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Singapore inviting comments on amendments to food regulations to delete standards of identity

On June 21, 2021, the Singapore Food Agency (SFA) announced that it is soliciting comments from the food industry and stakeholders to comment on the revision to remove the individual food standards (standards for food definition), which is scheduled to come into effect in April 2022.

Main Points

  • Out of 200 or more standards of identity* most of them are to be deleted, but about 10% of them are to be retained partially or fully.
  • For deleted food standards, it is possible to refer to available international standards (such as those of the Codex Alimentarius Commission) or the Singapore Standards.
  • In the future, a food classification system based on CODEX will set standards for the use of additives in foods that are not clearly defined.

*"Standards of identity" stipulates an essential composition (ingredients, etc.) and minimum quality criteria (contained components) for each food.

Background of the amendment and overview

Here are some excerpts from the announcement to provide a background and overview of this amendment.

Standards of identity in the Food Regulations (referring to those standards in Regulations 39 to 260) were developed during the 1970s to early 1990s.
"At present, there is a large variety of food products available in the market to meet different consumer needs and preferences . Many of these food products do not have a standard of identity prescribed in the Food Regulations, for example, breakfast cereals, 3-in-1 powdered beverages, frozen cooked meals etc. "
"SFA has, from time to time, received requests from the industry, to allow the import/manufacture and sale of food products which do not comply with the quality criteria in the Food Regulations, because of climate, environmental factors, production methods etc. Cases encountered include specific gravity / refractive index / iodine value for edible vegetable oils, milk solids content for milk, milk fat content for processed cheese, among others. The inability to meet quality criteria prescribed in the Food Regulations for these products does not mean that the products are unsafe for consumption. "
"As the food industry innovates to produce variations of a product (for e.g., sugar-free kaya, egg-free mayonnaise), having to conform to a fixed standard of identity would stifle their efforts at innovation. "
"For the standards of identity that are retained in the Food Regulations, the industry is required to ensure compliance with these standards." "For standards of identity that are deleted from the Food Regulations, industry can refer to available international standards (such as those of the Codex Alimentarius Commission) or the Singapore Standards."
"The proposed deletion of the standards of identity does not affect food safety. All food products imported, manufactured and sold in Singapore must comply with prevailing food safety provisions, such as use of food additives and maximum limits for incidental constituents, as well as relevant labelling requirements."
SFA has plans, in future, to develop a food category system (with associated food category descriptors), to provide clarity to the industry regarding the food additive provisions. . The food category system would be based on the Codex General Standard for Food Additives (CODEX STAN 192-1995). "

In addition, SFA has publicized "FREQUENTLY ASKED QUESTIONS" regarding this amendment. The following points must be watched carefully.

"The industry is responsible to ensure that the naming or product descriptor as labelled is accurate and sufficient to reflect the true nature and contents of the prepacked food product", "and to ensure that the food does not carry claims or suggestions that are false, misleading or deceptive, or are likely to create an erroneous impression regarding the value, merit or safety of the food."

Upcoming schedules

Comments will be invited until 5:00 p.m., 20 August 2021 through email. The list of standards of identity proposed to be deleted/retained can be found in Annex I.

Some excerpts (FLOUR, BAKERY AND CEREAL PRODUCTS)from ANNEX I(FLOUR, BAKERY AND CEREAL PRODUCTS)

Standard Regulation to be Deleted Regulation to be Retained
39 Flour or wheat flour 39  
40 Wholemeal, whole wheat or entire wheat flour 40  
40A Wholegrain   40A
41 Vital gluten flour 41  
・・・ 42-51  
52 Milk bread 52  
53 Labelling of bakery products Paragraph (1) of
Rg 53
Paragraph (2) of
Rg 53
54 Flour confectionery 54  
55 Pasta 55  
56 Labelling of pasta 56  

Some excerpts(39. Flour or wheat flour)from STANDARDS AND PARTICULAR LABELLING REQUIREMENTS FOR FOOD

  1. Flour or wheat flour shall be the fine, clean and sound product obtained in the commercial milling of sound and clean wheat grain and shall -
    1. have a moisture content of not more than 15%;
    2. have not less than 6% protein (total nitrogen x 5.7) calculated on a wet basis of 14% moisture content; and
    3. yield not more than 0.6% of ash calculated on a wet basis of 14% moisture content.
  2. Flour may contain the following:
    1. malted wheat flour;
    2. malted barley flour in an amount not exceeding 0.75% of the weight of the flour;
    3. harmless preparation of enzymes obtained from Aspergillus oryzae;
    4. ascorbic acid as bread improver;
    5. ammonium or potassium persulphate in an amount not exceeding 250 ppm (calculated by weight);
    6. ammonium chloride in an amount not exceeding 0.2% (calculated by weight); and
    7. acid calcium phosphate [calculated as CaH4(PO4)2] in an amount not exceeding 0.7%.
  3. Flour shall not be artificially bleached except by oxidizing changes brought about by means of an electrical process in which only ozone or oxides of nitrogen are produced, or by chlorine or chlorine dioxide, or by benzoyl peroxide. The residue of chlorine dioxide and benzoyl peroxide in the flour shall not exceed 50 ppm (calculated by weight).
  4. Flour intended for the manufacture of biscuit may contain sulphur dioxide not exceeding 200 ppm (calculated by weight).
  5. No flour, intended for sale as such, shall contain any emulsifier or stabiliser.

It would be easier to understand that the amendments to delete "standards of identity (standards for the definition of the food)" would be considered as equivalent to the deletion of "individual food standards in Japan’s 'Specifications and Standards for Food, Food Additives, Etc." and "Appended Table 3 (definition of individual processed food) in the "Food Labeling Standards" (and the "JAS Standards" which is the reference source)" when applied to the Japanese system.

-As for mandatory labeling for containers and packaging, there are cases where labeling standards are set for each food,
-As for permitted additives, there are cases where labeling standards are set for each food,
"Definitions of each food" is an important confirmation item for food export operations and also interesting.

A variety of food products has been developed to meet different consumer needs by technological innovation and development of new materials. We hope that this will provide an opportunity that not only the results of the invitation of opinions on this amendment but also trends of other countries in the future will be of interest to you.

September 2021