Food Compliance
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Labeling Requirements in Malaysia
Oct 23, 2023
Lennie Tao
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CONTENTS

Note: the content of this Pedia was compiled mainly based on following regulations and guideline released by the Malaysian Ministry of Health Department:

In Malaysia, food labeling requirements shall comply with all provisions of food labeling as stipulated in the Food Regulations 1985. It’s forbidden for any party to sell or advertise foods that are non-compliant in the labeling. Key content of the labeling requirements are summarized below.

1. Language

  • For imported foods, the label shall be in Malay or English, and in either case may include any translation thereof in any other language. 

  • In the case of imported special purpose foods (infant formula, canned food for infants and children, cereal-based food for infants and children, low energy food and formula dietary food) and certain milk products (skimmed milk, full cream milk powder or dried full cream milk, skimmed milk powder, evaporated milk, condensed milk, filled milk, evaporated filled milk and condensed filled milk), the label shall be in Malay and may include any translation thereof in any other language. 

2. Designation/description of the food

The designation of the food should contain the common name of its principle ingredients, e.g. apple juice, instead of Malus domestica (scientific name of apple) juice. In case of mixed or blended food, the label should have “mixed/blended (appropriate designation of food)” printed.

2.1 Special indications that should be labeled below the designation or description of the food

When a product falls into the following two cases, relevant statements shall be inserted below the appropriate designation of the food.

  • Where the food contains beef or pork, or its derivatives, or lard, the following statement or any other words to this effect, should be included: “CONTAINS (state whether beef or pork, or its derivatives, or lard)”.

  • Where the food contains added alcohol, the following statement shall be “CONTAINS ALCOHOL”. The words “CONTAINS ALCOHOL” shall be written in capital bold-faced lettering of a non-serif character not smaller than 6 point. 

3. Ingredient labeling

Ingredients, other than water, food additives and added nutrient should be labeled in descending order of proportion by weight.

3.1 The labeling of ingredient that causes hypersensitivity

If the food contains ingredients known to cause hypersensitivity, the ingredients shall be declared on the label. Such ingredients are as follows:

  • Cereal containing gluten including wheat, rye, barley and oat; 

  • Nut and nut product including peanut and soybean;

  • Fish and fish product;

  • Milk and milk product (including lactose); and 

  • Egg and egg product. 

For further information, please check the Guideline to Label on Hypersensitivity [3].

3.2 Food additive labeling

Scope of food additive in Malaysia: “food additive” includes preservative, coloring substance, flavoring substance, flavor enhancer, antioxidant and food conditioner, but shall not include nutrient supplement, incidental constituent or salt. 

Please note that the implementation date of such requirement has been postphoned to January 1, 2024 (originally came into effect on July 22, 2022), and enterprises can choose to follow the requirements before Jan 1, 2024: Where the food additive is listed in the International Numbering System (INS), a statement of the functional class of the relevant food additive should be followed by the name of the food additive or INS number in brackets; or if it doesn’t have an INS number, it can only label with a statement of the functional class and the name of food additive”. (This requirement shall not apply to a package where the largest of its surface area is less than 10cm2.) 

  • Where the food additive is with more than one functional class, it should label one functional class only.

  • Where the food additive is a flavoring substance, only the functional class shall be stated.

3.3 Ingredients derived from animal or obtained through modern biotechnology

  • Where the ingredients or the food additives added to such food, are derived from animals, the common name of such animal shall also be stated, e.g. “Collagen (Fish)”.

  • Where the food contains edible fat or edible oil or both, the common name of the animal or vegetable from which such fat or oil is derived should be labeled as well, e.g. “Vegetable oil (Palm oil)”. (This requirement shall not apply to a package where the largest of its surface area is less than 10cm2.)

  • The origin of food and food ingredients obtained through modern biotechnology shall be labeled as follows:

  1. in the case of food and food ingredients are composed of or contains genetically modified organisms, it should be labeled with the words “genetically modified (name of the ingredient)”;

  2. in the case of food and food ingredients are produced from, but does not contain genetically modified organisms, the words “produced from genetically modified (name of the ingredient)” shall appear on the label; 

  3. The statement “contains genetically modified ingredient” shall be stated on the principal display panel in close proximity with the name of the food and shall be in not less than 10 point lettering;

4. Minimum net weight/volume/number of package content 

All food labels shall include a statement on the minimum net weight or volume or number of the content of the package. The height of the lettering in the statement shall be uniform. 

net-weight.png

5. Name and address of manufacturer/importer/country of origin 

In the case of imported food, the labeling of this part should include:

  1. Name and address of the manufacturer overseas; or 

  2. Name and address of the owner of the rights of manufacture or packing; or

  3. Name and address of the agent in a) and b); and 

  4. Name and business address of the importer in Malaysia; and

  5. Country of origin of the food. “Country of origin” here means the country in which the manufactured food last underwent a treatment or process resulting in a substantial change in its nature.

6. Best Before / Expiration Date Requirements

The list of foods for which listing the date is mandatory is as shown in below. Foods that are not listed below may also list the date but the format shall be as prescribed by the food labeling regulations. 

1

Biscuit, bread

12

Meat product in non-hermetically sealed containers

2

Canned food for infants and children

13

Milk and milk product other than ice cream which is less than 200 ml in volume and hard cheese

3

Cereal-based food for infants and children

14

Non-carbonated pasteurized soft drink and non-carbonated U.H.T. soft drink

4

Chocolate, white chocolate and milk chocolate

15

Nutrient supplement or preparation of nutrient supplement sold as food

5

Coconut cream, coconut milk, coconut paste, coconut cream powder and desiccated coconut 

16

Pasteurized fruit juice

6

Edible fat and edible oil other than margarine in hermetically sealed containers

17

Pasteurized vegetable juice

7

Fish ball or fish cake

18

Peanut butter

8

Food additives with a shelf life of less than 18 months

19

Sauce

9

Infant formula

20

Seri Kaya

10

Liquid egg, liquid egg yolk, liquid egg white, dried egg, dried egg yolk, and dried egg white

21

Special purpose food

11

Low energy form of any food which requires date marking



The listing of date on food labels shall be shown in one of the following formats:

expiry-date.png

7. Prohibited statement/claims

The following statement and claims are prohibited to be labeled on products except as otherwise provided in these Regulations:

  • Words to indicate grading, quality or superiority or any other words of similar meaning shall not appear on the label of any package of food unless such description of quality grading conform to those established by the relevant authorities responsible for such grading;

  • The word “pure” or any other words of similar meaning unless the food is of the strength, purity or quality prescribed by regulation. 

  • The word “compounded”, “medicated”, “tonic” or “health” or any other words of similar meaning. E.g., health food.

  • Claims on the absence of
    a) beef or pork or its derivatives, or lard or added alcohol if the food does not contain such ingredients; or
    b) any additives or added nutrient the addition of which is prohibited in these Regulations. E.g., “No alcohol; Does not contain boric acid.”

  • Claims stating that any particular food will provide an adequate source of all essential nutrients.

  • Claims implying that a balanced diet or a combination of a variety of foods cannot supply adequate amounts of all nutrients. 

  • Claims that cannot be substantiated. 

  • Claims suggesting that a food can prevent, alleviate, treat or cure a disease, disorder or other physiological function. 

  • Claims that cause the consumer to doubt the safety of similar food. 

  • Claims that arouse or exploit fear in the consumer. 

  • The word “organic”, “biological”, “ecological”, “biodynamic” or words of similar meaning unless the food conforms to the requirements specified in the Malaysian regulations.

  • The word “nutritious” or words of similar meaning unless the food meets the requirements below: 

  1. The food contains a range of nutrients including carbohydrate, fat, protein, vitamin and mineral; 

  2. The food contains a substantial amount of energy of more than 40kcal per 100g or 20kcal per 100ml; 

  3. The food contains source of protein not less than 5g per 100g or 2.5g per 100ml; 

  4. The food contains at least four vitamins of an amount that meets the criteria for claim as source and two minerals (excluding sodium) of an amount that meets the criteria for claim as source; and 

  5. The amount of the nutrients mentioned in point a) and d) is declared. 

  • The words “special dietary” or any other equivalent term

  • The word “wholegrain” or “whole meal” unless the food contains — 

  • (a)  100% of wholegrain or whole meal for wheat flour, rice flour, rice or grains; 

  • (b)  60% or more of wholegrain or whole meal for bread; and 

  • (c)  25% or 8 g or more of wholegrain or whole meal per serving for other products. 

8. Nutrition labeling

“Nutrition labeling” means a description intended to inform the consumer of the nutrient content of a food. Nutrition labeling shall not apply to any packages that have a total surface area of less than 100 cm2 and returnable glass bottles, provided that no nutrition claim is made.

Unless otherwise provided in these Regulations, the nutrient content relating to food shall be provided for all products specified in regulations as shown below: 

Regulations

63 - 75

84 - 87

89 - 113

116

134B

135

146-152

157-170

177

185-207

214

221

223-224

226-242

246-249

252-259

269A

279-282

339-358

360D

360E

-

-

-

-

-

-

These regulations include pasta, prepared cereal food, bread, milk product (include skimmed milk, pasteurized milk, sterilized milk, ultra-high temperature (U.H.T) milk, flavored milk, full cream milk powder, skimmed milk powder, cream, butter, cheese, etc.), canned meat, soft drink, etc.

8.1 Labeling items

Information on nutritional value shall be expressed in the form of per serving and per 100 g (ml). The mandatory nutrients to be declared shall be energy, protein, carbohydrate, total sugar, fat and sodium. 

Only vitamins and minerals listed in the nutrient reference values (NRV) and present in amounts of at least 5% per serving shall be declared in the nutrition information. 

8.2 Nutrient content claims

“Nutrient content claim” means a nutrition claim that describes the level of a nutrient contained in a food. This type of claim should follow the Table I and Table II of the Fifth A Schedule. For example, where the energy content of a food is not more than 4 kcal per 100g, then the food can claim “Free Energy”.

 Part of the content of Table I:

table-i-of-fifth-schedule.png

8.3 Nutrient comparative claims

“Nutrient comparative claim” means a claim that compares the nutrient levels or energy value of two or more foods, with words like “reduced”, “less than”, “fewer”, “increased”, “more than”, “light” or “extra”. 

Nutrient comparative claims should be labeled after conforming to the following conditions:

  • The food being compared shall be different versions of the same or similar food and the foods being compared should be clearly identified;

  • A statement of the amount of difference in the energy value or nutrient content shall be given and the relevant information shall appear in close proximity to the nutrient comparative claim.

  • The comparison should be based on a relative difference of at least 25 per cent in the energy value or nutrient content, except for micronutrients where a 10 per cent difference would be acceptable, between the compared foods and a minimum absolute difference in the energy value or nutrient content equal to or more than the value required for claim as “low” or a “source” in Table I and II to the Fifth A Schedule.

8.4 Nutrient function claims

“Nutrient function claim” means a nutrition claim that describes the physiological role of the nutrient in the growth, development and normal functions of the body. But it shall not imply or include any statement to the effect that the nutrient would afford a cure or treatment for or protection from a disease. 

Only the nutrient function claims or any other words of similar meaning as specified in Table III to the Fifth A Schedule shall be permitted to be specified on a label. E.g., when the folic acid content of a food is over 60 μg DFE per 100 g, it can label “Folic acid is essential for growth and division of cells.”

Part of the content of Table III: 

table-iii-of-fifth-schedule.png

8.5 Other function claims

It means a claim that describes specific beneficial effect of other food component in the food that gives positive contribution to health or improvement of a function of the body. Any other function claim shall not imply or include any statement to the effect that the nutrient would afford a cure or treatment for a disease or protection from a disease. 

Food can label the function claim only when the food is made complies with the minimum amount of the other food component and other conditions specified in Table IV to the Fifth A Schedule. E.g., only satisfy the three conditions listed in Table IV, it is compliant to label “Beta glucan from (state the source) helps to reduce cholesterol.”

Part of the content of Table IV: 

table-iv-of-fifth-schedule.png

For detailed requirements, please check Food Regulation 1985, its amendment and the labeling guideline. 

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