Thailand Updates Food Labeling Requirements.
On July 19, 2024, Thailand’s Ministry of Public Health Notification No. 450 B.E.2567 (2024) came into effect after being published in the Government Gazette the day before. The notification introduces significant updates to the labeling requirements for prepackaged foods. This new regulation consolidates and updates Thailand’s rules for food labeling by repealing and replacing several previous notifications.
The notification’s key changes and their implications for food businesses are identified below.
1. Clarified “Best Before” Definition
The notification aligns the definition of “best before” with Codex standards. It now refers to the date marking the end of the period during which the food maintains its best quality under stated storage conditions. After this date, food quality may change, and the product cannot be marketed.
2. Updated Labeling Exceptions
Certain foods are exempt from labeling requirements, with the latest list including:
- Foods sold directly to consumers by manufacturers who can provide product information.
- Unprocessed foods.
- Some fresh foods not sold directly to consumers.
- Prepackaged foods produced and sold for immediate consumption in food service settings.
However, any of these exempt foods that have received food serial numbers must still have labels that comply with the notification.
3. Expiration Date and Best-Before Date Display
The notification provides clearer language for displaying the expiration date and best-before date. If specific wording is required by other notifications, it must be followed. English equivalents are now permitted alongside Thai text.
4. Warning Displays
Multiple applicable warnings can now be consolidated and displayed together, provided the complete message is included as specified.
5. Claims about Substances or Ingredients
New guidelines have been established for making claims about food additives and ingredients. Claims should be factual, not deceptive, and provably not false.
6. Label Placement and Design
Labels must be permanently affixed, proportionate to the packaging, and prominently displayed.
7. Display of Trademarks
Symbols related to trademarks or registered trademarks can be displayed with English symbols or text instead of Thai symbols or text.
8. Changes to Miscellaneous Requirements
The notification also includes changes to various labeling requirements:
- Additional information beyond the specified requirements is now allowed, provided it does not mislead consumers.
- For foods where net weight cannot be displayed, units (e.g., number of eggs) must be used instead.
- The ingredient list no longer needs to be in descending order by weight, as this is now only a recommendation.
- Shellfish, squid, and their products have been added to the Thai FDA’s list of allergens that need to be clearly identified when applicable.
- Food coloring additives no longer need to be specified as natural or synthetic.
- Food names no longer need to be displayed in a horizontally continuous manner.
Compliance Timeline
Food products labeled before July 19, 2024, can continue to be sold for up to two years from this date. However, businesses should begin transitioning to the new labeling requirements as soon as possible to ensure full compliance by July 19, 2026.
Recommendations for Food Businesses
This notification on labeling for prepackaged foods contains a number of notable updates and changes. In order to stay compliant with the latest regulations, companies with affected products should:
- Review current labeling practices against the new requirements.
- Update labeling designs and information to comply with the new regulations.
- Notify staff of the new requirements, particularly regarding allergen information and expiration date displays.
- Ensure any claims made about substances or ingredients meet the new guidelines.
Companies may also wish to adjust their labeling strategies to take advantage of the various flexibilities introduced by the new notification.
For further information, please contact:
Siradapat Ratanakorn, Tilleke & Gibbins
siradapat.r@tilleke.com
