European Margarine Association
IMACE
IMACE represents the margarine industry's common interests on non-competitive issues and works towards obtaining a regulatory framework at EU level that responds to the needs of margarine manufacturers.
ID: 580415127070-95
Lobbying Activity
Response to EU cardiovascular health plan
15 Sept 2025
IMACE welcomes the Commission initiative to create an EU cardiovascular (CVD) health plan plan and is pleased to provide our sector views and suggestions to contribute to this consultation. Next to lifestyle changes, shifting to healthier consumption patters and in particular also healthy fat consumption across society can contribute significant to reduce the CVD risks. Education, information on the fat quality and clear dietary recommendations and public procurement guidance on the fat quality of foods could contribute to healthier dietary fat intakes.
Read full responseResponse to Environmental claims based on environmental footprint methods
20 Jul 2023
IMACE would like to thank the Commission to give us the possibility to provide feedback on the legislative proposal on substantiating green claims. We expressed several concerns and suggestions in the document in annex to further improve the current proposal, making it as effective as possible without exessive burden for the companies (in particular for SMEs).
Read full responseResponse to Setting of nutrient profiles
2 Feb 2021
IMACE – the European Margarine Association – welcomes the opportunity to contribute to the public consultation on the Inception Impact Assessment (IIA) on the proposal for a revision of the FIC Regulation. From the margarine and spreads perspective, the FIC is overall fit for purpose. Nonetheless, specific provisions have proved ill-adapted to consumer information and should be revised.
IMACE herein provides its views on two of the key aspects of the IIA (front-of-pack nutrition labelling and country of origin labelling), before addressing additional elements for revision:
• Trans Fatty Acids (TFA);
• Portion sizes;
• Indications on food suitable for vegetarians and vegans.
Please find in annex our detailed input.
Read full responseResponse to Farm to Fork Strategy
16 Mar 2020
The forthcoming Farm to Fork Strategy will be instrumental to achieve the objectives of the EU Green Deal and for a successful transition to a low-carbon, circular economy. Thus, IMACE – the European Margarine Association – welcomes the opportunity to comment on the European Commission’s Roadmap and to provide its views on sustainable food systems.
The plant-based margarine and spreads sector endorses the need for a holistic and horizontal approach towards transforming the way we produce and consume food as much as how we dispose of land and waste. In this document, IMACE shares in the document attatched recommendations for a comprehensive EU food policy, from sustainable production to diets.
Read full responseResponse to Establishing a legal limit for the industrial trans fats content in foods
29 Oct 2018
The European Margarine Association (IMACE) supports the proposed legislation by the European Commission (by amending Part B of Annex III to Regulation (EC) No 1925/2006) setting a legal limit in the content of industrially produced trans fats in food which is intended for the final consumer that shall not exceed 2 grams per 100 grams of fat.
Over the past 20 years, IMACE members have been supporting the industry’s initiatives to reduce trans fatty acids (TFA) in margarines and spreads, via reformulation, optimisation of refining processes in accordance with the IMACE Code of Practice on TFA(1). As a result, IMACE already complies to the requirements of the proposed regulation. Following these numerous industry actions, significant overall reductions in the non-ruminant TFA content of food products sold to the final consumers have been achieved. Consequently, the intake of non-ruminant TFA in the EU has decreased considerably over recent years to a level, where there is no longer a general public health concern whereas ruminant TFA have become the main source of TFA intake in Western Europe.
This decrease was also highlighted by EFSA in its opinions of 2004(2) and 2009(3), based on data analysis at national level.
IMACE is of the opinion that the proposed policy option, which is only applicable to one source of TFA (non-ruminant TFA), does not address the public health issue concerning the TFA intake fully.
Given the fact that both TFA sources are equally detrimental to public health(2,3,4,5,6,9), as also confirmed by the latest WHO Report(7), IMACE is of the opinion that, on the basis of non-discriminatory measures as provided for in the EU General Food Law, specific consumer information/education may help to address this limitation.
Moreover, IMACE is of the opinion that the current full/partial hydrogenation labelling, pursuant to Regulation (EU) No 1169/2011 will become redundant once a legal limit is set in force. Such labelling does not bring any added value in helping consumers make informed and healthy choices. Given the limited/wrong understanding of the consumers and the negative perception on the Partially Hydrogenated Vegetable Oils (PHVO)/Fully Hydrogenated Vegetable Oils (FHVO) information, the current mandatory labelling stigmatizes the margarines and spreads sector unfairly (8). This is confirmed by the EU Commission report (9).
References
(1) IMACE Voluntary Code of Practice on TFA
(2) EFSA opinion of the scientific panel on dietetic products, nutrition and allergies on a request from the Commission related to the presence of trans fatty acids in foods and the effects on human health of the consumption of trans fatty acids. 8 July 2004
(3) EFSA Scientific Opinion on Dietary Reference Values for fats, including saturated fatty acids, polyunsaturated fatty acids, monounsaturated fatty acids, trans fatty acids, and cholesterol. EFSA Journal 2010; 8(3):1461. [107 pp.]1461
(4) Gebauer S. et al. (2015), Vaccenic acid and trans fatty acid isomers from partially hydrogenated oil both adversely affect LDL cholesterol: a double-blind, randomized controlled trial. American Journal of Clinical Nutrition, 2015
(5) Brouwer IA, Wanders AJ, Katan MB. Effect of Animal and Industrial Trans Fatty Acids on HDL and LDL Cholesterol Levels in Humans: a quantitative review. PLOS ONE 2010; 5(3):e9434
(6) Yanping et al. Saturated fats compared with unsaturated fats and sources of carbohydrates in relation to risk of coronary heart disease. Journal of American college of Cardiology, vol 66 N°14, 2015
(7) Brouwer IA. Effect of trans-fatty acid intake on blood lipids and lipoproteins: a systematic review and meta-regression analysis. WHO 2016
(8) A&B Danish study on consumer understanding of PHVO/FHVO, MIFU 2014
(9) Report from the Commission to the European Parliament and the Council regarding trans fats in foods and in the overall diet of the Union population – December 2015 – COM(2015)
Read full responseMeeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and The EU Vegetable Oil and Proteinmeal Industry
26 Sept 2018 · EU initiative on transfats
Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis) and The EU Vegetable Oil and Proteinmeal Industry
13 Apr 2018 · Trans fats acids