Food Information

Labelling Guidelines for Food Importers & Manufacturers

Overview

All pre-packed food products for sale in Singapore must be labelled according to the general labelling requirements of the Singapore Food Regulations. 

Some pre-packed food products (e.g. special purpose foods, foods with nutrition or health claims, etc.) are required to meet additional labelling requirements.

Traders, producers and manufacturers should ensure that their pre-packed food are labelled correctly before making the products available for sale in Singapore.

Pre-packed food product refers to any food product that is packed in a wrapper or container in advance, before being put up for sale. 

Food which is weighed, counted or measured in the presence of the purchaser and food which is loosely packed in the retailer’s premises are exempted from these general labelling requirements.

Food label refers to any tag, brand, mark, or statement in words, pictures or diagrams, that is on, attached to, used, displayed in connection with or accompanying any food or package containing food. The label provides consumers with basic information of product such as the food product’s source, nature, contents (e.g. ingredients, allergens), quantity and quality.

The sections below will provide an overview of the labelling requirements. For a detailed guide to self-check food labels and nutrition claims, please download: 

You can also refer to SFA’s Interactive Label Template, which illustrates the various features and information found on a complying label.

About SFA’s appointed food labelling consultants

As part of SFA’s continuous effort to assist food traders to comply with the Food Regulations in terms of food labelling and advertising, SFA has collaborated with our local institutes of higher learning (listed in alphabetical order below) as SFA’s appointed food labelling consultants. Appointed food labelling consultants will provide consultation service* to the food traders on food labels and advertisements of prepacked food to help them comply with the Food Regulations.

  • Nanyang Polytechnic through its School of Chemical and Life Sciences
  • Republic Polytechnic through its School of Applied Science
  • Singapore Polytechnic through its Food Innovation and Resource Centre (FIRC)
  • Temasek Polytechnic through its School of Applied Science

* Consultancy fees may apply depending on service provided    

Name of Institute of Higher Learning Contact details    List of SFA's appointed food labelling consultants

Nanyang Polytechnic

 

Dr Gan Heng Hui
Email: gan_heng_hui@nyp.edu.sg
Telephone: 65501528

1. Dr Gan Heng Hui
2. Ms Tay Mia Eng
3. Ms Lena Ling
4. Ms Seah Lay Hoon
           

Republic Polytechnic

 

Dr Ritu Bhalla
Email: ritu_bhalla@rp.edu.sg
Telephone: 66971597

1. Dr Ritu Bhalla
2. Ms Eng Yong Yong
3. Ms Loh Sow Wai
4. Ms Chaitra Jagdish
5. Ms Yvonne Cheng
6. Mr Eric Kwek
7. Mr Samuel Aw

Singapore Polytechnic

 

Mr Zen Tan
Email: zen_tan@sp.edu.sg
Telephone: 68704619

1. Ms Carolyn Stephen
2. Ms Chen Ying Jie
           
           

Temasek Polytechnic

Ms Johanna Tan
Email: TANJO@tp.edu.sg
Telephone: 67806202

1. Ms Johanna Tan
2. Ms Zhang Yu
3. Ms Luana Ker
4. Ms Nur Azlina Binte Djabar Ali
5. Ms Saihah Binte Mohamed Salleh

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Interactive Label

Label Nutrition
 
Nutrition Labelling

Nutrition labelling enables consumers to make more informed choices with regard to the nutritional characteristics of the food. It is compulsory for prepacked food products, which carry nutrition claims, to include on their labels an acceptable nutrition information panel, with the amounts of the nutrients for which the claims have been made declared. Quantities of nutrients declared in nutrition information panels of food labels should be in absolute values, and not expressed over a range of values.

Inclusion of a nutrition information panel in food labels is mandatory only if nutrition claims are made. Food manufacturers and importers are however encouraged to follow the Health Promotion Boards's (HPB) guidelines on nutrition labelling, if they would like to inform consumers of the nutrient contents of their food products.

 
 
 
 
 
Halal Logo

The us of the "Halal" logo in Singapore is under the purview of the Islamic Centre of Singapore (Majlis Ugama Islam Singapore, MUIS).

The "Halal" logo may be used on food labels as long as all conditions and Halal requirements set by MUIS are met. Please visit www.muis.gov.sg for more information on the use of the "Halal" logo on food products.

 
Manufacturer

It is mandatory to incorporate the name and address of the local importer, distributor or agent on the labels of imported food products for sale in Singapore.

The name and address of the declared on the product labels must be qualified with suitable descriptive words such as "Imported by/Distributed by/Sole agent".

The sticker label used to incorporate the name and address of the local importer, distributor or agent in Singapore should be firmly attached on the product at all times, and does not cover other essential information required under the Food Regulations.

 
Food Containing Aspartame

Food products containing aspartame are required to carry a caution statement "PHENYLKETONURICS: CONTAINS PHENYLALANINE" to indicate the presence of phenylalanine.

 
Food Containing Royal Jelly

A statement in words like "WARNING - THIS PRODUCT MAY NOT BE SUITABLE FOR ASTHMA AND ALLERGY SUFFERERS" are required on the labels of royal jelly and food containing royal jelly.

 
Low Fat

The requirements for nutrition claim like "low fat" are made to cater for the local dietary intake pattern. Food products which carry this claim shall comply with the requirement as stated under our national nutrient claims guidelines found in the "Handbook on Nutrition Labelling" (published by Singapore's Health Promotion Board), if they are meant for sale in Singapore.

To claim for low fat, it is necessary that the product shall contain less than 3g fat per 100g of the product.

 
Manufacturer Country

The country where the product is manufactured shall be considered as the country of origin for the purpose of labelling. Then name of country of origin for product should be declared in full. The use of abbreviations is not acceptable.

Declaration of the countries of origin in the form of the overseas manufacturers' addresses is acceptable, only if the names of the countries are clearly stated in the addresses. Declaration of the name of a state in country alone without the official name of the country is not acceptable, as the name of that state may also be used in another country.

Prepacked food products manufactured in Singapore are not required to have the name of the country of origin declared in their labels. They should, however, carry the names and addresses of the local manufacturers, packers or vendors.

 
Date Marking

Date marking allows consumers to know the date by which the food shall be eaten for best quality. The expiry dates of prepacked food products may be declared as "Use by/Sell by/Expiry date/Best Before (here insert the day, month and year)". The dates declared in any of these formats will be taken as the expiry date for the food products.

Under the Food Regulations, there are currently 19 broad categories of food products that are required to be marked with expiry date. They include food products with a short shelf-life(e.g. tofu and pasteurized milk), products which are prone to changes in quality over time (e.g. vitaminised drink and cooking oil), products which are more susceptible to insect infestation (e.g. flour and breakfast cereals) and products for more vulnerable individuals (e.g. infant food).

 
Net Weight

The minimum net quantity stated on the product label must be in absolute values, and not expressed over a range of values. For example,

Net Weight: 490g --> Right declaration
Net Weight: 500g +- 10g --> Wrong declaration

The net weight of a prepacked food product containing for example 20 mini sachets of 25g each may be declared as "Net weight: 20 x 25g". Individual mini sachets are not required to have the individual net weights declared, as long as the product is not sold in the form of the mini sachets.

General Labelling Requirements

All imported or locally manufactured/produced pre-packed food for sale in Singapore must be labelled with basic information such as name of food, ingredients, net content and source. This also applies to pre-packed foods that are intended for human consumption and offered as a prize, reward or sample for the purpose of advertising.

The following basic information is required to be declared in English on the labels of pre-packed food. Items 1 to 4 should be in printed letters not less than 1.5mm in height.

1. Name or description of food


This refers to a common name or a description which is sufficient to indicate the true nature of the food product. 

Some examples of names or descriptions include:

  • "Bread"
  • "Minced or chopped meat"
  • "Olive oil"
  • "Concentrated Fruit Juice"

Ensure that the terms used for the common names or descriptions comply with the statutory requirements by referring to “Part IV – Standards and Particular Labelling Requirements for Food” of the Food Regulations.

2. Statement of ingredients


This refers to a complete list of ingredients and additives used in the food product, listed in descending order of their weight in the product (i.e. the ingredient that weighs the most must be listed first and the ingredient which weighs the least must be listed last).

See section "Ingredient Listing" below for more information on the steps to declare the statement of ingredients.

3. Declaration of foods and ingredients known to cause hypersensitivity


All foods and ingredients known to cause hypersensitivity must be declared on the food label when present as an ingredient or additive, or as a component of a compound ingredient.

See section on "Ingredient Listing" below for the list of foods and ingredients known to cause hypersensitivity and the steps to declare them.

4. Declaration of net content in package


This refers to the net quantity of the food present in the package, which is derived using the Average Quantity System (AQS) or the Minimum Quantity System (MQS).

Net quantity must be expressed in terms of:

  • Volumetric measure for liquid foods (e.g. millilitres, litres)
  • Net weight for solid foods (e.g. grams, kilograms)
  • Either weight or volumetric measure for semi-solid or viscous foods (e.g. tomato paste, yoghurt, etc.)

*Liquid medium is defined as water, aqueous solutions of sugar and salt, fruit and vegetable juices in canned fruits and vegetables only, or vinegar, either singly or in combination.

In the case of weight measure, suitable words such as “net” should be used to describe the manner of measure.

For more information on AQS, download the following slides (available in English and Chinese):

You can also download the international standards relating to the AQS:

*Efforts have been made to provide an accurate translation of R 79 and R 87 documents. However, as the official text is contained in the English versions, any discrepancies or differences created in the translation are not binding and have no legal effect for compliance or enforcement purposes. Please refer to the official English versions of the documents should you have any questions related to content accuracy.

5. Name and address of the local manufacturer/producer or importer


For food products of local origin, labels must include the name and address of the local manufacturer/producer, packer or vendor.

For imported food products, the label must indicate the name and address of the local importer, distributor or agent. Telegraphic, facsimile and post office addresses alone are not acceptable.

6. Country of origin of food


Labels on imported food products must indicate the name of the country of origin of the food. The name of a city, town or province alone is not acceptable.

Locally manufactured/produced food products are encouraged to provide this information on the label on a voluntary basis.

Exemptions


Labelling requirements do not apply under these conditions:

  • Food weighed, counted or measured in the presence of the purchaser.
  • Food that is loosely packed at the retailer’s premises.
  • Intoxicating liquors are not required to carry a statement of ingredients on their labels.

Checklist for General Labelling Requirements


  Requirements Font Height Language 
Checkbox 1. Name or description of food Information should be in printed letters not less than 1.5 mm in height.



Information should be printed in English 
Checkbox 2. Statement of ingredients 
Checkbox 3. Declaration of foods and ingredients known to cause hypersensitivity
Checkbox 4. Declaration of net content in package
Checkbox 5. Name and address of the local manufacturer/producer or importer 
Checkbox 6. Name of country of origin
For imported foods only 
You may also include:
Recipes or suggestions or pictorial illustrations on how to serve pre-packed foods.

Information should be closely accompanied by the words "Recipe" or "Serving Suggestion"
The words "Recipe" or "Serving Suggestion" should be in printed letters not less than 1.5 mm in height The words "Recipe" or "Serving Suggestion" should be printed in English 
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Additional Labelling Requirements

In addition to the statutory general labelling requirements (see section above), some pre-packed food products have to meet additional requirements.

In addition to the statutory general labelling requirements (see section above), some pre-packed food products have to meet additional requirements.

Below is an overview of the additional labelling requirements:

1. Date marking of expiry date


Currently, only products listed under the Second Schedule of the Food Regulations have to be date marked in accordance to Regulation 10 of the Food Regulations.

The date-marking must be permanently marked or embossed on the package, and printed in letters not less than 3mm in height. Date mark shall not be removed, altered, obscure, superimposed or tampered in any manner.

2. Advisory statements for food containing certain sweetening agents


Advisory statements to restrict the consumption of some food categories have to be included in the labels if the product contains certain sweetening agents (e.g. acesulfame-K, saccharin, etc.) added at the maximum permissible levels.

3. Labelling of Special Purpose Foods


Special purpose foods are foods formulated to cater for the special dietary needs of specific groups of consumers. These include sugar-free foods, low-calorie foods, diabetic foods, etc.

These foods must be labelled clearly to indicate their special suitability, and must meet the statutory nutrition labelling requirements.

See section "Nutrition, Health & Other Claims" below for guidelines on using nutrition and health claims and the list of acceptable nutrition and health claims.

4. Nutrition labelling


Nutrition labelling in the form of a nutrition information panel is required when nutrition claims or permitted health claims are made for pre-packed foods.

The information declared in the panel must include the energy, protein, fat and carbohydrate contents of the food. The nutrients indicated in the nutrition claim must also be declared.

For more information on the permitted nutrition and health claims, see section "Nutrition, Health & Other Claims" below. 

For an acceptable format of the nutrition information panel, see the Twelfth Schedule of the Food Regulations.

5. Specific labelling for certain food categories


Certain food categories (e.g. irradiated food, wholegrain, milk, fruit wine, pre-packaged edible fats and oils etc.) are required to meet specific labelling requirements.

6. Advisory statements for certain ingredients


Products containing certain ingredients (e.g. royal jelly, aspartame, etc.) need to be labelled with the relevant advisory statements or any other statements to the same effect (e.g. “Warning: This product may not be suitable for asthma and allergy sufferers”).

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Nutrition, Health & Other Claims

Importers and manufacturers/producers of pre-packed food have to meet the statutory food labelling requirements. These include proper nutrition labelling for certain food products such as special purpose foods, foods that make health claims, etc.

The sections below will provide an overview of the guidelines on using nutrition claims or health claims, and information on application procedures for using new health claims.

For exact requirements and information on using nutrition and health claims (e.g. definitions, technical criteria such as weight or percentage of nutrients, etc.), importers and manufacturers/producers can refer to the following documents:

Using Nutrition, Health or Other Claims


In general, there are 3 types of claims food products can carry:

  • nutrition claims,
  • health claims, and
  • other claims: Organic, gluten free, etc.

All pre-packed food products bearing nutrition claims or health claims must come with a nutrition information panel, as well as meet the related requirements stated in:

Nutrition claims

Nutrition claims suggest or imply that food products have nutritive properties such as:

  • Energy
  • Salt (sodium or potassium)
  • Protein and amino acids
  • Carbohydrates, starch or sugars
  • Fats, fatty acids and cholesterol
  • Fibre 
  • Vitamins or minerals
  • Any other nutrients

Examples of nutrition claims include "Low in calories", "Sugar free", “Reduced sodium” and “High in Vitamin C”.

Manufacturers/producers can use SFA’s Vitamins and Nutrients Calculator to run a search on various vitamins and minerals for advice on making a claim regarding vitamins or nutrients.

Health claims

Health claims are descriptions that state, suggest or imply that a relationship exists between foods (or their constituents) and health.

There are 3 types of health claims:

  • Nutrient function claims
  • Other function claims
  • Nutrient specific diet-related health claims

Nutrient function claims

Nutrient function claims describe the physiological role of the nutrient in growth, development and normal functions of the body.

In principle, only approved nutrient function claims that are listed in the SFA website (Guide to Food Labelling and Advertisement and Vitamins and Nutrients Calculator), can be made on food products that meet the respective claim criteria. The list of nutrient function claims are generally supported by scientific evidence.

Other function claims

Other function claims describe the specific beneficial effects foods (or their constituents) have on normal functions or biological activities of the body, in terms of:

  • a positive contribution to health, or
  • the improvement of a function, or
  • modifying or preserving health.

Other function claims must be stated in their exact approved form, and must not be presented as product-specific (i.e. the claim cannot imply or suggest that the beneficial effects are specific to the product).

Truncated or reworded versions which deviate from or change the intended meaning of the original approved claim will not be accepted.

The list of approved health claims that can be used on food products sold in Singapore can be found in the ‘A Guide to Food Labelling and Advertisements.'

Nutrient specific diet-related health claims

Nutrient specific diet-related health claims are claims which relate foods (or their constituents), in the context of the total diet, to the reduced risk of developing a disease or health-related condition.

These claims are also known as “reduction of disease risk claims” under the Codex Guidelines for Use of Nutrition and Health Claims.

Local food manufacturers/producers and importers are encouraged to inform SFA or HPB on their intention to use the following approved nutrient specific diet-related health claims:

Approved Nutrient Specific Diet-related Health Claims*
A healthy diet with adequate calcium and vitamin D, with regular exercise, helps to achieve strong bones and may reduce the risk of osteoporosis. (State name of food here) is a good source of / high in / enriched in / fortified with calcium.
A healthy diet low in sodium may reduce the risk of high blood pressure, a risk factor for stroke and heart disease. (State name of food here) is sodium free / very low in / low in / reduced in sodium.
A healthy diet low in saturated fat and trans fat, may reduce the risk of heart disease. (State name of food here) is free of / low in saturated fats, trans fats.
A healthy diet rich in whole grains**, fruits and vegetables that contain dietary fibre, may reduce the risk of heart disease. (State name of food here) is low / free of fat and high in dietary fibre.
A healthy diet rich in fibre-containing foods such as whole grains+, fruits and vegetables may reduce the risk of some types of cancers. (State name of food here) is free of / low in fat and high in dietary fibre.

* The criteria for use of these health claims (e.g. maximum amount of sodium, fat allowed in product, etc.) can be found under regulation 9A and the Fourteenth Schedule of the Food Regulations. The approved health claims and criteria are based on HPB’s existing nutrient claims guidelines, with reference taken from currently available guidelines established by major developed countries.

** Refer to regulation 40A for the definition and labelling requirements for "wholegrain" products.

Apply for nutrient specific diet-related health claims

STEP DESCRIPTION
Step 1: Ensure your food product meets the relevant criteria for the intended health claim.

Refer to the revised regulation 9A and the Fourteenth Schedule of the Food Regulations for more information.
Step 2: Apply for HPB’s approval for your food product to carry the Healthier Choice Symbol (HCS).

It is recommended for food products to first pass a pre-market evaluation and be approved by HPB to carry the Healthier Choice Symbol before the use of the nutrient specific diet-related health claims can be considered.

See HPB’s page on the Healthier Choice Symbol Programme for more information.          

Step 3: Notify the use of the nutrient specific diet-related health claim through e-mail via the online feedback system: https://csp.sfa.gov.sg/feedback
           
SFA will assist in providing advice on the suitability for the use of the intended nutrient specific diet-related health claim for your food product.

Other claims

Other claims are those not related to nutrition or health claims, and include “organic” and “gluten-free” and “Raised without the use of antibiotics”.

Organic

Products that are specified as organically produced, must be accompanied by a certificate to substantiate that the product is certified as organic under an inspection and certification system that complies with section 6.3 of the Codex Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods, GL 32-1999, or its equivalence.

Gluten-free

Products labelled as “gluten free” must meet the Standard for Foods for Special Dietary Use for Persons Intolerant to Gluten (CODEX STAN 118-1979) established by the international food standards setting body, Codex Alimentarius Commission*.

Download the guidelines and standard from the links below:

*The Codex Alimentarius Commission is the international food standards body established by the Food and Agricultural Organisation of the United Nations and the World Health Organisation.

Raised without the use of antibiotics

Food products labelled as being free from antibiotic and hormones are not allowed. The table below provides guidance on the appropriate use of claims relation to the absence of antibiotics and hormones in food.

Claim Position Rationale Criteria
Claims on presence of hormones
Hormone free/ Raised without use of hormones Not allowed This claim would create the impression that the meat does not contain hormones. This claim would be incorrect and inaccurate as meat, poultry and fish products contain naturally occurring hormones. Not applicable
No growth promotants / stimulants Not allowed Hormones and low doses of antibiotics in feed are considered growth stimulants. Some consider most of the ingredients in feed mixes such as grains, vitamins and minerals to stimulate growth. With such a broad and diverse understanding of growth stimulant, this claim could mean the absence of a number of substances and the presence of others, depending on the individual. Currently, there is also no objective criteria to define and evaluate such a claim, its use is therefore not acceptable. Not applicable
Claims on presence of antibiotics
Antibiotic free Not allowed The claim would create a false uniqueness since food, made with animal raised for food production, for sale in Singapore are not allowed to contain antibiotic residues. Not applicable
Fed no antibiotics/
Not injected with antibiotics
Not allowed Antibiotics could be administered by different means (e.g. injection, water, feed or spray), a claim on the absence of antibiotics through specific administration, would mislead consumers. Not applicable
Raised without use of antibiotics May be used on food labels and advertisements, provided that the conditions are met. SFA notes that traders would deliberately source food from farmers that take extra effort to ensure that no antibiotics were administered throughout the lifespan of the animal (i.e. from birth to slaughter), due to market demand. In order to recognise the farmer’s effort to differentiate their method of production and to protect consumer’s interest, SFA requires food traders to provide documentary proof to substantiate for use of such claim. The claim has to be supported by a valid certification issued from a competent authority recognised to conduct audits with respect the use of the claim, throughout the lifespan* of the animal.

*“Lifespan” would include that the animal is not given birth or nursed by mothers administered with antibiotics, as antibiotics would be passed through mother’s bloodstream and milk.

Application for Use of New Health Claims


Besides using the permitted health claims, local food manufacturers/producers and importers can apply for the use of new health claims (i.e. new nutrient function claims and new other function claims).

Apply for new health claims

STEP DESCRIPTION
Step 1: Refer to the Food Regulations for information on permitted food ingredients and additives.
Step 2: Download and complete SFA’s Health Claim Application Form. Ensure that you have attached all required supporting documents (e.g. approval letter or document from national food authorities, verification of proprietary or confidential data, etc.)
Step 3: Submit the completed application form and all supporting documents to:

Regulatory Policy Department
Food Regulatory Management Division
Singapore Food Agency
JEM, 52, Jurong Gateway Road, #14-01
Singapore 608550

How new health claims are evaluated

Applications for the use of new health claims are evaluated according to the framework and principles established by SFA’s Advisory Committee on Evaluation of Health Claims.

The framework and principles are based on Codex Alimentarius’ recommendations on the scientific basis for health claims.

About the Advisory Committee

The advisory committee was formed in August 2009, and is tasked to:

  • establish the framework and principles for evaluation of health claims in Singapore, based on Codex's recommendations on the scientific basis for health claims;
  • evaluate and make recommendations on applications for use of other function claims as defined by Codex; and
  • advise and update relevant scientific developments and legislation relating to evaluation of health claims.

The committee comprises reputable scientific experts with relevant professional training and experience from the following government bodies, tertiary institutions and industry associations:

  • Health Promotion Board
  • Health Sciences Authority
  • Enterprise Singapore
  • A*STAR
  • Consumers Association of Singapore
  • National University of Singapore
  • Nanyang Technological University
  • Nanyang Polytechnic
  • Republic Polytechnic
  • Singapore Polytechnic
  • Temasek Polytechnic
  • Singapore Manufacturers' Federation
  • Singapore Food Manufacturers' Association
  • Health Supplements Industry Association of Singapore
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Ingredient Listing

Importers and manufacturers of pre-packed food have to meet the statutory food labelling requirements.

The sections below provide information and guidelines on declaring the statement of ingredients and the foods and ingredients known to cause hypersensitivity.

Statement of Ingredients


Labels of pre-packed foods must bear a clear statement of ingredients that specifies the complete list of ingredients and additives used in the food.

Unless the quantity or proportion of each individual ingredient is specified, the ingredients and additives used, must be listed in descending order of the proportions by weight in which they are present.

The steps below serve as a guidance to assist you in the declaration of statement of ingredients.

How to declare

STEP DESCRIPTION
Step 1: List down all the ingredients used in the food product in their exact identities* and arrange them in descending order by weight, i.e.:
  • The ingredient that weighs the most must be listed first, while the ingredient that weighs the least must be listed last.
Step 2: Identify the compound ingredients used in the food product, and find out the components of the compound ingredients by:
  • checking with your suppliers, or
  • checking the documents provided by suppliers (e.g. product specification sheets).


List out these components in descending order by weight in parenthesis next to the compound ingredients. E.g. “Batter (water, cornstarch, wheat flour, salt, sodium bicarbonate)”.
Step 3: Find out whether there are any simplified terms for the ingredients.

See the First Schedule of the Food Regulations for the list of permitted generic terms. Otherwise, all ingredients must be listed in their exact identities*.

For food additives, besides declaring their exact chemical names, you can use the International Numbering System (INS) or E numbers.
Step 4: Check the presence of any ingredients or additives that are known to cause hypersensitivity, and label their exact identities.

For more information, see the section below on Foods & Ingredients Known to Cause Hypersensitivity.

* Exact identity refers to the specific name or description indicating the true nature of the ingredient.

You can also download Guidelines on the Declaration of Statement of Ingredients for Food Products for detailed steps and examples.

Foods & Ingredients Known to Cause Hypersensitivity


Pre-packed food labels must bear a declaration of all foods and ingredients known to cause hypersensitivity that are present in the food as:

  • an ingredient,
  • an additive, or
  • a component of a compound ingredient.

This is in line with Regulation 5(4)(ea) of the Food Regulations.

What to declare

The following foods and ingredients are known to cause hypersensitivity and must be declared in the food labels:

No. Group Ingredients
(i) Cereals containing gluten Wheat, rye, barley, oats, spelt, their hybridised strains and their products.
(ii) Crustacean and crustacean products Crayfish, prawns, shrimps, lobsters, crabs and their products.
(iii) Eggs and egg products Eggs from laying hen, duck, turkey, quail, goose, gull, guinea fowl and their products.
(iv) Fish and fish products Molluscs such as oysters, clams, scallops and their products.
(v) Peanuts, soybeans and their products Peanuts, which may be declared using “groundnuts” or similar terms, and soybeans, which may be declared using terms such as “soya” or “soy”.
(vi) Milk and milk products (including lactose) Milk from cows, buffaloes, goats and their products.
(vii) Tree nuts and nut products Almond, hazelnut, walnut, cashew nut, pecan nut, Brazil nut, pistachio nut, macadamia nut and their products.
(viii) Sulphites in concentrates of 10mg/kg or more Sulphites directly added and/or carried over from food ingredients at a total concentration of 10mg/kg or more (calculated in terms of total sulphur dioxide).

How to declare

There are 2 ways to declare foods and ingredients known to cause hypersensitivity:

  1. Using statement of ingredients
  2. Using “contain” statement

Option 1: Declaration using statement of ingredients

The list of foods and ingredients known to cause hypersensitivity will be listed as part of the declaration of the complete list of ingredients used in the food product, in descending order by weight. Allergens should not be listed using generic terms.

Option 2: Declaration using “contain” statement

All ingredients, including those known to cause hypersensitivity, must be clearly declared in the statement of ingredients.

The “contain” statement is an additional statement that appears immediately after the complete statement of ingredients. The statement:

  • must not provide any contradictory information, and
  • should not be used to declare additional food ingredients or additives not declared in the statement of ingredients.

Allergenic ingredients which are unintentionally introduced into foods must not be declared in the “contain” statement. Such cases include contamination or ingredients being carried over during manufacturing, transportation, storage, etc.

Tips for declaration

Type of Food Allergen Declaration using statement of ingredients Declaration using “contain” statement
Food ingredient or additive

E.g. Peanut oil
Avoid generic terms when declaring food allergens.

E.g. Do not use “vegetable oil”, a generic term, to designate peanut oil, an allergen. Instead, use words like “Peanut oil” or “Vegetable oil (peanut)” in the declaration.
If generic terms are used in the statement of ingredients, the food allergens should be declared in the “contains” statement.

E.g. If “vegetable oil” is used to designate peanut oil in the statement of ingredients, use the following “contains” statement to declare the allergen (i.e. peanut):
  • “Contains: peanut”
Component ingredient of a compound ingredient

E.g. A cake made of batter containing wheat flour
Declare the components of the compound ingredient in parentheses immediately after the compound ingredient. Avoid using generic terms for the food allergens.

E.g. “Batter (water, cornstarch, wheat flour, salt, sodium bicarbonate)”
If generic terms are used in the statement of ingredients, the food allergens can be declared in the “Contains” statement.

E.g. If wheat flour is declared as “flour” in the statement of ingredients, the “contains” statement can be used as follows:
  • “Contains: wheat”
Food ingredient or additive derived from allergenic sources

E.g. Lecithin, sodium caseinate
Provide a description, in parentheses, to highlight ingredients that are derived from allergenic sources.

E.g. “Lecithin (egg product)”, “Sodium Caseinate (from milk)”
Provide a “Contains” statement to highlight the source of allergens.

E.g. If lecithin and sodium caseinate are declared in the statement of ingredients, the following “Contains” statement can be used to highlight their allergenic sources:
  • “Contains: egg, milk”

Special considerations

  • In line with international practice, the following ingredients are not required to be declared on the label:
    • cereals, whey and nuts when used as distillates for alcoholic beverages, and
    • fish gelatine or isinglass* when used as fining or clarifying agents in beer and wine.
    Food traders have to bear full responsibility for ensuring that the undeclared information does not, in actual fact, cause harm to consumers.
  • AVA does not encourage the use of disclaimer statements such as “may contain” to declare the presence of ingredients known to cause hypersensitivity, as they may restrict consumer choice unnecessarily and undermine valid warnings.

    Food traders whose products carry the “may contain” statement may be required to provide justification if consumers raise any concerns on potential food allergens in the products.

* Isinglass is a semi-transparent whitish gelatine prepared from the swim bladders of sturgeon and certain other fishes and is used as a clarifying agent in beer and wine.

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