Thailand Consults on Revised Nutrition Labeling Guidelines for GDA Formats

On March 7, 2025, Thailand FDA announced a public consultation on two draft notifications aimed at updating food nutrition labeling requirements. Any comments can be sent to [email protected] by April 30.

The two drafts under the consultation are:

Draft of MOPH Notification on Nutrition Labels (No.2)
Draft of MOPH Notification on Foods Required to Display Nutrition Labels and Levels of Energy, Sugar, Fat and Sodium in GDA Format (No. 3)

Background

The proposed revisions address two major issues in current Guideline Daily Amounts (GDA) labeling practices:

Color Limitations: Existing labels face challenges with color compliance due to printing restrictions. For instance, the mandated colors for lines and text—typically black or dark blue—cannot always be used.
Packaging Constraints: Many products, such as instant noodles packaged in corrugated cardboard boxes, cannot support a white label background.

Key Changes in the Draft Notifications

Draft of MOPH Notification on Nutrition Labels (No.2)

The proposed draft revises background color requirements to align with the upcoming changes in another draft notification (see below). Specifically, for packaging formats where a single unit cannot be consumed at once (e.g., wholesale cartons), manufacturers will be permitted to use alternative background colors when a white background is impractical—provided that the nutritional information remains legible and clearly visible.

Draft of MOPH Notification on Foods Required to Display Nutrition Labels and Levels of Energy, Sugar, Fat and Sodium in GDA Format (No. 3)

Key changes are marked in red below.

Current provisions (Notification No. 394)	Proposed provisions (Draft notification)	Principles of consideration
1.2 The border color of the cylindrical shape must be one of the following: black, dark blue, or white, as appropriate, and it must contrast with the background color of the label. 1.3 The background color inside the cylindrical shape must be white only. 1.4 All lines inside the cylindrical shape must be either black or dark blue and must match the color of the text displayed inside the cylindrical shape.	1.2 The border color and the lines inside the cylindrical shape must be the same as the text color displayed inside the cylindrical shape, and they must contrast with the background color of the label. 1.3 The background color inside the cylindrical shape must be white only. Except in cases where large packaging contains multiple food items combined in a single package that is wrapped for sale and where it is not possible to make the background color inside the cylindrical shape white. In such cases, any single color may be used as the background color inside the cylindrical shape, provided it is clearly readable, such as corrugated cardboard boxes.	Adjust the requirements for the border color and lines of the cylindrical shape to ensure practicality and to avoid restricting innovation in food labeling and packaging. Modify the background color requirements specifically for cases where a single unit of packaging cannot be consumed in one sitting and where multiple packages are bundled together for sale, such as wholesale cartons. In such cases, if a white background cannot be used, other colors may be displayed as appropriate, provided the information remains visible and clearly readable.
2. The energy, sugar, fat, and sodium values must be displayed in an easily visible and clearly readable format and font size, arranged in a cylindrical shape in the following order:	2. The energy, sugar, fat, and sodium values must be displayed in an easily visible and clearly readable format, font color and font size, arranged in a cylindrical shape in the following order:	Clarify the provisions, as Section 1.2 allows text to be displayed in any color and does not strictly require black or dark blue.
2.1 Section 1: The words "Energy", "Sugar", "Fat" and "Sodium" must be displayed in the same color as the lines inside the cylindrical shape.	2.1 Section 1: The words "Energy", "Sugar", "Fat" and "Sodium" must be displayed in the same color as the lines inside the cylindrical shape. Additionally, the term "Total Sugar" may be used instead of "Sugar", and "Total Fat" may be used instead of "Fat" as appropriate.	Adjust the requirements to allow additional nutrient information to be displayed on the GDA label, aligning with the required information in the nutrition information panel, as specified in Notification No. 445 on Nutrition Labeling.

The revised drafts are designed to address current practical challenges in nutrition labeling while supporting innovation in packaging design. By refining color specifications and display requirements, the new guidelines aim to ensure that nutritional information remains both accessible to consumers and feasible for manufacturers to implement.