WAGING WAR ON A SILENT KILLER: WHY NIGERIA’S FATS AND OILS REGULATIONS 2022 MATTER AND WHAT MANUFACTURERS MUST DO NOW
By Aniekan Akpan and Maria Amos

In the arsenal of public health threats facing Nigeria, industrially produced trans fats — iTFAs — are stealthy, persistent, and lethal. They are woven into the very fabric of modern diets, lurking in everyday staples: margarine, pastries, street food, fried snacks. And while they may be tasteless, their consequences are not. iTFAs are known contributors to coronary heart disease and other noncommunicable diseases (NCDs) that collectively account for more than 30% of deaths in Nigeria annually.

This is why the federal government’s decision to adopt and enforce the Fats and Oils Regulations, 2022, spearheaded by the National Agency for Food and Drug Administration and Control (NAFDAC), marks a critical inflection point in the nation’s public health trajectory. These regulations are not merely technical amendments to food safety protocols—they are an assertive regulatory intervention, rooted in international best practices and designed to eliminate a toxic compound that has no physiological justification in the human diet.

But regulatory success in Nigeria, like elsewhere, has less to do with the strength of the law on paper and more to do with implementation, enforcement, and—importantly—industry compliance.

The Biochemistry of Harm

The science around iTFAs is settled. Industrial trans fats are chemically modified oils created through partial hydrogenation—a process that stabilises liquid vegetable oil, turning it into a semi-solid fat useful for commercial food production. While this transformation may benefit food shelf life and texture, it wreaks havoc on cardiovascular health.

Trans fat consumption increases low-density lipoprotein (LDL) cholesterol—the so-called “bad” cholesterol—while decreasing high-density lipoprotein (HDL), or “good” cholesterol. The resulting lipid profile elevates the risk of atherosclerosis, myocardial infarction, and ischemic stroke. The World Health Organization (WHO) estimates that iTFAs are responsible for more than 260,000 deaths globally every year, with a disproportionately high burden in low- and middle-income countries.

Unlike saturated fats, which are controversial but metabolically functional, iTFAs confer no nutritional value. They are, as the WHO has plainly stated, “an unnecessary toxic compound.” This scientific consensus led to the launch of the REPLACE action package in 2018, an initiative aimed at eliminating iTFAs from the global food supply by 2023.

Nigeria’s regulatory response was not only timely—it was imperative.

The Legal Regime: What the 2022 Regulations Actually Say

The Fats and Oils Regulations, 2022, issued under the NAFDAC Act and the Food, Drugs and Related Products Act, introduced a structured framework for regulating the presence of iTFAs in the Nigerian food environment.

The regulation is unambiguous: Regulation 7(3) imposes a legal limit of 2 grams of industrially produced trans fats per 100 grams of total fat content in any edible fat, oil, or fat-containing food product. This mirrors the WHO’s model regulations and places Nigeria in alignment with regulatory benchmarks already adopted in countries such as Denmark, India, and South Africa.

Importantly, the regulations apply extraterritorially—they govern both locally produced and imported products. That provision closes an oft-exploited loophole that allows domestic bans to be circumvented via transnational supply chains.

The regulations go further. Regulation 7(1) mandates full disclosure of fat composition on product labels—saturated, trans, mono-, and polyunsaturated fats, as well as cholesterol. Regulation 7(4) prohibits any “trans fat-free” or “cholesterol-free” claims unless scientifically verified and expressly approved by NAFDAC. The provision targets a growing pattern of deceptive labelling practices, especially prevalent in the unregulated market for street foods and low-cost snacks.

Also of note is Regulation 6(3), which demands that any blend of animal and vegetable fats must be clearly labelled, leaving no room for ambiguity. This reflects an important philosophical shift: regulation should not just enforce safety but ensure informed dietary choice.

Compliance Is Not Optional

The burden of implementation falls squarely on manufacturers and distributors. Regulation 9(1) of the Regulations requires registration of all regulated products with NAFDAC prior to any form of commercial activity, including advertising, distribution, or sale. This registration process is not procedural window-dressing. It is a mandatory gatekeeping mechanism to ensure that no product enters the market without regulatory vetting.

Moreover, manufacturers are expected to reformulate. The technical challenge here is real: reformulating products to reduce iTFA content may require substituting partially hydrogenated oils with more expensive alternatives such as high-oleic vegetable oils, interesterified fats, or fully hydrogenated oils (which do not contain trans fats). But these are not insurmountable hurdles. Global case studies from Colombia to Thailand have shown that reformulation can be achieved without compromising taste, shelf life, or production costs.

Noncompliance carries stiff penalties. Offenders may face up to ₦800,000 in fines or one year imprisonment (or both) if they are individuals, and up to ₦5 million in fines for corporate bodies. Moreover, directors, managers, and officers of offending corporations may be held personally liable. This is not symbolic enforcement. It is a deliberate strategy to create corporate accountability.

More strikingly, Regulation 11 of the Regulations provides for asset forfeiture upon conviction—including both the proceeds of the offence and any instrumentalities used in its commission. That is a regulatory design feature intended to dismantle commercial incentives for noncompliance.

Why This Matters Now

There is an urgent political economy dimension to these regulations that cannot be ignored. Nigeria is facing a growing epidemic of noncommunicable diseases. According to Nigeria’s National Policy for the Prevention and Control of NCDs, over one-third of deaths in Nigeria are attributable to NCDs, and cardiovascular diseases are the leading cause. The vast majority of these deaths are preventable.

But unlike communicable diseases, which demand large-scale vaccination campaigns or vector control programs, NCD prevention often hinges on regulatory interventions—especially those targeting food environments. Nigeria’s iTFA regulation is not just a technical exercise in food composition; it is an evidence-based public health intervention with life-saving consequences.

This is especially relevant in a country with a vibrant informal food economy and an expanding ultra-processed food industry. Street food vendors, small bakeries, and multinational corporations all play a role in shaping the average Nigerian diet. A regulatory environment that tolerates harmful ingredients risks compounding the health inequalities that are already entrenched by income, geography, and gender.

What Manufacturers Must Do—Now

For manufacturers, this is a moment of reckoning. Compliance will not be optional; it will be monitored, enforced, and audited. Reformulation plans should already be underway. Ingredient procurement systems must adapt. Internal quality control procedures must align with the new thresholds. Product labels must be redesigned. Marketing teams must undergo regulatory training. NAFDAC must become a partner, not an afterthought.

But compliance also offers a competitive edge. Manufacturers who meet the 2g/100g requirement and embrace transparent labelling will not only appeal to increasingly health-conscious consumers—they will be eligible for export into jurisdictions that have banned iTFAs altogether. In this way, regulation is not a constraint—it is a gateway to global markets.

The Path Ahead: Enforcement, Education, and Equity

For these regulations to have teeth, NAFDAC must be given the resources and political autonomy to enforce them. That means inspections, not just guidelines. It means monitoring imports, testing products on shelves, and penalising infractions with consistency and impartiality.

But enforcement alone is not enough. A parallel investment in public education is necessary. Consumers need to understand what iTFAs are, how to read labels, and why reformulated products matter. Civil society and the health sector must work together to communicate not just the science, but the stakes.

Finally, attention must be paid to economic equity. Small and medium-sized enterprises (SMEs), especially in the informal sector, will need technical assistance to comply. Subsidised testing services, access to reformulation expertise, and phased implementation plans can ensure that public health progress does not come at the cost of livelihoods.

From Technical Regulation to National Commitment

The elimination of iTFAs from Nigeria’s food supply is not just a regulatory milestone. It is a statement of national priorities. It is a choice to invest in long-term public health over short-term commercial convenience. It is an opportunity to set a precedent not only for Africa but for the Global South, where food safety regulation has long lagged behind epidemiological necessity.

The law is in place. The science is clear. The need is urgent.

Now, the question before manufacturers, regulators, and consumers alike is this: will we follow through?

REFERENCES

Afshin A, Sur PJ, and Fay KA et al, “Health Effects of Dietary Risks in 195 Countries, 1990–2017: A Systematic Analysis for the Global Burden of Disease Study 2017,” Lancet 393:1958–72, DOI: 10.1016/S0140-6736(19)30041-8 (2019)

Bösch S, Westerman L, and Renshaw N, et al, Front Nutr 8: 645750, DOI: 10.3389/Fnut.2021.645750

Resolve To Save Lives, Implementing and Enforcing Trans Fat Elimination Policies: Case Studies

World Health Organization, Countdown to 2023: WHO Report on Global Trans Fat Elimination 2021, https://www.who.int/publications/i/item/9789240031876

World Health Organization, “Trans Fat,” (24 January 2024), https://www.who.int/news-room/fact-sheets/detail/trans-fat

World Health Organization, “The Top 10 Causes of Death,” (August 2024), https://www.who.int/news-room/fact-sheets/detail/the-top-10-causes-of-death (accessed 27 June 2025)

World Health Organization, “REPLACE: Trans Fat Free by 2023,” https://www.who.int/teams/nutrition-and-food-safety/replace-transfat.2021