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Case Study

Trans Fat Elimination in the Philippines

The Philippines mandated the elimination of industrially produced trans fat from its food supply – a policy supported by local civil society advocates working in partnership with the Global Health Advocacy Incubator (GHAI).

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The Challenge

Cardiovascular disease is the Philippines’ leading cause of death, and is increasingly linked to trans fat consumption. Trans fatty acids (TFAs) are commonly consumed in the form of partially hydrogenated oil (PHO). In 2011, the Philippines’ Department of Health called for the elimination of these industrially produced TFAs from the food supply as part of a broader strategy to promote healthy diets and reduce the country’s chronic disease burden. However, this call was not followed up by laws, regulations or other policy measures limiting TFA in food. A change to the status quo looked unlikely as long as public awareness of the health harms of TFA remained low.

Research and Legal Analysis

GHAI partnered with ImagineLaw in 2018 to catalyze and support government action. ImagineLaw is a Manila-based nonprofit law organization that designs and advocates for evidence-based health policies. The first step in this process was to understand and assess the market landscape. ImagineLaw commissioned research on the local production and importation of PHOs and foods high in TFA, drawing on a GHAI toolkit for market mapping (“Partially Hydrogenated (PHO) Market Mapping: Identifying Sources of Industrially Produced Trans-Fatty Acids in the Food Supply"). The research found that one PHO manufacturer was responsible for half of the country’s PHO market, while the other half was comprised of imports.

The World Health Organization (WHO) recommends two approaches for limiting TFA in the food supply: capping industrially produced TFA at 2 grams per 100 grams of total fat and banning PHO. The market map suggested that a hybrid approach utilizing both best practices would be necessary in the Philippines. ImagineLaw conducted a legal analysis which suggested that these objectives could best be met with a multi-pronged strategy that included both legislative and administrative measures.

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Supporting Government Action

ImagineLaw engaged key decision makers at the Department of Health (DOH) and beyond to explore next steps, and joined a Healthy Diet Technical Working Group (TWG) established by DOH in July 2019 to lead policy development. DOH held a series of meetings and workshops with the Philippines Food and Drug Administration (FDA), National Nutrition Council, WHO and other stakeholders to begin building support for the elimination of industrially produced TFA and explore policy pathways. DOH worked closely with ImagineLaw, WHO and others to craft a policy memo informing the development of TFA measures, including an administrative order directing FDA to establish a TFA limit and ban PHOs. ImagineLaw is now working with members of Congress to advance complementary legislation.

Media Advocacy

ImagineLaw launched a national campaign, Trans Fat Free Philippines, to generate public awareness and support for trans fat elimination. The organization created an informational website and worked with digital influencers to raise awareness and support for TFA elimination measures. In collaboration with government partners, ImagineLaw produced a series of public service announcements that have been shown online and in health facilities across the country. ImagineLaw also engaged influential journalists and media figures, including the award-winning children’s book author Dr. Luis Gatmaitan, who in 2020 published a book on cardiovascular health and trans fat titled Ang Tatay Kong Mahilig sa Instant (“My Father Who Likes Instant”). The book was featured in a storytelling series hosted by the National Library of the Philippines, and shared with political decision makers.

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Monitoring and Capacity-Strengthening

ImagineLaw and other civil society partners shared information about healthier PHO alternatives with officials and provided support for the government to increase its capacity to test for TFA in foods, fats and oils. These are necessary steps for the government to monitor and enforce TFA measures. The civil society groups also identified and countered misinformation and opposition from the food and oil industry and provided decisionmakers with accurate data. GHAI tracked public conversations related to TFA and helped campaign partners adjust messages and tactics to maximize effectiveness.

Adapting Advocacy During the Pandemic

As COVID-19 spread around the world, pandemic response became the government’s primary priority. ImagineLaw supported these efforts, while positioning TFA elimination as part of a long-term vision for strengthening public health and resilience, particularly as evidence grew linking chronic illness with increased risk of death and illness from COVID-19. Campaign partners shifted to digital technology to advocate, coordinate and implement activities, aided by strong relationships established pre-pandemic.


The advocacy and educational efforts paid off on July 20, 2021, when an administrative order signed by the Philippines’ Secretary of Health, Francisco T. Duque III, went into effect. The order puts the country on a path to eliminating industrially produced TFA from its food supply, and specifically calls on FDA to issue and enforce TFA limits in line with WHO recommendations within two years. Advocacy continues to advance complementary TFA regulatory and legislative measures.

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Lessons Learned

  • Government leadership and ownership is key to successful policy change, and civil society engagement is often required to make this happen
  • Civil society coalitions are critical to success, particularly when they include constituents and partners with diverse strengths
  • Media advocacy and social mobilization are critical to building and demonstrating broad support for trans fat elimination and other health priorities
  • Industry groups may oppose public health campaigns that threaten their revenues, and need to be addressed as part of the advocacy efforts