CONSULTATION ON DRAFT FOOD (AMENDMENT) REGULATIONS 2021: LABELLING AND ADVERTISING REQUIREMENTS FOR “NUTRI-GRADE BEVERAGES” SOLD IN SINGAPORE

RESPONSES TO COMMENTS RECEIVED FOR THE CONSULTATION ON DRAFT FOOD (AMENDMENT) REGULATIONS 2021 REGARDING LABELLING AND ADVERTISING REQUIREMENTS FOR “NUTRI-GRADE BEVERAGES” SOLD IN SINGAPORE

1. The Singapore Ministry of Health (MOH) and Health Promotion Board (HPB) conducted a public consultation exercise from 1 April 2021 to 31 May 2021. Feedback was sought from stakeholders on the proposed Food (Amendment) Regulations under the Sale of Food Act (“Amendment Regulations”), to introduce new requirements on Nutri-Grade beverages¹ sold in Singapore (“measures”). MOH and HPB have also notified the Amendment Regulations to the WTO and invited members’ comments over the same period. The measures are summarised as follows:

a. Nutri-Grade beverages are to be graded “A”, “B”, “C” or “D” according to the Nutri-Grade grading system; 

b. Nutri-Grade beverages will have to carry a nutrition information panel (“NIP”), stating the energy content and the amount of carbohydrate, total sugar, fat, saturated fat and protein in the Nutri-Grade beverages; 

c. Nutri-Grade beverages graded “C” or D” must be labelled with a Nutri-Grade mark on the front-of-pack of the package. If the Nutri-Grade beverage is sold online, through a vending machine or an automated beverage dispenser, the image of the Nutri-Grade mark must be displayed to the purchaser; and 

d. Nutri-Grade beverages graded “D” are prohibited from advertising, except at points-of-sale platforms.

Background

2. High sugar intake is linked to increased risk of obesity and diabetes. A 2021 local meta-analysis which included studies on Asian populations found that higher consumption of sugary beverages was associated with a 51% higher risk of diabetes, compared to lower consumption². The World Health Organization (WHO) has called on countries to take action to reduce individuals’ intake of sugar to as low as possible, stating that “nutritionally, people do not need any sugar³ in their diet”⁴. 

3. However, Singaporeans are consuming on average twelve teaspoons (or 60g) of sugar daily. More than half of Singaporeans’ daily sugar intake comes from beverages, of which pre-packaged beverages contribute 64 per cent. This is a concern, and more needs to be done to reduce Singaporeans’ sugar intake. 

4. As such, MOH announced on 10 October 2019 its decision to introduce the measures. This decision was made after carefully considering the feedback received from members of the public, industry and expert stakeholders, and reviewing existing overseas and local evidence. 

5. The measures aim to provide consumers with nutrition information, particularly on sugar content, to make informed choices, and reduce influence from advertising, thus encouraging healthier choices and spurring industry reformulation. The measures also complement MOH and HPB’s current promotional and educational efforts to shift the market towards healthier product offerings, as part of a sustainable long-term approach to reshape consumer behaviour and choices.  

Summary of comments 

6. MOH and HPB received a total of 65 comments⁵ to the Amendment Regulations from members of the public, industry stakeholders and overseas Governments, a breakdown of which can be found in Table 1 below. 

Table 1. Comments by category

Category	Number of comments received
Industry (excluding Industry Associations)	49
Industry Associations	8
Overseas Government	6
Members of the Public	2
Total	65

7. Most of the comments received sought to better understand the Amendment Regulations, in particular, the definitions of Nutri-Grade beverage, sugar and sugar substitutes, the Nutri-Grade grading system, the requirements in relation to the NIP, the implementation timeline and the operational aspects of the Amendment Regulations. There were a few comments on the design and the policy intent of the measures.  MOH and HPB’s responses to the key comments raised are set out in Table 2 of the Annex.

8. MOH and HPB would like to thank all respondents for participating in the consultation. MOH and HPB are reviewing the proposed Amendment Regulations, taking into consideration the comments received. Singapore intends to publish the Amendment Regulations in the Gazette, 12 months before they are intended to come into effect.

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¹ The proposed definition of a Nutri-Grade beverage is stated within the new regulation 184A, to be introduced under the Amendment Regulations. 

² Nithya Neelakantan, Su Hyun Park, Guo-Chong Chen, Rob van Dam. (2021) Sugar-sweetened beverage consumption, weight gain, and risk of type 2 diabetes and cardiovascular diseases in Asia: a systematic review. Nutrition Reviews. [Notes: For the purpose of this study, “higher consumption” is defined as daily or almost daily consumption, with a median of 2 servings per day, and “lower consumption” is defined as rare or no consumption.] 

³ Sugar here refers to free sugars, which is defined by the WHO as sugars added to foods and drinks, and sugar that is naturally present in honey, syrups and fruit juices. These do not include the sugars present in milk (i.e. lactose and galactose) and the sugars present in whole fruit and vegetables.

⁴ WHO (2016, Oct 11) WHO urges global action to curtail consumption and health impacts of sugary drinks [Press release] Retrieved from www.who.int/news-room/details/11-10-2016-who-urges-global-action-to-curtail-consumption-and-health-impacts-of-sugary-drinks