A Guide To Food Labelling And Advertisements - SFA

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A Guide toFood Labelling and AdvertisementsA publication of theSingapore Food Agency (SFA)First published Feb 2010.Amendments Oct 2011, Oct 2013, Jul 2014, Jan 2015, Jul 2015, Mar 2016, Aug 2018, Feb2019, Apr 2019, Sep 2019, Jan 2020, Apr 20201

ContentsIntroduction . 3Overview . 4(A)General Labelling Requirements . 7(a) Name or description of food . 8(b) Statement of ingredients . 10(c) Foods and ingredients known to cause hypersensitivity . 15(d) Net quantity of food in package . 22(e) Name and address of local food business and country of origin26(B)Exemptions. 29(C)Additional Labelling Requirements . 31(a) Date-marking of expiry date . 31(b) Serving suggestions . 35(c) Foods containing sweetening agents . 35(d) Special purpose foods. 37(e) Nutrition labelling . 40(f) Foods claimed to be source of energy or protein . 43(g) Specific labelling requirements for certain food categories . 44(h) Advisory statements . 45(D)Prohibited Claims on Food Labels and Advertisements . 46(E)Use of Nutrition Claims and Health Claims . 47(a) Nutrition claims . 47(b) Health claims . 50(i) Nutrient function claims and other function claims . 50(ii) Nutrient specific diet-related health claims . 68(F)Application for new health claims . 73(G)Methods of Analysis . 74(H)Other claims . 75(a) Organic . 75(b) Gluten-free . 76(c) Raised without the use of antibiotics . 76Contacts . 80Appendix I: Types of health claims as defined under the “CodexGuidelines for Use of Nutrition and Health Claims” . 82Appendix II: Checklist for food labels and advertisements . 842

IntroductionThis Guidebook aims to provide food importers, distributors,manufacturers, producers, packers and retailers habetterunderstanding of the labelling requirements of the FoodRegulations, as well as the permitted and prohibited claims foruse in food labels and advertisements.This Guidebook includes a checklist to assist food businessoperators to self-check their food labels and peratorsareresponsible to ensure that their food products comply with thesafety, specification standards and the labelling requirementsstipulated under the Food Regulations.In addition, food business operators are to refer to the Sale ofFood Act and the Food Regulations for the actual legal textwhere necessary. The legislation can be downloaded from thefollowing website: https://sso.agc.gov.sg.Please note that the information and the checklist provided inthe material do not serve as any form of certification orapproval of food labels and advertisements.3

OverviewThe Singapore Food Agency (SFA) administers the Sale ofFood Act and the Singapore Food Regulations to ensure thatfood made available for sale in Singapore are safe forconsumption to safeguard public health.The food labelling requirements under the Act and Regulationsare primarily to support food safety regime. SFA takesreference from the international food standards setting body,the Codex Alimentarius Commission1 (Codex), when reviewingthe labelling requirements for Singapore.Food label is one of the most important and direct means forsellers to communicate product information to buyers. It is oneof the primary means by which consumers differentiatebetween individual foods and brands to make informed foodchoices at point of sale, before consuming. It also helpsconsumers to identify a food product in the case of food safetyincident.1The Codex Alimentarius Commission is the international food standards body established by theFood and Agricultural Organisation of the United Nations and the World Health Organisation.4

All prepacked food products for sale in Singapore must belabelled according to the general labelling requirements of theSingapore Food Regulations. This includes prepacked food thatare offered as a prize, reward or sample for the purpose ofadvertising.Some pre-packed food products (e.g. special purpose foods,foods with nutrition or health claims, etc.) are required to meetadditional labelling requirements.For the purpose of this Guide, prepacked food product refersto any food product that is packed in a wrapper or container inadvance, before being put up for sale.Food label refers to any tag, brand, mark, or statement inwords, pictures or diagrams, that is on, attached to, used,displayed in connection with or accompanying any food orpackage containing food. The label provides consumers withbasic information of product such as the food product’s source,nature, contents (e.g. ingredients, allergens), quantity andquality.5

We would like to remind industry members that it is an offenceto sell prepacked foods without proper labelling or to makefalse or misleading claims for food products. The penalties fornon-compliance are stated under Section 49 of the Sale ofFood Act and regulation 261 of the Food Regulations; relevantsections are quoted below:Section 49 of the Sale of Food ActAny person who is guilty of an offence under this Act forwhich no penalty is expressly provided shall be liable onconviction to a fine not exceeding 5,000 and, in the caseof a second or subsequent conviction, to a fine notexceeding 10,000 or to imprisonment for a term notexceeding 3 months or to both.Regulation 261 of the Food RegulationsAny person who contravenes or fails to comply with anyof the provisions of these Regulations shall be guilty of anoffence and shall be liable on conviction to a fine notexceeding 1,000 and in the case of a second orsubsequent conviction to a fine not exceeding 2,000.6

(A) General Labelling RequirementsAll prepacked food for sale in Singapore must be labelled withthe following mandatory information in English.(a)Name or description of food(b)Statement of ingredients(c)Net quantity of food in package and(d)Name and address of local food business, and(e)Country of origin (only for imported food products)The Food Regulations do not specify the placing of themandatory labelling information. However, the mandatorylabelling information must be legible and should not be in anyway hidden, obscured by any other written or pictorial matter.The mandatory labelling information would also apply to prepacked foods that are intended for human consumption andoffered as a prize, reward or sample for the purpose ofadvertising.The use of sticker labels to incorporate the mandatorylabelling information in English on the labels of your foodproduct is acceptable if the sticker label used is firmly attachedon the product at all times, and it does not cover other essentialinformation required under the Food Regulations.7

The information made available on the sticker labels should notcontradict with those declared on the original label. Please notethat tampering of date marking (i.e. expiry date) declared on theoriginal label, is prohibited under the Food Regulations.(a) Name or description of foodA common name or description of the food provides consumersquick reference to the nature of the food they intend topurchase. It also helps to identify the food, especially in theevent of a food safety incident. Refer to “Part IV – Standardsand Particular Labelling Requirements for Food” of the FoodRegulations to ensure that the terms used for the commonname or the descriptions comply with the requirement.Food business operators must ensure that name or descriptionof the food is an accurate representation of its true nature andnot be presented in a manner that is false, misleading ordeceptive; or is likely to create an erroneous impressionregarding its product content.In particular, the name or description of the food must bedeclared in printed letter not less than 1.5 mm in height,based on the lowercase of the printed letter.8

Tips to avoid misleading common names: The common name or descriptor should not be misleading orconfusing to consumers. A “coined”, “fanciful”, “brand” name or“trade mark” used, should be accompanied by the name ordescriptor of the food. Abbreviations, including initials, should not be used as part of theproduct descriptor if they potentially lead to deception. Do not use words that do not reflect the actual composition of foodcontents (e.g. Products labelled as "Fruit biscuits" should thereforecontain fruit components, whether in the form of fruit pulp, fruitjuice or fruit flavouring.) Improperly suggesting a place of origin (e.g. “Singapore noodles”on noodles which was not made in Singapore) Resembling, directly or phonetically, the name of another productfor which it is an imitation or substitute (e.g. “bird’s nest drink” onan imitation bird’s nest product) False differentiation is not allowed (e.g. “Cholesterol freemargarine” on margarine as all margarines are cholesterol free)9

(b) Statement of ingredientsLabels of pre-packed foods must bear a clear statement ofingredients that specifies the complete list of ingredients andadditives used in the food. A statement of ingredients isrequired for prepacked food products containing two or moreingredients.Unless the quantity or proportion of each individual ingredient isspecified, all the ingredients and additives used must be listedin descending order of the proportions by weight in which theyare present (i.e. based the ingoing weight of the ingredient atpoint of manufacture, the ingredient that weighs the most mustbe listed first and the ingredient which weighs the least must belisted last).The exact identity or the permitted generic terms 2 of theingredients and additives should be declared. InternationalNumbering System (INS) number or E number can be used fordeclaration of food additives. It is not a requirement to state thefunctional class of the additives used. It is also not mandatoryto state that a food contains water.2Under regulation 5(4)(b) of the Food Regulations, the name and description of ingredientsshould indicate their true nature. Only generic terms listed in the First Schedule of the FoodRegulations can be used for the respective food groups.10

The use of the synthetic colouring matter, tartrazine must bedisclosed under the statement of ingredients as either"tartrazine", or "colour (102)" or "colour (FD&C Yellow #5)" orsimilar words.For compound ingredients which comprise more than oneconstituent, the constituents should be declared in descendingorder. For example, “soy sauce (soybean, black bean, salt,sugar)”.In particular, the statement of ingredients for the food must bedeclared in printed letters not less than 1.5 mm in height,based on the lowercase of the printed letter.Declaration of processing aidProcessing aids, as stipulated in the Codex Procedural Manual,are exempted from the declaration in the list of ingredients. “Processing aid means any substance or material, notincluding apparatus or utensils, and not consumed as afood ingredient by itself, intentionally used in the processingof raw materials, foods or its ingredients to fulfil a certaintechnological purpose during treatment or processing andwhich may result in the non-intentional but unavoidablepresence of residues or derivatives in the final product.”11

This approach is aligned with the recommendations of Codexon the declaration of processing aids in the statement ofingredients, as laid out in the following standards: Codex General Standard for Labelling of Food AdditivesWhen Sold as Such (CXS107-1981) and Codex General Standard for the Labelling of PrepackagedFood (CXS 1-1985)Food businesses must be able to justify the presence ofundeclared processing aids in the final food product, as andwhen necessary.12

How to declare statement of ingredientsThe ingredients listing may start with a heading that includesthe words "Ingredients".STEPSDESCRIPTION1List down all the ingredients used in the food product intheir exact identities* and arrange them in descending orderby weight, i.e. the ingredient that weighs the most must belisted first, while the ingredient that weighs the least must belisted last.2Identify the compound ingredients used in the foodproduct, and find out the constituents of the compoundingredients by checking: with your suppliers, or the documents provided by suppliers (e.g. productspecification sheets).List out these constituents in descending order by weight inparenthesis next to the compound ingredients. E.g. “Batter(cornstarch, wheat flour, salt, sodium bicarbonate)”.3Find out whether there are any simplified terms for theingredients.SeeRegulations forthetheFirstlistofSchedulepermittedofthe Foodgenericterms.Otherwise, all ingredients must be listed in their exactidentities*. For food additives, besides declaring their exactchemical names, you can use the International NumberingSystem (INS) or E numbers.13

4Check the presence of any ingredients or additives thatare known to cause hypersensitivity and label their exactidentities.For more information, see the section on Foods &Ingredients Known to Cause Hypersensitivity.* Exact identity refers to the specific name or description indicating the true nature of theingredient.Options for declaring statement of ingredientsFood companies may choose to use one of the followingoptions based on the company’s needs.Option 1: Declaration the full exact identities of ingredients andadditivesFull cream milk, wheat flour, egg powder, vegetablemargarine [Partially hydrogenated palm oil, salt, mono- anddiglycerides of fatty acids, polyglycerol esters of fatty acids,butylated hydroxyanisole, butylated hydroxytoluene, butterflavor], sugar, salt, sodium bicarbonate, tartaric acid14

Option 2: Declaration using a combination of permitted genericterms, INS numbers and full exact identitiesFull cream milk, wheat flour, egg powder, vegetablemargarine[Partially hydrogenatedvegetable oil, salt,emulsifiers (INS 471 and INS 475), butylated hydroxyanisole(INS 320), butylated hydroxytoluene (INS 321), flavouring],sugar, salt, sodium bicarbonate (INS 500ii), tartaric acid(INS 334)Option 3: Declaration by replacing the exact identities ofingredients and additives with permitted generic terms and INSnumbers, respectivelyFull cream milk, wheat flour, egg powder, vegetablemargarine(partially hydrogenatedvegetableoil,salt,emulsifiers, INS 320, INS 321, flavouring), sugar, salt, INS500ii, INS 334(c) Foods and ingredients known to cause hypersensitivityFoods and ingredients that are known to cause hypersensitivityto individuals include those that causes allergenic reactions (i.e.allergens). As allergenic reactions like anaphylaxis could be lifethreatening, it is important that the addition of these ingredientsis clearly declared on the food label.15

What to declareThe following foods and ingredients are known to causehypersensitivity and must be declared on food labels:(i)Cerealscontaining glutenThis group includes wheat, rye, barley,oats, spelt or their hybridised strains andtheir products.(ii)Crustacean andcrustaceanproductsThis group includes crayfish, prawns,shrimps, lobsters, crabs and their products.(iii)Eggs and eggproductsThis group includes eggs from laying hensas well as eggs from duck, turkey, quail,goose, gull, guinea fowl and their products.(iv)Fish and fishproductsThis group also includes molluscs such asoysters, clams, scallops and their products.(v)Peanuts,soybeans andtheir productsPeanuts may be declared using similarterms such as “groundnuts”. Terms suchas “soya” or “soy” can be used forsoybeans.(vi)Milk and milkproducts(includinglactose)This group includes milk from cows,buffaloes, or goats and their products.(vii) Tree nuts and nut This group includes almond, hazelnut,productswalnut, cashew nut, pecan nut, Brazil nut,pistachio nut, macadamia nut and theirproducts.(viii) Sulphites inconcentrates of10mg/kg or moreFood products that have sulphur dioxideand/or sulphites directly added and/orcarried over from food ingredients at a totalconcentration of 10mg/kg or more(calculated in terms of total sulphurdioxide).16

How to declare Foods & Ingredients Known to CauseHypersensitivityThere are 2 ways to declare foods and ingredients known tocause hypersensitivity:1. Using statement of ingredients2. Using “contain” statementOption 1: Declaration using statement of ingredientsAll food ingredients and additives used in food products,including those listed as food ingredients and additivescausing hypersensitivity must be declared clearly in thestatements of ingredients in descending order by weight.Allergens should not be listed using generic terms. dients, the compositions in descending order by weight,should be declared in parenthesis next to the compoundingredients. For example, “Batter (cornstarch, wheat flour,salt, sodium bicarbonate)”17

Option 2: Declaration using “Contains” statementWhen a “Contains” statement is used, it should appearimmediately after the statement of ingredients. However,information provided in the “Contains” statement should notcontradict that declared in the statement of ingredients. Allfood ingredients and additives used in foods must bedeclared clearly in the statement of ingredients. The“Contains” statement should not be used to declare additionalfood ingredients/additives which are not declared in thestatement of ingredients. Allergenic ingredients which areunintentionally introduced into foods such as throughcontamination or carried-over from such ingredients duringmanufacturing, transportation, storage or any other meansmust not be declared in the “Contains” statement.18

Tips for declaration of allergensIf the foodOption 1:Option 2:allergen is .Declaration usingDeclaration usingstatement of ingredients“Contains” statementDeclare all ingredients inAll ingredients must beingredientdescending order bydeclared in theor a foodweight under thestatement ofadditivestatement of ingredients.ingredients. If genericGeneric terms should beterms are used in theExamples:avoided when declaringstatement ofPeanut oil,food allergens. Foringredients, the foodlecithininstance, generic termsallergens can besuch as “vegetable oil”declared in theand “emulsifier” should“Contains” statementnot be used for peanutas follows:(i) a foodoil and lecithinrespectively. Refer to (iii) Contains:peanut, eggfor proper declaration.(ii) anConstituents ofIf wheat flour isingredientcompound ingredientsdeclared as “flour” inof amust be declared inthe statement ofcompoundparenthesis next to theingredients, theingredientcompound ingredients.“Contains” statementcan be used as follows:Example:Example:A cake made of Batter (cornstarch, wheat Contains: wheatbatterflour, salt, sodium19

containingbicarbonate)wheat flourDescription must beA “Contains” statementingredientprovided in order tocan be provided toor foodhighlight ingredients thathighlight the source ofadditiveare derived fromallergens for peanut oil,derivedallergenic sources.lecithin, sodium(iii) a foodfromcaseinate, as follows:allergenicExamples:sourcesPeanut oil, lecithin (eggContains: peanut, egg,product), sodiummilkExamples:caseinate (from milk)Peanut oil,lecithin, sodiumcaseinate20

Special considerations To be in line with international practice, when cereals, wheyand nuts are used as distillates for alcoholic beverages, orfish gelatine or isinglass3 as fining/clarifying agents in beerand wine, these ingredients are not required to be declaredon the label. Food business operators must bear fullresponsibility for ensuring that the information they choosenot to declare does not, in fact, cause harm to consumers. The use of disclaimer statements such as “may contain” todeclare the presence of ingredients known to causehypersensitivity, when manufacturers cannot discount thepossibility of cross contamination in their food products, isnot encouraged. This may unnecessarily restrict consumerchoice and undermine valid warnings. Food business operators whose products carry the “maycontain” statement may be required to provide justification ifconsumers raise any concerns on potential food allergensin the products.3Isinglass is semi-transparent whitish gelatine prepared from the swim bladders of sturgeon andcertain other fishes and is used as a clarifying agent in beer and wine.21

(d) Net quantity of food in packageThe net quantity of the food present in the package is requiredto be declared on the label. It must be in absolute values, andnot expressed over a range of values.For example,Correct manner of declaration Net Weight: 490gWrong manner of declarationNet Weight: 500g /- 10gThe net weight of a prepacked food product containing forexample 20 mini sachets of 25g each may be declared as "Netweight: 20 x 25g".The net quantity may be derived using the Minimum QuantitySystem or the Average Quantity System.The net quantity of the food present in the package can beexpressed in terms of:(i) Volumetric measure (e.g. millilitres, litres) for liquid foodproducts(ii) Net weight (e.g. grams, kilograms) for solid food productsand accompanied with the word, “net”(iii) Either volumetric measure or net weight for semisolid/viscous products (e.g. tomato paste, yoghurt).22

Food packed in a liquid medium 4 must be labelled with both“net weight” and “drained weight” declared.Examples of products that require drained weight declaration:(i) Products with liquid packing medium which is drained awayprior to consumption of the product. The products includecanned seafood in brine e.g. abalone, pacific clams, tuna,crabmeat and canned vegetables in brine such as buttonmushrooms, whole corn kernels, chickpeas, gingko nuts inwater.(ii) Preserved/pickled products in liquid medium with salt,vinegar or sugar. The liquid medium is neither drainedaway nor consumed. The products include pickled preserved ginger, salted plums.(iii) Canned fruit and vegetable packed in juices or sugarsyrups. For this instance, juice content is not a decisivefactor to purchase.The products include cannedrambutans in pineapple juice, peaches, pears, lychees,longans in light syrup, fruit cocktail in syrup.4Liquid medium is defined as water, aqueous solutions of sugar and salt, fruit and vegetablejuices in canned fruits and vegetables only, or vinegar, either singly or in combination.23

Examples of products that do not require drained weightdeclaration:(i) Products for drinking which contain solid bits. For suchproducts, the liquid portion forms the most part of theproduct. These products include grass jelly drink, fruit juicewith aloe vera bits, juice drink with nata de coco, birds’ nestflavoured drink with jelly, bottled hashima dessert.(ii) Products containing solid food in gravy, paste or saucewhich are meant to be consumed as a dish. The productsinclude shark’s fin soup, peanut soup, curry chicken,sardines and baked beans in tomato sauce, fried gluten insoy sauce, braised peanuts and vegetarian mock meat insoy sauce, kimchi and sauerkraut.(iii) Products containing solid food in oil predominantly. Theproducts include canned seafood such as tuna, anchoviesin vegetable oil, sundried tomato in oil and fermentedbeancurd.(iv) Products containing solid food with small amount of waterdue to syneresis. The products include beancurd and jelly.Note: The above examples are not exhaustive and are for illustrationonly. Companies may approach SFA on the declaration of “drainedweight” for specific products.24

For frozen food that has been glazed with ice, both the “grossweight” and “net weight” shall be declared. The net weightdeclared for such product must exclude the weight of the iceglazing. For example, the net content declaration of glazedsutchi fish fillet will be declared as “Gross weight of fish: 1000g;Net weight of fish: 800g”.In particular, the net quantity of the food must be declared inprinted letter not less than 1.5 mm in height, based on thelowercase of the printed letter.25

(e)Name and address of local food business and countryof originTo facilitate food traceability during a food safety recall/crisis, itis mandatory for prepacked food products to be labelled withthe following information:(i) Name and address of the local food business(ii) Country of origin of food product (only for imported foodproducts)(i) Name and address of the local food businessFor imported food products, the label must indicate the nameand address of the local importer, distributor or agent.For food products of local origin, labels must include the nameand address of the local manufacturer/producer, packer orvendor.Replacing the name and address with other contact informationfor example, telephone/fax numbers, websites, emails and postoffice addresses etc are not acceptable.(ii) Country of origin of foodLabels on imported food products must indicate the country oforigin of the food. The name of a city, town or province alone is26

not acceptable. The use of abbreviations is not recommended ifthe abbreviations would result in confusion to consumers.Declaration on country of origin is not mandatory for foodproducts manufactured/produced locally. This is becauselocally manufactured food products are manufactured by foodestablishments licensed by SFA and these food manufacturersmust inform SFA of the manufacture of the food. As thisinformation is enough to enable traceability, it is not mandatoryfor the country of origin (i.e. Singapore) to be declared on thepackaging. Nonetheless, local manufacturers may choose toinclude it on a voluntary basis.In line with the Codex, the ‘country of origin’ refers to the lastprocessing place of the food. In Singapore’s context, it wouldbe the country where the handling of the food last took place(i.e. when food was packed into primary packaging).Products that are produced in Country A and packed inSingapore, may be labelled as “Product of Country A. Packedin Singapore”, or just “Packed in Singapore”. To qualify for theuse of the terms “Product of Singapore” or “Made in Singapore”,the product should undergo manufacturing processes tochange the nature of the food in premises licensed by SFA.27

Tips on how to declareDescription ofManner of declarationmanufacturing scenarioThe product is farmed andprocessed/packed inSingapore. “FarmedandproducedinSingapore” “Singapore produce” “Product of Singapore”The product should “Product of Singapore”undergo significant “Made in Singapore”manufacturing process,which usually changes thenature of the originalproduct, in a licensedpremise in Singapore.The above are suggested words only and it is for the foodbusinesses to ensure accuracy when using these declarations.Some Singapore food business operators may develop aformulation/recipe of a product or buy over its ownership butchoose to manufacture the product overseas. To indicate therelation of the product with national identity, the products maybe labelled with words like “A Singapore brand” / “Productowned by Singapore” / “Singapore formula”, as appropriate.However, the actual country of origin (i.e. last processing place)28

for the food must be clearly declared so that it would not hindertraceability of the product, and consumers are not misled bysuch declaration.(B) ExemptionsGeneral labelling requirements do not apply under theseconditions. However, the same information must be provided tothe buyer of the product when requested, through means likevoluntary labelling, documentation, electronic platform or verbalcommunication. Food packed in non-retail containers (i.e. for supply tofood manufacturers or food services for further use). Foodbusiness operators may wish to include information of thefood on the non-retail containers on a voluntary basis. Non-prepacked (loose) foods, i.e. food which is weighed,counted or measured in the presence of the purchaserand food which is loosely packed in the retailer’s premisesare exempted from these general labelling requirements. Foods sold loose in retail outlets, for example cold meatsor cheeses sold from delicatessen counter, bread sold inbakery shops, meat sold at butchers, pick and mixconfectionery. Foods which are not sold pre-packed, such as mealsserved in a restaurant and food from a takeaway.29

Intoxicating liquors (liquor containing more than 0.5% (v/v)alcohol at 20 C) are not required to carry a statement ofingredients on their labels.Bread which is sold loosely packed in retailer’s premises is notrequired to carry a statement of ingredients as the foodbusines

operators to self-check their food labels and advertisements before sale/publication. Food business operators are responsible to ensure that their food products comply with the safety, specification standards and the labelling requirements stipulated under the Food Regulations. In addition, food business operators are to refer to the Sale of .

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