovascular disease (CVD) (Uauy et al. 2009; Michas et al. 2014; Nishida and Uauy 2009). In fact, it has been estimated that reducing the 2010 levels of population TFA intake in the US (0.6% of daily energy intake) to zero can prevent up to 7000 deaths from cardiovascular disease and 20,000 heart attacks per year in the US (Dietz and Scanlon 2012). Furthermore, it has been found that the amount of TFA consumption is directly proportional to CVD risk (IOM 2005); up to 480 deaths from cardiovascular disease and 1,200 heart attacks in the US can be prevented per year with only a reduction of TFA consumption by 0.04% of daily energy intake, which is less than 7% of the 2010 levels (Dietz and Scanlon 2012). Because consumption of even very small quantities of TFA can have large negative health consequences (IOM 2005), the World Health Organization (WHO) has made a recommendation that the proportion of people’s daily energy intake that is from trans fats be less than 1% (Nishida and Uauy 2009), which corresponds to 2g/day for a 2000 calorie/day diet (AHA 2015). WHO has further recommended that countries should work towards eliminating industrial TFAs from all foods (Uauy et al. 2009). 

In response to the growing body of evidence for TFA as a harmful substance, the U.S. Food and Drug Administration (FDA) began to require labeling of trans fat content in processed food in 2006 (FDA 2013b). However, while labeling regulations have been largely responsible for the decrease in average TFA intake in the US by 3.3g per day per person (pp/pd) from 2003 to 2009, from 4.6g pp/pd to 1.3g pp/pd (Doell et al. 2012), the danger of consuming even small quantities of TFA has propelled FDA to take further action (FDA 2013c). In 2013, FDA made a preliminary determination that PHOs are not generally recognized as safe (GRAS). If this decision is finalized, manufacturers would be banned from selling foods containing PHOs (FDA 2013c), thereby eliminating the primary source of dietary TFAs. Despite the seemingly straightforward nature of its health benefits, the potential ban has been the subject of much controversy and debate due to its coercive nature (Resnik 2010; CBS 2013), and as of March 2015, FDA had not yet made a final decision regarding the GRAS status of PHOs (Gelski 2015). However, one critical aspect of trans fat regulation that both critics and proponents of the ban have failed to consider is that there is a lack of transparency in the reporting and labeling of trans fatty acid content in foods, due to rounding error and serving size variability (FDA 2013b). These problems cause labels to deceptively claim 0g trans fat in foods that actually contain clinically significant amounts of trans fat, given that the recommended TFA intake is <2g pp/pd. These labels thus lie to consumers, preventing them from making informed decisions about their diet (the purpose of labeling in the first place), and causing them to believe that they are on a trans-fat-free diet when they in fact are far from it. Thus, before FDA policymakers continue debate about a PHO ban, they must first realize that current labeling regulations of TFA content in processed foods are inadequate and allow for deceptive labeling, and must change current TFA labeling regulations to allow for transparent and accurate labeling of TFA in processed foods. What can and cannot be achieved through labeling regulations can only be seen once they are made transparent enough to actually allow consumers to make informed choices about their TFA consumption, and only after this is it possible to determine the necessity of a ban.

The lack of transparency in FDA’s TFA labeling regulations can best be seen through a comparison with Canada’s TFA labeling regulations, present as of December 12, 2005 (Micha and Mozaffarian 2008). Although Canada’s labeling policies may not be faultless, their juxtaposition with those in the United States clearly show the shortcomings of FDA’s TFA labeling regulations. The first notable difference between the USA and Canada’s TFA labeling regulations is that of rounding: in the US, foods with fewer than 0.5g of trans fat per serving can be labeled as having 0g of trans fat, whereas in Canada, only foods with fewer than 0.2g of trans fat per serving can be labeled as having 0g of trans fat (Micha and Mozaffarian 2008). This allows more TFA-containing foods in the US to claim zero TFA content. Rounding is necessary to some degree in all labeling practices because it is impractical and unfeasible to show the exact amount of a given substance.  For example, a product may be experimentally determined to contain 0.3456789g of trans fat per serving, but this number with many decimals will confuse the reader and take up too much space. Thus, to increase clarity, rounding is necessary to some degree. However, the rules for rounding this number are what determine whether this 0.3456789g amount is labeled, for example, as 0.3g (rounded to the nearest 0.1g), 0.5g (rounded to the nearest 0.5g), or 0g (rounded to the nearest whole 1g). Based on the countries’ differing rounding rules, in the US, this 0.3456789g amount would be rounded to 0g, since foods with fewer than 0.5g of TFA per serving can be labeled as 0g. However, in Canada, it would be rounded to 0.3g, since only foods with fewer than 0.2g of TFA per serving can be labeled as 0g (see Appendix 1 for a more detailed explanation of rounding rules in the US and in Canada; FDA 2013a; CFIA 2005). While this rounding error is seemingly insignificant, it is clinically significant in the case of TFAs since any amount of TFA consumption causes increased risk of CVD (IOM 2005). Here, “zero plus zero doesn’t always equal zero” (Gordon 2011:1). In fact, zero plus zero can add up to a non-zero, clinically significant amount. Manifestations of rounding error misrepresenting a food’s actual content are in fact prevalent in the US: 84% of US products containing PHOs (the main dietary source of trans fats) are labeled as having 0g of trans fat, which can lead consumers to potentially “underestimate their trans fat consumption” (Clapp et al. 2014:1).

Another problem behind trans fat labeling regulations in the United States is the inadequacy of the definition of “serving size,” which also prevents consumers from accurately judging their TFA consumption. In the US, a food can be labeled as having 0g trans fat if it has less than 0.5g TFA per serving (FDA 2003). Here, a “serving” is based on “reference amounts customarily consumed per eating occasion” (CFR 2014:1), which are provided by the Code of Federal Regulations Title 21. In Canada, foods can be labeled as having 0g trans fat when they contain less than 0.2g TFA per serving, which is also determined by reference amounts (CFIA 2014), provided by Health Canada (see Appendix 2 for more detail on serving size regulations; CFIA 2015). However, there are significant differences between the reference amounts provided by the United States and those provided by Canada. For example, the reference amount for one serving of potato chips in the US is 30g (CFR 2014), whereas that of potato chips in Canada is 50g (CFIA 2015). Though there is nothing intrinsically wrong with this difference, it shows how the amount of trans fat in a given product can be hidden by the serving size: if a serving size is sufficiently small, its TFA content can be rounded to zero. For example, if a food contains 0.6g of TFA per 50g, it cannot claim 0g; however, if the serving size is 30g, it can claim 0g TFA (though it still has 0.6g TFA per 50g). Using reference amounts for serving sizes is a particular problem when they misrepresent the amount actually eaten per sitting, which is the case with the currently outdated reference amounts established 20 years ago (FDA 2014a).  

Taken together, current TFA labeling with its loopholes of rounding error and variable serving sizes allow companies to actively lie to consumers by causing them to believe that they are on a trans-fat-free diet even though they may be consuming much more than the WHO-recommended amounts. Although companies must follow the rules provided by FDA for rounding and serving size, and cannot, for example, choose their own serving sizes to hide TFA content in their foods, FDA rules are in line with company interests by allowing them to claim 0g trans fat in foods that do contain trans fats. Manufacturers using PHOs, who look to continue sales of their products but understand consumers’ increasing awareness of the negative health consequences of TFA-containing foods (Camp et al. 2012), could take advantage of these loopholes by opting to use a reference amount as a serving size instead of providing the content in the entirety of a product (e.g. a bag of chips), or by decreasing their foods’ PHO content just enough to be able to round down to zero. In a hypothetical scenario, a child could eat some cookies, and if the cookies were labeled to have zero grams of trans fat per 30g serving (CFR 2014), which corresponds to about 2.5 cookies (SND 2014), then the parent would have no reason (when solely considering TFAs) to restrict the child’s amount of cookie intake. However, in reality, these cookies could have 0.49g of trans fat per serving (~2.5 cookies) and with 10 cookies, this child would reach the 2g/day WHO-recommended maximum suggested TFA intake. If the child continues to eat cookies over several days and years, up to a hypothetical infinite amount, they would be consuming an infinite amount of trans fat, all the while their parents think that they are consuming none.

While manifestations of deceptive labeling causing inadvertent TFA consumption are not as drastic in real life, they do occur and can be clearly seen through a comparison of the differential TFA content claims on similar Canadian and American food products. In comparing nutrition labels of identical foods in the US and Canada with similar market sizes, discrepancies were found in the amount of trans fat claimed by the labels to be present in the foods. For example, a 100g Hershey’s Cookies and Cream chocolate bar sold in the US was labeled to have 0g of trans fat per serving size of 43g, or 6 pieces (2.5 servings per chocolate bar; see Appendix 4, Figure 2). In contrast, the same-brand same-flavor 100g Hershey’s Cookies and Cream chocolate bar sold in Canada was labeled to have 1g of trans fat per serving size of 50g, or half the chocolate bar (2 servings per chocolate bar; see Appendix 4, Figure 1). There is no reason that Hershey’s Cookies and Cream chocolate sold in the US would be any different from those sold in Canada since it would make no economic sense for the chain to manufacture one type of chocolate for the US and another type of chocolate for Canada. Thus, the US chocolate must also have more than 0.5g of trans fat per half a chocolate bar (see Appendix 1 for rounding rules in the two countries). What, then, allowed the same chocolate in the US to have 0g of trans fat per serving which in Canada has 1g of trans fat per serving? It is the small serving size (43g in the US as opposed to 50g in Canada) and the rounding error (in the US <0.5g is rounded to 0g). (Interestingly, the Code of Federal Regulations (CFR 2014) does not provide a reference amount for chocolate. Hershey’s seems to be taking advantage of this in using 43g as a serving size, which is small enough for its TFA content to be claimed as 0g.) TFA content being hidden in serving size also occurs in other products: for example, Doritos Nacho Cheese Chips is labeled as having 0g of trans fat per serving size of 28g in the US for an 88.5g bag of chips (Appendix 4, Figure 4), but as 0.2g per serving size of 50g in Canada for an 80g bag of chips (Appendix 4, Figure 3). Thus, the US chips must also contain at least 0.2g TFA, not 0g, per bag. These snacks are only a snapshot of the problem. Compounded by several rounding errors and misrepresentative serving sizes per day, and consumers can quickly be consuming several grams of trans fat per day while thinking they are consuming none.

The lack of transparency of current TFA labeling policies is problematic because of this discrepancy in what consumers believe they are consuming and what they are actually consuming. According to the Food and Agricultural Organization of the United Nations, the purpose of labeling is to “provide consumers with the information they need and desire to make food choices” (FAO 2015:1). In the case of current TFA labeling regulations, consumers not only are prevented from making informed food choices, but also are being lied to by labels on foods that claim to but do not actually contain zero trans fat. Yes, the labeled content of other substances in foods such as other fats are also dependent on rounding error and serving size, but the degree of accuracy in TFA labeling required to actually give consumers “the information they need and desire to make food choices” (FAO 2015:1) must be much higher than that of other substances. This is because the scale on which the substances are judged are different. TFA is harmful in much smaller quantities than other substances such as saturated fats are (the American Health Association recommends daily intake of saturated fats to be below 16g/2000cal diet, as compared to below 2g/2000cal diet for trans fats; AHA 2015). Thus, 10g of TFA is not the same as 10g of saturated fat, so TFAs must be treated differently with more precise labeling regulations. Accurate and transparent labeling of TFA content is especially important now, as a 2009 survey found that 72% of Americans read labels on products to select healthier foods, and 61% of Americans consider “’zero grams of trans fat per serving’ to be the most important claim for heart health” (Scott-Thomas 2009:1). With the current deceptive nature of TFA labeling, people who are seriously trying to follow a zero-trans-fat diet and select foods based on trans fat content may actually be consuming very dangerous amounts of trans fat without knowing. This is seriously problematic because these peoples’ risk for CVD is increasing while they seek to avoid such a risk increase. Thus, to allow people to actually be able to make choices about foods for their own health, it is necessary that trans fat labeling be made more transparent and accurate to a scale reflective of the substance’s degree of harm per quantity consumed.

In order to account for the fact that trans fatty acids have large potential negative health consequences in very small amounts, labeling regulations for trans fats in the United States should allow for less rounding error than labeling for other fats, and must not be able to claim 0g of trans fat unless there is actually no TFA or PHO present. In order to accomplish this, the threshold below which TFA content can be rounded to zero should be decreased to a number that would give less rounding error and allow fewer companies being able to claim 0g trans fat on their foods even when they contain PHOs. To add to this, rounding could be required to be to the nearest 0.1g up to 0.5g. Such labeling policies are feasible as they have already been implemented in Canada (CFIA 2005). Because rounding would still be necessary, for products that have TFA content that can be rounded to zero, some sort of indication such as an asterisk or a ‘~’ sign in front of the “0” should be made on the label to clearly indicate that the TFA content is approximately, not actually, zero. Making these alterations to TFA labeling policies would make labels more representative of their actual TFA content, which would allow consumers to actually be able to judge their level of TFA intake.                                                                            

To increase consumers’ ability to make informed choices about their diet, it is not sufficient to only change thresholds for rounding, it is also necessary to change the definition of a “serving size” in the United States. Serving sizes in the US (and in Canada), as previously mentioned, are currently based on reference amounts, which is in turn derived from what FDA considers as a reasonable amount of a certain food to be consumed in one sitting (CFR 2014). This is inherently ambiguous, as can be seen by the fact that the US and Canada have different reference amounts for the same foods (see Appendix 3; CFR 2014; CFIA 2015). Serving sizes based on reference amounts are also often misrepresentative of the actual amounts that people consume in one sitting, as can be seen by the example of one 88.5g (hand-held size) Doritos Nacho Cheese chip bag (which is usually consumed entirely in one sitting) having three servings per bag (see Appendix 4, Figure 2). Two solutions to this problem – that have already been proposed by FDA – are to make serving sizes more reflective of what is actually eaten by a consumer in one sitting, and to include two-column labels, one having information for one serving and the other having information for one package of the food (FDA 2014a). Either way, the amount of TFA present in any amount of food someone consumes must be clear, so as to allow consumers to make informed choices about their own health especially when it comes to such potentially dangerous substances as trans fats. 

Ultimately, the fact that labeling regulations for TFA content in processed foods allow content to be expressed as zero when it is not zero for a substance that research clearly shows is proportionally harmful to the degree it is consumed (IOM 2005) is highly problematic, especially when it causes people to inadvertently consume significant amounts of the substance they are trying to avoid. For the reason of truly allowing consumers to make their own health and diet decisions, it is important to implement more accurate TFA labeling regulations, whereby rounding and serving sizes would not be able to hide from a consumer that they are consuming trans fats. Furthermore, an understanding and resolution of this problem is important beyond providing consumers adequately accurate information in that the results of implementing more accurate TFA labeling are crucial to the debate on banning trans fatty acids. Depending on the results of improved TFA labeling, proponents of the ban may be able to more strongly conclude that labeling alone is not enough; or, critics of the ban may be actually be able to assert that labeling is favorable to a ban because the former allows for consumer choice (which it currently does not do). These arguments cannot be made without the introduction of clear and accurate TFA labeling. No matter what, first resolving the deceptiveness and lack of transparency in TFA labeling regulations will help move Americans in a direction of less trans fatty acid intake, resulting in fewer instances of heart attacks and deaths due to cardiovascular disease. Whether a TFA ban will be required or not in the future, once labeling regulations have been improved, is to be determined by further research and debate.

 

References

[AHA] American Heart Association. c2015. Know Your Fats [Internet]. American Heart Association; [updated 2014 Apr 21; cited 2015 Apr 17]. Available from: http://www.heart.org/heartorg/conditions/cholesterol/preventiontreatmentofhighcholesterol/know-your-fats_ucm_305628_article.jsp

Camp D, Hooker NH, Lin CJ. 2012. Changes in fat contents of US snack foods in response to mandatory trans fat labelling. Public Health Nutrition. 15(06): 1130-1137.

CBS. 2013. Industry shifted after NYC trans fat ban, but support still not universal [internet]. CBS News; [cited 2015 Apr 17]. Available from: http://www.cbsnews.com/news/industry-shifted-after-nyc-trans-fat-ban-but...

[CFIA] Canadian Food Inspection Agency. 2005. Labelling of Trans Fatty Acids. Government of Canada: Canadian Food Inspection Agency [Internet]. 2005 [cited 2015 Apr 17]. Available from: http://www.inspection.gc.ca/food/labelling/food-labelling-for-industry/n...

[CFIA] Canadian Food Inspection Agency. 2014. Specific nutrient content claim requirements trans fatty acid claims [internet]. Canadian Food Inspection Agency; [cited 2015 Apr 14]. Available from: http://www.inspection.gc.ca/food/labeling/food-labeling-for-industry/nut...

[CFIA] Canadian Food Inspection Agency. 2015. Information within the Nutrition Facts Table: Reference amounts [internet]. Canadian Food Inspection Agency; [cited 2015 Apr 14]. Available from: http://www.inspection.gc.ca/food/labeling/food-labeling-for-industry/nutrition-labeling/information-within-the-nutrition-facts-table/eng/1389198568400/1389198597278?chap=5

[CFR] Code of Federal Regulations. Food and Drugs, 21 C.F.R. Section 101.12 (2014). Available from: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=101.12.

Clapp J, Curtis CJ, Middleton AE, Goldstein GP. 2014. Prevalence of Partially Hydrogenated Oils in US Packaged Foods, 2012. Preventing Chronic Disease [Internet]. [cited 2015 Apr 16]; 11: 1-3. Centers for Disease Control and Prevention. Available from: http://www.cdc.gov/pcd/issues/2014/14_0161.htm

Dietz WH, Scanlon KS. 2012. Eliminating the Use of Partially Hydrogenated Oil in Food Production and Preparation. Journal of the American Medical Association. 308(2): 143–144.

Doell D, Folmer D, Lee H, Honigfort M, Carberry S. Updated estimate of trans fat intake by the US population. Food Additives and Contaminants. 2012 [cited 2015 May 4];29(6): 861–874.

[FAO] Food and Agriculture Organization of the United Nations. c2015. Food labelling [Internet]. United Nations [updated 2013 Sep 3; cited 2015 Apr 16]. Available from: http://www.fao.org/ag/humannutrition/foodlabel/en/

[FDA] U.S. Food and Drug Administration. c2003. Guidance for Industry: Trans Fatty Acids in Nutrition Labeling, Nutrient Content Claims, Health Claims; Small Entity Compliance Guide [internet]. U.S. Department of Health and Human Services: U.S. Food and Drug Administration; [updated 2014 Dec 12; cited 2015 Apr 16]. Available from: http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm053479.htm

[FDA] U.S. Food and Drug Administration. 2013a. Guidance for Industry: A Food Labeling Guide (16. Appendix H: Rounding the Values According to FDA Rounding Rules) [internet]. U.S. Food and Drug Administration [updated 2014 Nov 22; cited 2015 May 4]. Available from: http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryin...

[FDA] U.S. Food and Drug Administration. c2013b. FDA targets trans fat in processed foods [internet]. U.S. Food and Drug Administration; [updated 2015 Feb 25; cited 2015 Apr 13]. Available from: http://www.fda.gov/forconsumers/consumerupdates/ucm372915.htm

[FDA] U.S. Food and Drug Administration. c2013c. Tentative Determination Regarding Partially Hydrogenated Oils; Request for Comments and for Scientific Data and Information. The Federal Register [Internet]. [cited 2015 Apr 17]. Available from: https://www.federalregister.gov/articles/2013/11/08/2013-26854/tentative-determination-regarding-partially-hydrogenated-oils-request-for-comments-and-for

[FDA] U.S. Food and Drug Administration. 2014a. Proposed Changes to the Nutrition Facts Label [internet]. U.S. Food and Drug Administration; [updated 2014 Aug 1; cited 2015 Apr 17]. Available from: http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm385663.htm

Gelski J. c2015. Still no timeline for final pho GRAS rule [internet]. Food Business News; [cited 2015 Apr 17]. Available from: http://www.foodbusinessnews.net/articles/news_home/regulatory_news/2015/03/still_no_timeline_for_final_ph.aspx?id={4a839484-0efa-440e-828e-db4589792f99}&cck=1

Gordon S. 2011. Trans Fat on Food Labels: The New Math [internet]. Prevention; [cited 2015 May 4]. Available from: http://www.prevention.com/food/smart-shopping/fda-sets-new-trans-fat-gui...

[IOM] Food and Nutrition Board, Institute of Medicine of the National Academies. Dietary reference intakes for energy, carbohydrate, fiber, fat, fatty acids, cholesterol, protein, and amino acids. Washington, D.C.: National Academies Press; 2005.

Micha R, Mozaffarian D. 2008. Trans fatty acids: Effects on cardiometabolic health and implications for policy. Prostaglandins, Leukotrienes and Essential Fatty Acids. 79(3-5): 147-152.

Michas G, Micha R, Zampelas A. 2014. Dietary fats and cardiovascular disease: Putting together the pieces of a complicated puzzle. Atherosclerosis. 234: 320-328.

Nishida C, Uauy R. 2009. WHO Scientific Update on health consequences of trans fatty acids: introduction. European Journal of Clinical Nutrition. 63: S1-S4.

Resnik D. 2010. Trans Fat Bans and Human Freedom. The American Journal of Bioethics. 10(3): 27-32.

Scott-Thomas C. 2009. Company claims consumers duped by trans fat labeling loophole [internet]. [cited 2015 Apr 17]. Available from: http://www.foodnavigator-usa.com/suppliers2/company-claims-consumers-duped-by-trans-fat-labeling-loophole

[SND] Self Nutrition Data. c2014. Nutrition facts: Cookies, chocolate chip, commercially prepared, regular, higher fat, enriched [internet]. Self Nutrition Data; [cited 2015 May 4]. Available from: http://nutritiondata.self.com/facts/baked-products/4935/2

Uauy R, Aro A, Clarke R, L'Abbé M, Mozaffarian D, Skeaff M, Stender S, Tavella M. 2009. WHO Scientific Update on trans fatty acids: summary and conclusions. European Journal of Clinical Nutrition. 63: S68-S75.

 

Appendix 1: Rounding in Canada and the United States

FDA requires that trans fat amounts below 0.5g be rounded to 0g, amounts between 0.5g and 5g be rounded to the nearest 0.5 gram, and amounts above 5g be rounded to the nearest 1 gram (FDA 2013a). In Canada, amounts of TFA less than 0.2g are rounded to 0g, amounts between 0.2g and 0.5g are rounded to the nearest 0.1g, amounts between 0.5g and 5g are rounded to the nearest 0.5g, and amounts above 5g are rounded to the nearest 1g (CFIA 2005).

 

Appendix 2: When Trans Fatty Acid Content can be Claimed as 0g in Canada and the United States

In the US, foods can be labeled as having 0g trans fat if there is less than 0.5g per serving (FDA 2003); a serving is based on “reference amounts customarily consumed per eating occasion” (CFR 2014:2), which is provided by the Code of Federal Regulations Title 21. In Canada, a food can be labeled as “free of trans fatty acids” when the food “contains less than 0.2g of trans fatty acids per i) reference amount and serving of stated size, or ii) serving of stated size, if the food is a prepackaged meal” (CFIA 2014:1). Here, similar to in the US, a “reference amount” is defined to be “a specific regulated quantity of a type of food usually eaten by an individual at one sitting” (CFIA 2015:1)

 

Appendix 3: Reference Amounts for Some Foods in Canada and the United States

Chips: 50g in Canada, 30g in the United States (CFIA 2015; CFR 2014)

Yogurt: 175g in Canada, 225g in the United States (CFIA 2015; CFR 2014)

Cottage Cheese: 120g in Canada, 110g in the United States (CFIA 2015; CFR 2014)

  

Appendix 4: Figures

 

 

Figure 1: Hershey’s Cookies and Cream Chocolate from Canada. Picture taken on April 15, 2015, in Burlington, Ontario, Canada. Serving size is 50g, or half a bar. Trans fat content labeled as 1g.

 

 

 

Figure 2: Hershey’s Cookies and Cream Chocolate from the U.S. Picture taken on April 13, 2015, in Cambridge, MA, USA. Serving size is 43g (6 blocks). Trans fat content is labeled as 0g.

 

Figure 3: Doritos Nacho Cheese Chips from Canada. Picture taken on April 13, 2015, in Burlington, Ontario, Canada. Serving size is 80g (one package). Trans fat content is labeled as 0.2g.

 

 

Figure 4: Doritos Nacho Cheese Chips from the U.S. Picture taken on April 13, 2015, in Cambridge, MA, USA. Serving size is 28g, or about 11 chips. Trans fat content is labeled as 0g.