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Understanding the PHO Ban

The U.S. Food and Drug Administration finalized and published its determination on June 17, 2015 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. Download Our “Understanding the PHO Ban” Guide

Major Provisions of the FDA Declaratory Order

  • FDA has defined PHO as those liquid fats and oils that have been hydrogenated but not to near completion and with an iodine value (IV) greater than 4.
  • The FDA has also determined that Fully Hydrogenated Oil (FHO) contains less than 2% trans-fat, and the definition of FHO is near complete saturation with an iodine value (IV) value of 4 or less. The declaratory order is limited to PHOs only and does not affect FHOs.
  • PHOs are not GRAS for use in any human foods.
  • The FDA order specifies a compliance date of no later than June 18, 2018.
  • Any interested party may seek food additive approval for one or more specific uses of PHOs, with data demonstrating a reasonable certainty of no harm of the proposed use. GRAS determination does not apply to naturally occurring trans-fat.
  • The PHO ban applies only to food for human consumption and does not include animal feed.


While the FDA has provided a 3-year period for compliance, we strongly encourage the implementation of replacement solutions as soon as possible. IOI Loders Croklaan has developed more than 200 PHO free solutions offering functionality across a wide range of applications leveraging the versatility of palm oil. In order to facilitate our customers in finding solutions we launched our “Creative Studio”, a comprehensive research applications lab, in 2013.