Food Labelling Regulations and Challenges in ASEAN

EAS
Strategic advice 11 April 2014
EAS Strategic advice
Food Labelling Regulations and
Challenges in ASEAN
EAS Strategic Advice Pte Ltd – 3 Killiney Road, #07-04 Winsland House 1 Singapore 239519
Tel: (+65 6) 838 12 70 - Fax: (+65 6) 835 95 36 - Email: info@eas.asia - www.eas.asia
Evon Chan
Regional Regulatory Affairs Adviser
evonchan@eas.asia
Food & Hotel Asia
International Conference
11th of April 2014

EAS
Introduction

EAS
Indonesia
The Republic of Indonesia’s National Agency for Drug and Food
Control (NADFC) is responsible for ensuring that foods sold in
Indonesia are safe, and properly labelled.
Food labelling is strictly governed by:
• Government Regulation of the Republic of Indonesia No.69 Year of
1999 on Food Labelling and Advertisement
• Decree of Head of Drug and Food Administration Republic Of
Indonesia Number HK.03.1.23.11.11.09909 Year 2011 concerning
The Control of Claim on Processed Food Labeling and
Advertisement
• Decree of Head of Drug and Food Administration Republic Of
Indonesia Number HK.03.1.4.12.11.09955 Year of 2011 concerning
Registration of Processed Food

EAS
Language to be used
• Bahasa Indonesia
Product name
• Description which is sufficient to indicate the true nature of the product
List of ingredients
• In descending order of weight
• Mandatory listed by common names of ingredients and no abbreviations such
as Docosahexaenoic acid (DHA).
• Carry over additive: Other than by direct addition, an additive that present in a
food as a result of carry-over from a raw material or ingredient used to produce
the food
Examples:
Ingredients:….,Ketchup (contains preservative sodium benzoat)
Ingredients:….,Citrus flavor (contain coloring tartrazin)
Ingredients:…., Seasoning powder (flavor enhancer monosodium
glutamate (carry over))
General requirements for labelling of food

EAS
• Format for declaration of food additive
– Declare in the ingredient list by functional class
– Antioxidant, Sweetener, Preservative and Flavour Enhancer are require to
label the name of food additives.
– Colouring is require to label both name of food additive and INS number.
Net content or drained weight
• Solid food: milligram (mg), gram (g), kilogram (kg)
• Liquid food: milliliter (ml or mL), liter (l or L)
• Semi solid: milligram (mg), gram (g), kilogram (kg) or milliliter (ml or mL) or liter
(l or L)
Name and address of the manufacturer or distributor
• For locally manufactured products, the name and address of the manufacturer
or packer or distributor
• For imported products, the name and address of oversea manufacturer and the
name and address of local importer and/or distributor and the country of origin

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Format of date marking
• Date marking can be expressed as follows: “Best before (indicate
day/month/year or month/year)”
• For foods expected to keep for 3 months or less - the words “best before”
followed by the date in terms of the day, month and year.
• For foods expected to keep for more than 3 months – the date mark may be
given in the form “best before” followed by the date in terms of the month and
year.
Food registration code
• For locally manufactured products – BPOM RI MD
• For imported products – BPOM RI ML
Production code
• Can be batch code or date of production/manufacture

EAS
Nutrition Labelling
Inclusion of nutritional value information is required:
• Statement stating that it contains vitamin, mineral, or other
nutritional substances.
• Based on the provisions of prevailing legislation on food quality and
nutrition such as national fortification programme.

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Nutrition Information Panel

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Percentage of Indonesian RDA
Mandatory to declare percentage of Indonesian recommended dietary
allowances (RDA)
Formula for getting % AKG is:
Nutrient Value
Indonesian RDA
X 100 = % AKG

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Malaysia
Food products are regulated by the Food Safety and Quality
Division, Ministry of Health Malaysia.
Food Safety and Quality Division has provided the following
regulations related to food labelling and claims:
• Food Regulations 1985 Part IV – Labelling
• Guide to Nutrition, Labelling & Claims

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Language to be used
• For locally manufactured products, must be in Bahasa Malaysia
• For Imported products, can be in Bahasa Malaysia or English
Product name
• Description which is sufficient to indicate the true nature of the product

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List of ingredients
• In descending order of weight.
• Containing edible oil/fat – common name of the vegetable, animal or marine oil
or fat used
Examples:
Contains permitted (functional class of food additive) such as colouring,
preservative, antioxidant, etc
Contains (name of the additive) as permitted flavour enhancer such as
monosodium glutamate
Contains (class name of the food conditioner) as permitted food conditioner
such as emulsifier, stabiliser, acidity regulators, etc

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• Letter height for the net weight statement must be the same
Food registration code
• Food products are not subject to pre-marketing approval
Name and address of the manufacturer or distributor
• For locally manufactured products, the name and address of the
manufacturer or packer or distributor
• For imported products, the name and address of oversea manufacturer
and the name and address of local importer and/or distributor and the
country of origin

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• Foods requiring date marking (e.g. chocolate, biscuit, bread, etc)
• Date marking shall be shown in one of the following forms:
“EXPIRY DATE or EXP DATE (indicate day/month/year or month/year)”
“USE BY (indicate day/month/year or month/year)”
“CONSUME BY (indicate day/month/year or month/year)”
“BEST BEFORE (indicate day/month/year or month/year)”

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Nutrition Labelling
Foods requiring nutrition labelling
• Foods that are frequently consumed and in significant amounts,
and are important to the community (e.g. prepared cereal food and
bread, flour confection)
• Foods that have been fortified, enriched, vitaminised,
supplemented or strengthened with specific vitamins or minerals
• Food that make nutrition claims
• Special purpose food: infant formula, follow-up formula, canned
food for infants and young children and cereal-based food for
infants and young children

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Mandatory Nutrients
Solid food
• Energy, carbohydrate, protein,
fat
Liquid food
• Energy, carbohydrate,
protein, fat
• Total sugar (mandatory
for ready-to-drink
beverages only)
If the package contains
only a single portion
• Column for nutrient listing
• Column for per package/
per serving

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Optional Nutrients
Vitamins and minerals
• Only those listed in the NRV can be declared on a label (e.g. vitamin A,
vitamin C, iron, zinc, etc)
• Others (prior written approval from “Director”)
• Present in significant amounts (5% of NRV per serving)
Dietary fibre, cholesterol, sodium
• Can be declared on the label
Fatty acid
• Where a claim is made regarding the amount or type of FA, the amount of
all the four main types of FA shall also be declared

EAS
Thailand
The Food and Drug Administration (FDA) of the Ministry of
Public Health (MOPH) are responsible for food control and
regulations.
The regulatory notifications that cover food labelling include:
• Notification of Ministry of Public Health (No.194) B.E 2543 (200) Re
Labels
• Notification of Ministry of Public Health (No.182) B.E. 2541(1998) Re
Nutrition Labelling
• Notification of Ministry of Public Health (No.305) B.E 2550 Re Labelling
Requirement on Certain Processed Foods

EAS
Language to be used
• Thai language however foreign language may be included
Product name
• The product name must not be misleading, or offensive to Thai language and
culture
List of ingredients
• Main compositions shall be expressed in percentage of approximated weight
and in descending order
Example:
Ingredients: dried potato 50%, vegetable oil 33%, salt 2.5%, citric acid,
natural flavour
Examples:
“Utilizing preservatives”
“Utilize of (name of flavour enhancer) for flavour enhancer”
“Utilize of (name of sweetener) as food artificial sweetener”
“Natural colouring” or “artificial colouring”
“Natural flavour” or “nature-identical flavour” or “artificial flavour”

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• Solid food: net weight
• Liquid food: net volume
• Semi solid: net weight or net volume
Name and address of the manufacturer or packer or distributor
• For locally manufactured products, the name and address of the manufacturer,
• For imported products, the name and address of local importer and/or
distributor and the country of origin
• Expiry date: To indicate “Expire” or “Consume Before” DD/MM/YY or MM/YY
for food that cannot be store for more than 90 days
• Date of manufacture: To indicate “produce” DD/MM/YY or MM/YY
for food that cannot be store for more than 90 days)

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Registration/ serial number
• Food products are subject to simple notification procedures

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Nutrition Labelling
Nutrition labelling is mandatory for the following foods
• Foods with nutrition claims
• Foods which utilize food value in sale promotion
• Food targeted towards specific groups of consumers
• Other foods as determined by the Food and Drug Administration

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• Mandatory front of pack labelling for snack foods (e.g. fried or baked
potato chips, crackers, etc)
• To demonstrate amount of energy, sugar, fat and sodium
• To present in the front of the label in a conspicuous and clear
position
Front of Pack Labelling

EAS
Reference serving size for the following food groups
• Dairy products
• Beverages
• Snack food and desserts
• Semi-processed foods
• Bakery products
• Cereals and grain products
• Miscellaneous
Reference Serving Size

EAS
Type of food One reference serving
Dairy products
Yoghurt
Cream chess and chess spread
150 g
30 g
Beverages
Fruit juice
Tea, coffee and other drinks
200 ml
200 ml
Snack food and desserts
Chocolate
Crispy snack
40 g
30 g
Semi-processed food
Noodle
Vermicelli
50 g
50 g
Bakery products
Bread
Cookies
50 g
30 g
Cereals and grain products
Pasta (macaroni, spaghetti and others) 55 g (raw)
140 g (cooked)
Miscellaneous
Maple syrup
Salad sauce
30 ml
30 g
Reference Serving Size

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Percentage of Thai RDI
Mandatory to declare percentage of Thai recommended daily intakes (Thai
RDI)
Formula for getting % Thai RDI is:
Nutrient Value
Thai RDI
X 100 = % Thai RDI

EAS
Singapore
The import and sale of food in Singapore is governed by the Sale of
Food Act and the Food Regulations, administrated by the Agri-
Food & Veterinary Authority (AVA).
The Singapore Food Regulations require all prepacked food
products for sale in Singapore to be labelled according to the
requirements specified.
A Guide to Food Labelling and Advertisement also provides food
importers, manufacturers, and retailers with a better understanding
of the labelling requirements of the Food Regulations.

EAS
Language to be used
• English, additional description in any language is allowed provided that such
addition is not contrary to the English statement.
Product name
• A common name or a description which is sufficient to indicate the true nature
of the food product.
List of ingredients
• In descending order of weight.
• Compound ingredients which comprise more than one constituent, the
constituents should be declared in descending order.
Example:
soy sauce (water, soybean, black bean, salt, sugar)
- International Numbering System (INS) number or E number can be used
for declaration of food additives
Example:
“tartrazine”, or “colour (102) or “colour (FD&C Yellow #5)

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• Solid food: net weight
• Liquid food: net volume
• Semi solid: net weight or net volume
Name and address of the manufacturer or packer or distributor
• For locally manufactured products, the name and address of the manufacturer,
• For imported products, the name and address of local importer and/or
distributor and the country of origin
• Expiry date should be qualified by words like "USE BY", "SELL BY", "EXPIRY
DATE", "BEST BEFORE" or other words of similar meaning.
• The validity of the date mark is dependent on its storage, the storage direction
must be stated on the label or package.
Example: "BEST BEFORE : 31 Dec 2010. Store in a cool, dry place."

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Nutrition Labelling
Nutrition labelling is required when nutrition claims, or permitted
health claims are made.
• The information to be
declared in the panel
includes the energy,
protein, fat and
carbohydrate contents of
the food.
• Declaration of other
nutrients is mandatory
when such nutrients are
the subject of a nutrition
claim.

EAS
Summary
General labeling information requirements are similar
across ASEAN
• Product name
• List of ingredient in descending order of weight
• Net content
• Name and address of manufacturer or importer or distributor
• Product expiry date
Difference lies with the details!
• Different font size, layout and format of nutrition information panel
• Different format of declaration for food additives
• Additional country specific requirements e.g. front-of-pack labelling
for snack food in Thailand
• Others GMO, allergen, and Halal labelling

EAS
Conclusion and Recommendation
Companies wish to develop common label that can
be use in multiple markets
• Difficult to design a product label that will accommodate all the
mandatory requirements in multiple ASEAN countries,
particularly for the smaller labels
Possibility to develop harmonised food labelling
requirement across ASEAN region?
• Suggestion: refer to international standards such as Codex
general standard for the labelling of prepackaged food and
Codex guidelines on nutritional labelling

EAS
Thank you !
Evon Chan
EAS Asia
EAS Strategic advice on nutritional products
EAS Europe
50 Rue de l’Association
1000 Brussels
Belgium
Tel: (+32 2) 218 14 70
Email: info@eas.eu
www.eas.eu
EAS Asia
3 Killiney Road,
#07-04 Winsland House I
Singapore 239519
Tel: (+65 6) 838 12 70
Email: info@eas.asia
www.eas.asia
EAS Latin America
Lola Mora 421, 5th floor - No. 502
1107 Buenos Aires
Argentina
Tel: (+54 11) 52 45 84 95
Email: info@eas-americalatina.com
www.eas-americalatina.com

EAS
Q & A
EAS Strategic advice on nutritional products
EAS Europe
50 Rue de l’Association
1000 Brussels
Belgium
Tel: (+32 2) 218 14 70
Email: info@eas.eu
www.eas.eu
EAS Asia
3 Killiney Road,
#07-04 Winsland House I
Singapore 239519
Tel: (+65 6) 838 12 70
Email: info@eas.asia
www.eas.asia
EAS Latin America
Lola Mora 421, 5th floor - No. 502
1107 Buenos Aires
Argentina
Tel: (+54 11) 52 45 84 95
Email: info@eas-americalatina.com
www.eas-americalatina.com

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Food Labelling Regulations and Challenges in ASEAN

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