Regulatory Watch: Trans Fat, GRAS, Fragrance Guidelines and More

Recently, a range of regulatory activities affecting the flavor and fragrance industry have been announced, impacting everything from trans fat to product-specific fragrance disclosure.

Trans Fat & GRAS Under Attack

In June, the U.S. Food and Drug Administration (FDA) officially concluded that partially hydrogenated oils (PHOs), the primary dietary source of artificial trans fat in processed foods, are not generally recognized as safe or GRAS for use in human food. As a result, food manufacturers will have three years to remove PHOs from products, or petition the FDA regarding their safety. In food formulations, trans fats can enhance flavor, texture and shelf life. Many companies had already reformulated products to avoid the use of PHOs.

That same month, the Flavor and Extract Manufacturers Association (FEMA; issued a response to an article, “Meet the Secret Group That Decides Which Flavors Are ‘Natural,’” published by the Center for Public Integrity (CPI) at, which questioned the legitimacy of the FEMA generally recognized as safe (GRAS) process for flavor ingredient assessments. FEMA noted in a statement that it was “disappointed that CPI failed to report on the information that fully describes our process, rationale and safeguards to assure flavor safety, which was provided to the organization in extensive documentation.” The organization had provided more than 250 citations of accessible flavor safety publications on flavor safety and the FEMA GRAS program.

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