Thailand Implements New Nutrition Labeling Regulations

On January 5, 2024, Thai Food and Drug Administration (FDA) unveiled three notifications related to the nutrition labeling of prepackaged food, including:

• Ministry of Public Health Notification (No. 445) B.E. 2023 regarding Nutrition Labels

• Ministry of Public Health Notification (No. 446) B.E. 2023 regarding Foods Required to Display Nutrition Labels and Levels of Energy, Sugar, Fat and Sodium in GDA format (No. 2)

• Ministry of Public Health Notification (No. 447) B.E. 2023 regarding Health Claims of Food on Labels

These notifications will enter into force on July 2, 2024. However, a grace period of three years is given to food stakeholders. That is, stakeholders are allowed to be compliant with the new requirements no later than July 1^st, 2027, and food products aligning with the current requirements can continue to be sold in Thailand before July 1^st, 2027.

The following are the key points of these three notifications.

Ministry of Public Health Notification (No. 445) B.E. 2023 regarding Nutrition Labels

Application scope

Ministry of Public Health Notification (No. 445) B.E. 2023 regarding Nutrition Labels (hereinafter “MOPH No. 445) will replace MOPH Notification No. 182, No. 219 (No.2), and No. 392 (No.3) after it comes into effect. Its application scope newly includes “food with health claims” while removes “foods targeted at specific consumer groups for promotional purposes”, because the latter falls in the scope of food for special dietary uses, so its nutrition labeling shall follow the corresponding regulations for food for special dietary uses.

Nutrients subject to mandatory nutrition labeling

The mandatory nutrients on nutrition information panel are changed from 15 to 9 items, which are energy, total fat, saturated fat, cholesterol, protein, carbohydrate, total sugars, sodium and potassium. Pay attention, potassium is newly added. 

The value rounding guideline for vitamins and minerals are revised in accordance with Codex.

Format of the nutrition information panel

MOPH No. 445 further standardizes the format of nutrition information panel in Attachment 1 and no longer supports simplified format as stipulated in MOPH Notification No. 182. Enterprises can refer to the Attachment 1 for seven permitted formats. The use of formats other than specified must be approved by FDA first. Besides, the requirements for label design are also revised, involving the background color, font size, etc.

Thai Reference Daily Intakes (Thai RDIs)

The Daily Reference Values (Thai RDIs) for 33 nutrients are updated with reference to Nutrient Reference Values (NRVs) defined by the Codex standards.

Details can be found in MOPH Notification No. 445 Attachment 3 Daily nutrient reference values for Thai people.

Nutrition claims

In MOPH Notification No. 182, nutrition claims include content claim, comparative claim and function claim. According to the latest regulation scheme, the requirements for function claims are removed from MOPH Notification No. 445. Instead, they are detailed in MOPH Notification (No. 447) B.E. 2023 regarding Health Claims of Food on Labels. 

In addition, MOPH No. 445 updates the criteria of claiming “low saturated fat”, “less Sodium”, “no sugar added”, and “high/rich in xxx”.

Details can be found in MOPH Notification No. 445-Attachment 4 Criteria for nutritional claims on food labels. 

Ministry of Public Health Notification (No. 446) B.E. 2023 regarding Foods Required to Display Nutrition Labels and Levels of Energy, Sugar, Fat and Sodium in GDA format (No. 2)

The issuance of MOPH Notification No. 446 aims to clarify that the nutrition label mentioned in MOPH Notification No. 394 Re: Food products Required to bear Nutrition Labelling and Guideline Daily Amounts, GDA Labelling should comply with the formats and conditions specified in the latest MOPH Notification regarding nutrition label.

Ministry of Public Health Notification (No. 447) B.E. 2023 regarding Health Claims of Food on Labels

As mentioned above, MOPH Notification No. 447 is drafted to specify the criteria and conditions of function claims of food. Attachment 1 incorporates the permitted function claims of nutrients; Attachment 2 lists other function claims with specific conditions; Attachment 3 stipulates the claims for disease risk reduction and the corresponding claim conditions.

Enterprises must apply for evaluating function claims not specified in MOPH No.447. The documents required could be referred to Attachment 4.