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Food Labelling Regulations and Challenges in ASEAN

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Food Labelling Regulations and Challenges in ASEAN

  1. 1. 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
  2. 2. EAS Strategic advice 11 April 2014 Introduction
  3. 3. EAS Strategic advice 11 April 2014 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
  4. 4. EAS Strategic advice 11 April 2014 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
  5. 5. EAS Strategic advice 11 April 2014 • 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 General requirements for labelling of food
  6. 6. EAS Strategic advice 11 April 2014 General requirements for labelling of food 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
  7. 7. EAS Strategic advice 11 April 2014 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.
  8. 8. EAS Strategic advice 11 April 2014 Nutrition Information Panel
  9. 9. EAS Strategic advice 11 April 2014 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
  10. 10. EAS Strategic advice 11 April 2014 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
  11. 11. EAS Strategic advice 11 April 2014 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 General requirements for labelling of food
  12. 12. EAS Strategic advice 11 April 2014 List of ingredients • In descending order of weight. • Containing edible oil/fat – common name of the vegetable, animal or marine oil or fat used • Format for declaration of food additive 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 General requirements for labelling of food
  13. 13. EAS Strategic advice 11 April 2014 Net content or drained weight • 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 General requirements for labelling of food
  14. 14. EAS Strategic advice 11 April 2014 Format of date marking • 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)” General requirements for labelling of food
  15. 15. EAS Strategic advice 11 April 2014 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
  16. 16. EAS Strategic advice 11 April 2014 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
  17. 17. EAS Strategic advice 11 April 2014 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
  18. 18. EAS Strategic advice 11 April 2014 Nutrition Information Panel
  19. 19. EAS Strategic advice 11 April 2014 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
  20. 20. EAS Strategic advice 11 April 2014 General requirements for labelling of food 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 • Format for declaration of food additive 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”
  21. 21. EAS Strategic advice 11 April 2014 General requirements for labelling of food Net content or drained weight • 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, or packer or distributor • For imported products, the name and address of local importer and/or distributor and the country of origin Format of date marking • 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)
  22. 22. EAS Strategic advice 11 April 2014 General requirements for labelling of food Registration/ serial number • Food products are subject to simple notification procedures
  23. 23. EAS Strategic advice 11 April 2014 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
  24. 24. EAS Strategic advice 11 April 2014 • 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
  25. 25. EAS Strategic advice 11 April 2014 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
  26. 26. EAS Strategic advice 11 April 2014 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
  27. 27. EAS Strategic advice 11 April 2014 Nutrition Information Panel
  28. 28. EAS Strategic advice 11 April 2014 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
  29. 29. EAS Strategic advice 11 April 2014 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.
  30. 30. EAS Strategic advice 11 April 2014 General requirements for labelling of food 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) • Format for declaration of food additive - 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)
  31. 31. EAS Strategic advice 11 April 2014 General requirements for labelling of food Net content or drained weight • 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, or packer or distributor • For imported products, the name and address of local importer and/or distributor and the country of origin Format of date marking • 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."
  32. 32. EAS Strategic advice 11 April 2014 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.
  33. 33. EAS Strategic advice 11 April 2014 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
  34. 34. EAS Strategic advice 11 April 2014 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
  35. 35. EAS Strategic advice 11 April 2014 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
  36. 36. EAS Strategic advice 11 April 2014 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
  37. 37. AFRIS. AsianFoodRegulationInformationService. We have the largest database of Asian food regulations in the world and it’s FREE to use. We publish a range of communication services, list a very large number of food events and online educational webinars and continue to grow our Digital Library. We look forward to hearing from you soon! www.asianfoodreg.com adrienna@asianfoodreg.com

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