G/TBT/W/566  
 
29 November 2018  
(18-7535) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
 
EUROPEAN UNION — APPLICATION OF REGULATI ON NO. 1169/2011 AND  REGULATION 
(EC) NO 1924/2006 AS  REGARDS THE LABELLI NG OF FOOD PRODUCTS,  IN NOT 
PROHIBITING OR EXAMI NING TH E USE OF "PALM OIL F REE" LABELS  
STATEMENT BY INDONESIA  TO THE COMMITTEE ON TECHNICAL BARRIERS TO TRADE  
14 AND 15  NOVEMBER  2018 
The following communication, dated 22 November 2018 , is being circulated at the request of the 
delegation of Indonesia . 
 
_______________  
1.  The Government of Indonesia would like to once again raise its concerns regar ding the use of 
"palm oil free" label ling by a number of  food producing companies in the EU. Indonesia is deeply 
concerned that some of these food products with "palm oil free " labels are exported to countries 
outside the EU, including Indonesia. As a majo r CPO producer and exporter to a number of regions, 
including Europe, Indonesia is worried of the impact these labels may have on its trade and exports, 
to the EU as well as other regions.  
2.  The use of these labels lead to confusion and misguided understandi ng among consumers on the 
effects of food products that contain palm oil. The use of labels without or not based on scientific 
evidence by food exporters creates unfair trade, and we encourage the EU to remain consistent with 
EU Regulation No.1169/2011 on Food Information, Chapter V Art. 36.2, which states that voluntary 
shall not mislead and be ambiguous for consumer s and where necessary shall be provided with 
scientific evidence.   
3.  Indonesia also finds that palm oil free labelling is contrary to the EU 's decision not to give 
authorization to food producers to make any health claims concerning palm oil due to insufficient 
scientific evidence based on EU Regulation 1924/2006 on nutrition and health claims.  
4.  Indonesia takes this opportunity  to emphasize that there are international  research  on the 
content s of palm oil, the results of which can be considered as scientific justification on the positive 
impacts of palm oil, the y include, among others:  
a. Palm oil contains saturated fatty acids and  un-saturated fatty acids at a balanced level  
b. Palm oil is not associated with an increased risk of cardiovascular disease  
c. Palm oil contains micro elements of antioxidants which benefit the health (carotenoids, 
vitamin E and sterols)  
d. Palm oil has a quality advantage as an oil for frying compared to other vegetable oils. This 
is associated with free fatty acids (non trans fatty acids)  
5.  Considering these information, Indonesia encourages the EU to be fair and consistent  in 
monitoring the use of these labels,  especially where the labels are not based on scientific  evidence 
and can mislead consumers.  G/TBT/W/566  
 
- 2 - 
 
  6.  Indonesia encourages the EU to consider the principle of non -discrimination regarding the 
treatment of palm oil compared to other vegetable oils (sunflower, soybean, rapeseed oil)  produced 
in the EU . Indonesia strongly believes in the importance  of providing  scientific evidence with regard  
to the impact of palm oil in food products on human health, and also encourages the EU to provide 
scientific evidence and compariso n of the health impacts of other vegetable oils.  
7.  Indonesia emphasizes that the EU need to be consistent with the Article 2.1 of the TBT Agreement 
on non -discrimination, as well as Article 3.4  and 3.5  on measures implemented local governments 
and NGOs that must be consistent with the  TBT Agreement. Indonesia  encourages the EU to consider 
necessary actions to ensure that their local governments and NGOs  remain  consistent with the TBT 
Agreements  when implementing measures . 
__________