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As a Girl Scout Cookie order form was shared around the office this year, there was a noticeable absence of a “no hydrogenated oils” banner from fan favorite Samoas, Tagalongs, and the ever-popular Thin Mints, which, together, make up 57% of Girl Scout Cookie sales. We couldn’t help but ponder how, in light of recent FDA action, next year’s batch would likely be different, if only in formulation.


Reformulation may not sound like a major disruption to the average consumer – that is, until a beloved brand – such as Girl Scouts® Thin Mints® – is affected.

(Remember Coca-Cola’s attempt to reformulate its classic beverage under the “New Coke” banner? Despite taste tests indicating consumer preference, the brand experienced major backlash from brand loyalists who were less than enthused when the familiar formulation was replaced.)

Because PHOs have been used to contribute to texture, shelf-life, and structure of applications, there’s a chance reformulation could produce a different consumer experience, and as New Coke illustrated, consumers don’t always like different, even if different means better (or, in this case, potentially healthier).

The Trans-free Trend

PHO-free chatter took over the airwaves in both food industry and mainstream media in November, when the FDA announced its preliminary determination that partially hydrogenated oils (PHOs), a leading contributor to trans fats in the American diets, are no longer generally recognized as safe (GRAS).

While trans-free reformulation isn’t new (for instance, most were eliminated from Girl Scout Cookies during a 2007 reformulation), the imminence of an FDA decision has motivated food industry manufacturers to reformulate the last of the PHO-reliant applications, particularly frozen pizzas, frostings, and baked goods – including Girl Scout Cookies.

While some food brands have elected to eliminate or reduce PHOs through reformulation, if the ingredient’s GRAS designation is repealed as expected, food and beverage brands will be required to comply if they want to keep their products in front of consumers.

According to the American Heart Association, “Eating trans fats increases your risk of developing heart disease and stroke. It’s also associated with a higher risk of developing type 2 diabetes.”

According to the Centers for Disease Control and Prevention, “reducing trans fat consumption by avoiding artificial trans fats could prevent 10,000-20,000 heart attacks and 3,000-7,000 coronary heart disease deaths each year in the United States.”

 “PHOs would be considered ‘food additives’ and could not be used in food unless authorized by regulation. If such a determination were made, the agency would provide adequate time for producers to reformulate products in order to minimize market disruption.” – FDA Press Release


  • Application reformulation: Applications most likely to require reformulation include donuts, cookies, microwave popcorn, frozen pizzas, baked goods, and canned frostings
  • Cost to the food industry: switching to healthier oils is estimated to cost between $12 billion and $14 billion over 20 years
  • Opportunity for oil ingredient suppliers: as food manufacturers seek replacement ingredients, opportunities may grow for producers of palm, canola, soybean, butter, and other PHO-free oil sources
  • Economic benefits: eliminating the use of PHOs is estimated to result in economic benefits between $117 billion and $242 billion over 20 years
  • Consumer experience: Because PHOs are relied on for specific texture and sensory qualities, reformulation may alter the consumer experience – for better or worse

Trend-minded Marketing

In partnership with IOI Loders Croklaan, a global leader in trans-free oils and shortenings, MarketPlace developed print and digital advertising highlighting IOI Loders Croklaan’s ability to partner with food manufacturers as they reformulate applications to be PHO-free.

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Nicole Hill assists clients in growing their businesses and brands by identifying opportunities, then developing and implementing goal-driven strategies.