In lieu with multiple other countries in Asia from Vietnam to South Korea, the Thai food regulatory authority has embarked on a course to improve its labelling regulations to align with international standards.
Thai FDA’s major areas of focus with this upgrade is to change the requirements management over how expiration dates and allergen warnings are displayed on-pack.
“One major change that has been proposed in this draft is much deeper clarity regarding how allergen warnings need to be displayed and what ingredients need to carry such warnings,” the agency stated via a formal statement.
“First of all, there would now be a statement stating ‘Information on food allergies: Contains allergen XXX / There is Allergen XXX’ if the potential allergen is used as an ingredient; or a statement saying ‘Information on food allergies: There may be Allergen XXX / May contain Allergen XXX’ depending on the situation, to warn against possible contamination during the production process.
“The main concern here is that this statement must be clearly [demarcated] on the packaging near the vicinity of the ingredients list and must be clearly legible.
“Potential allergens or ingredients that tend to cause hypersensitivity and need to carry these warnings include gluten (wheat, rye, barley, oats, spelt or hybrids of these) and [most] products that contain these, crustaceans (crabs, shrimp, lobsters, etc.), shellfish and squid, eggs and egg products, fish and fish products, peanut and peanut products, soy and soy products, milk and dairy products, nuts with hard shells (almonds, walnuts, pecans, etc.) and related products, products with a sulphite content of 10mg/kg or more.
“The only occasion when this provision might be unnecessary would be if the product already has a product name clearly identifying allergens or such hypersensitive substances – examples here would be fresh cow milk or crispy peanuts.”
Thailand has had regulations in place to mandate allergen warnings since 2014, but this is the first time that the That FDA has made an indication of how the wording needs to be specified, likely in order to prevent misleading declarations that could potentially confuse consumers.
This has been an area of particular concern in the country especially after a 2021 study that revealed 7.22% of undeclared food allergens still remained in the local food system since the initial allergen regulations were enforced, though this was a significant improvement compared to the 18.9% rate found before the regulations were enforced.
Thai FDA also made another effort at standardisation in its proposal regarding expiration dates, where it was suggested that all manufacturers follow a more specific, systematic date format and system.
“A specific day, month and year should be stipulated or food products with a shelf life not exceeding 90 days, and a specific month and year for products with a shelf life of more than 90 days,” said the agency.
“There also needs to be a statement saying either ‘Expiry date’ or ‘Should be consumed before’ to avoid confusion. If the date cannot itself be displayed [in a clearly visible location], it is also mandatory to include text on the label to tell consumers where to find this date.
“All products must include this date in the day-month-year format in sequential order, with the month displayed as either a number or a letter; and if these are out of order there must also be statements conveying this clearly to consumers.”
Members of the public and food and beverage industry can submit comments from now until September 30 2023 via either this online feedback form; the commenting form at the Thai FDA website here, by post, by fax or by e-mail here. More information can be found at the Thai FDA website here.