On Oct. 22 The Post endorsed congressional action on legislation that would target imported oils -- coconut oil, palm oil and palm kernel oil -- for new food-labeling requirements. The editorial seemed to suggest that tropical oil producers, particularly from Indonesia, Malaysia and the Philippines, wish to prevent full disclosure to American consumers of the facts on tropical oils. This is not the case.

First, we do not object to comprehensive food labeling. What we object to is the fact that the labeling legislation singles out tropical oils while ignoring other, more widely used oils. According to the U.S. Department of Agriculture, palm, palm kernel and coconut oils make up only about 5 percent of the total oils and fats used in edible products. If the intention of the labeling legislation is to provide consumers with information on the fat content of the oils used in their foods, surely it would make more sense to label all oils in terms of their saturated, monounsaturated and polyunsaturated fat content. It is significant, moreover, that there are currently no laws pertaining to the labeling of other food products (such as meat and dairy products), which are almost certainly the major source of both cholesterol and saturated fats in the American diet.

When the major sources of cholesterol and saturated fats are ignored and a relatively insignificant source of saturated fats (tropical oils) is targeted for labeling, one cannot help suspecting that nonhealth considerations are the real reason behind the legislation. Indeed, U.S. Trade Representative Clayton Yeutter, in stating the administration's opposition to the legislation, has concluded that the oil labeling legislation "blatantly discriminates against imports and establishes a nontariff barrier."

Second, it is noteworthy that while all vegetable oils contain varying amounts of saturated fats, not all saturated fats affect blood plasma cholesterol adversely. Recent scientific research shows that the chemical makeup of some saturated fats -- including the medium chain triglycerides in coconut oil -- is such that their consumption does not lead to higher serum cholesterol levels or increased risk of heart disease.

Moreover, Richard Ronk, the acting director of the Center for Food and Safety and Applied Nutrition of the Food and Drug Administration, testified before Congress recently that although palm oil "contains some 50 percent saturated fatty acids, it does not behave as saturated oils." On the contrary, palm oil exhibited a distinct antithrombotic effect. Thus, tropical oils should not be simplistically labeled as saturated fats.

Third, other vegetable oils that are primarily unsaturated in their natural state often become highly saturated through a process known as hydrogenation, which tailors them for specific products. The labels mandated by the proposed legislation would fail to alert consumers to this fact.

We do not want the health of American consumers to be jeopardized by any harmful food products. We favor accurate and fair labeling. However, the evidence suggests that the food labeling measure endorsed by The Post would mislead consumers rather than inform them.

Within the context of protectionism we must also call attention to the adverse political and economic ramifications of the tropical oils legislation to the ASEAN region. Some 17 million Filipinos -- 30 percent of the population of the Philippines -- derive their livelihood from the coconut industry, and 13 percent of Malaysia's population is dependent on the export of palm oil. The impact of this protectionist legislation on our economies and peoples would be devastating.

Furthermore, the development and growth of the agricultural sector in each of our countries are crucial to the resolution of the insurgency problems that all of our countries have faced at some point. In the Philippines, for example, it has been demonstrated that whenever the coconut industry is in decline -- and more farmers and laborers fall below the poverty level -- the insurgency gains strength. Thus, the continued stability of the ASEAN economies is vital to ensure the protection of the important interests that the ASEAN nations and the United States share in the Pacific region.

-- Soesilo Soedarman, Albert Talalla and Emmanuel Pelaez The writers are the ambassadors of Indonesia, Malaysia and the Philippines, respectively.