Opening Remarks by Executive Director

Delivered by Tan Sri Datuk Dr Yusof Basiron, the Executive Director of CPOPC at the 4th Technical Working Group on 3-MCPD and GE, 3 December 2019, Jakarta, Indonesia

  • Thank you very much for accepting the invitation of CPOPC to participate in the 4th Technical Working Group (TWG) meeting 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). Today, I am happy to welcome Mr Edy Sutopo, Director for Forest and Estate-Crops, Ministry of Industry, Indonesia as a Vice-Chairman of this Technical Working Group. This will be his first meeting, and we would like to welcome him wholeheartedly.
  • As you are all aware, currently the reduction of 3-MCPD esters and glycidyl esters (GE) is a high priority agenda for the oils and fats industry. The European Union (EU) had already 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 1,000 µg/kg or 1 ppm on 26th February 2018.
  • Next, the EU is proposing a regulation on 3-MCPDE. I want to raise your kind attention on the European Union’s proposed Regulation on maximum levels of       3-MCPDE. In particular, this EU draft Regulation includes a maximum limit of   1,250 µg/kg of 3-MCPDE for vegetable oils mostly produced in Europe, including sunflower, rapeseed, olive oils, and an upper limit of 2,500 µg/kg for other oils including palm oil.
  • As it is currently drafted, the measure would:
  1. Stigmatise the use of palm oil, without any scientific justification;
  2. Discriminate against palm oil as opposed to other vegetable oils;
  3. Disregard the technological processes and innovations developed by the palm oil industry under international safety standards

All the above will result in negative perception among consumers that palm oil is unhealthy because it contains higher levels of 3-MCPDE. In fact, if safety is the main concern, then one single limit for all vegetable oils should have been proposed. Unfortunately, this is not the case.

  • As recent data and studies shows, the negative European sentiment towards palm oil is affecting its consumption.  This current draft is only going to increase such negative perception.   Moreover, as the EU is a leader when it comes to food safety standards, the discriminatory approach of the 3-MCPDE draft Regulation could easily spill to other regions of the world.
  • For these reasons, and in view of the upcoming notification of the EU draft measures to the World Trade Organisation (WTO), it will be crucial that palm oil producing countries  mobilise and raise objections on this proposal. The Government of Colombia had already raised concerns on this discriminatory approach at the SPS Committee of WTO meeting in June 2019.
  • Indonesia, Malaysia, Colombia and other palm oil producing countries could surely play a key role in connecting with other producing countries to defend and proudly promote palm oil reputation and quality at WTO and other international forums.
  • On the issue of the contaminant level of the 3-MCPDE as proposed by the European Commission, the 7th Ministerial Meeting of CPOPC on 16th July 2019 agreed that one maximum level at 2,500 µg/kg for all vegetable oils should be adopted, as the acceptable safety limit for consumption.
  • At the last TWG3 meeting, the Working Group had drafted a narrative on why we are supporting for one single limit of 2,500 µg/kg for 3-MCPDE. Following are some of the justifications:
  • 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 body weight 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 backgrounds 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.
  • At today’s meeting, there is an agenda to discuss on organising a one-day workshop on 3-MCPDE and GE as agreed by SOM 19.  There are various mitigation strategies and recommended practices being discussed and presented in seminars and conferences already. 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 workshop is important as we would like to engage all the experts and technology practitioners 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 workshop is able to agree and deliberate on some of these proposed 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 every one of you at this meeting and subsequent meetings.
  • Thank you.