Opening Remarks by Executive Director of CPOPC

Delivered by Tan Sri Dr Yusof Basiron, the Executive Director of CPOPC at the 3rd Technical Working Group on 3-MCPD and GE, 26 August 2019, Jakarta, Indonesia

  • Thank you very much for accepting the invitation of CPOPC to participate in the 3rd Technical Working Group (TWG) on 3-MCPDE and GE in Jakarta today.
  • CPOPC is grateful to the Government of Indonesia, Malaysia and Colombia for nominating you as expert members of this Technical Working Group (TWG). I am happy to note that Indonesia is going to name a Vice Chairman of this Technical Working Group today. This would further facilitate the working of this Group.
  • As you are all aware, the reduction of 3-MCPD esters and glycidyl esters (GE) is a high priority for the oils and fats industry. On 26th February 2018, the European Union (EU) had enacted Regulation (EU) 2018/290 which sets maximum limits for glycidyl fatty acid esters or GEs, with a level for edible oils and fats set at 1 ppm.
  • Next, the EU is proposing a regulation on 3-MCPDE. The European Commission has proposed two levels for vegetable oils and fish oils for the final consumer, or for use as food ingredients. The levels as you know are 1.25 ppm for coconut, maize, rapeseed, olives, sunflower, soyabean and palm kernel and mixtures of oils and fats from this category; and 2.5 ppm for others including palm oil.
  • Following joint outreach to the European Commission and respective national authorities, Member States and EU Commission have agreed to set an implementation time of 18 months. The EU will publish the publication in October 2019 after a public comment scheduled to start by end of this month (August 2019). The expected entry into force of maximum limits with effective from 1 January 2021.
  • In January 2018, the European Food Safety Authority (EFSA) had published the ‘Update of the Risk Assessment on 3-monochloropropanediol (3-MCPD) and its Fatty Acid Esters’. The EFSA found that palm oil and derivatives to have the highest levels of 3-MCPD, 2-MCPD (including esters) and GEs. Approximately around 6 million tonnes of tropical fats are refined across Europe, with 90% refined in the EU. Given the EFSA findings and the current developments at the Commission, it is likely to be a question of when, rather than if, the EU regulates 3- and 2-MCPDs as well.
  • On the issue of the contaminant level of the 3-MCPDE as proposed by the European Commission, the 7th Ministerial Meeting of CPOPC on 16 July 2019 agreed that one maximum level at 2.5 ppm for all vegetable oils should be adopted, as the acceptable safety limit for consumption. This has been publicise in the media and we will communicate the same position at the EU Public Comment and other avenues.
  • Following are the reasons for CPOPC decision:
  • We believe that this proposed level of 3-MCPDE in food is considered safe for most consumers and meet the conclusions of the EFSA opinion in January 2018 which concluded that the established TDI of 2 µg/kg bodyweight per day is not exceeded in the adult population. The impact on population would be minimal considering that the higher limit of 2,500 µg/kg or 2.5 ppm would apply to the majority of vegetable oils including blends which are largely used in processed foods.
  • Acknowledging that consumer health should be a priority, the EU should allow consumers to be safe regardless of the type of vegetable oil they may include in their diets.
  • We are in the opinion that split-levels simply result in a discrimination between different oils, without any scientific basis and no justifiable health reason. It is important to note that the content of 3-MCPDE is not simply connected to the type of oil used, but is actually due to the quality and freshness of the raw material, as well as to the process therein. The ‘other refined vegetable oils’ category would mislead the consumer and made them perceive such vegetable oils as bad compared to the other category of vegetable oils for which a lower limit is suggested.
  • Split-levels also add unnecessary complexity for the production of oil blends since mixture or blends of vegetable oils have to meet customers’ demands for functionality or taste in the final products.
  • The knowledge and know-how of 3-MCPDE generation and its relationship with the formation of GE in oil refining is still incomplete. Mitigation of              3-MCPDE is a complex issue requiring more research, process modifications and industrial trials namely on reduction of precursors in crude oils and on each production steps (degumming, neutralization, washing, bleaching and deodorization).
  • Split-levels will add additional and unnecessary costs and burden for processors to perform, monitor and comply to official controls.
  • Split-levels would not be consistent with the usual process contaminants risk management. If a certain level is considered ‘safe’, then it should be the same one for all foods within the same category, without any discrimination.
  • The EU should support and encourage the continuous efforts in research and investments made by the industry through mitigation measures aimed at reaching as low as reasonable achievable (ALARA) levels of 3-MCPDs, as reflected in Regulation EC (No) 1881/2006. A split-level would not be an incentive to continue investing in these mitigation measures.
  • It would be appropriate to follow the same approach used for regulatory measures on GEs, where one maximum limit was established for all vegetable oils.
  • Based on these background and the importance of palm oil as food products globally, the TWG is entrusted to discuss, develop and propose solutions to the proposed EU regulation. At the same time, to evaluate and propose mitigation efforts to limit the content of these compounds in palm oil that can be shared amongst palm oil producing countries.
  • Recently in July 2019, Codex Alimentarius Commission has adopted a Code of Practice on how to prevent and reduce 3-MCPDE and GE formation in refined oils processes. According to the Code of Practice, tackling the formation of 3-MCPDEs and GEs in edible oils involves following good practices during cultivation, harvesting and transportation of oil palm fruits to milling and finally refining and further food processing.
  • Over the past few years, we have heard various research and industrial trials on how to mitigate the formation of 3-MCPDEs and GEs. There are various mitigation strategies and recommended practices being discussed and presented in seminars and conferences. As proposed by TWG, CPOPC is going to organize workshops to share information and experiences by the industry and R&D institutions in mitigating 3-MCPDE and GE in palm oil processes based on all these findings.
  • This TWG is tasked to provide recommendations that can be shared and implemented by palm oil producing countries to reduce 3-MCPDEs and GEs in palm oil. We sincerely hope that this TWG is able to agree and deliberate on some of these propose targets that we can bring up to CPOPC member countries on:
  • Sharing of information and lesson-learned on works currently being undertaken to mitigate the formation of 3-MCPDE/GE throughout the supply chain industries.
  • Exchange of research outputs and propose collaborative works to further research projects in understanding the fundamental mechanics of the formation of these contaminants.
  • Identifying and promoting the most cost-efficient technologies to further reduce 3-MCPDE/GE levels in various stages of palm oil production from upstream, midstream and downstream.
  • Proposing a common revised CPO specification to properly address the mitigation efforts and to further improve the quality specifications of edible oils.
  • Once again, thank you very much for your kind participation today. I wish you all a good deliberation and fruitful discussion. I am looking forward to further engage with each and every one of you at this meeting and subsequent meetings.
  • Thank you.