Consultation on Draft Food Amendment Regulations 2015

Agri-Food and Veterinary Authority (Regulatory Administration Group)

Consultation Period: 21 Oct 2015 - 21 Dec 2015

Status: Closed - Summary of Responses

Consultation Outcome

RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON THE DRAFT FOOD (AMENDMENT) REGULATIONS 2015

The Agri-Food and Veterinary Authority of Singapore (AVA) initiated a public consultation exercise for the period 22 October 2015 to 21 December 2015. Feedback was sought from the food industry (local food manufacturers and importers) and interested parties on the proposed amendments to the draft Food (Amendment) Regulations 2015.

Eight submissions were received from local food industry members, foreign government agencies, and a member of the public. Two submissions were in support of the proposed amendments to the Food Regulations. The comments and feedback from the remaining six submissions are summarised below.

(A) Requirement for certification for food products labelled as “organic”

Some industry members raised concerns regarding this requirement, as third party / independent organic certification bodies are often not officially recognised / endorsed by the government bodies in the exporting countries, or the manufacturer adopts a set of organic standards which may not fully comply with the Codex Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods, GL 32-1999. There was also a request for a country to country equivalence agreement for trade in organic foods.

AVA has clarified with the feedback providers that the proposed new Regulation 9B(5) on organic certification (extracted below for reference) would allow AVA the flexibility in the implementation of the new requirement and accept valid organic certificates issued by organic certification bodies. AVA has also clarified that certification systems which are similar to Codex would be acceptable and there was no need for a country to country equivalence agreement solely for the issue.

“9B(5): A label must not include the word “organic”, or any word of the same significance, in relation to food unless the food is certified as organic under an inspection and certification system —

      (a) 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

      (b) that substantially complies with the guidelines mentioned in sub-paragraph (a) and is acceptable to the Director-General as being a suitable system for the certification of organic food.”.

(B) Changes to Regulation 9

Some industry members were concerned with the changes to Regulation 9, and sought clarification on how AVA intended to implement the new changes.

AVA has clarified with them that the changes to Regulation 9 (with the exception of the new requirement for organic certification) are all editorial in nature, and that there is no change to the contents of the regulation. The existing Regulation

9 has been re-organised into Regulations 9, 9A and 9B, so as to present the provisions in a clearer manner and to update the language used. Interested parties may refer to the  ANNEX for a comparison of the existing regulation 9 and the proposed “new” regulation 9, 9A and 9B for a better understanding of the matter.

(C) Changes to Regulation 30(3)

A foreign government body expressed concern over the changes to the maximum residue limits (MRLs) for pesticide residues on food.

AVA has clarified with the government body that the changes to regulation 30(3) are purely editorial in nature, and do not affect the contents. There is no change to the MRLs for pesticide residues on food.

AVA appreciates the time taken by all parties to submit feedback and comments on the draft Food (Amendment) Regulations 2015. We would like to encourage all parties to actively participate in future calls for comments.

Summary

The Agri-Food and Veterinary Authority (AVA) is seeking feedback from the food industry (local food manufacturers and importers) on the draft Food (Amendment) Regulations 2015.

Detailed Description

Summary of amendments

The draft Food (Amendment) Regulations 2015 contains trade facilitating measures such as the provision for the use of advantame, a new sweetening agent, in foods under good manufacturing practice, as well as allowing bovine lactoferrin, a new ingredient, in infant formulas, at levels up to 100 mg/100 ml.

The amendments include a requirement that food products labelled as “organic” (or similar terms) must be certified as organic under an inspection and certification system that complies with the Codex Guidelines for the Production, Processing, Labelling and Marketing of Organically Produced Foods, GL 32-1999; or equivalent.

“Veterinary drugs” will be included under the definition for “Incidental constituents” under Regulation 29. In conjunction with this amendment, a definition for “veterinary drugs” (based on Codex definition) will be included in the Food Regulations.

Other changes include the prohibition of the import, sale and advertisement of raw milk for direct human consumption; and provision for the use of the generic term “Modified Starches” for labelling purposes. Editorial amendments will be made to Regulations 9, 12, 30(3) and 38, to update the terms used, as well as to spell out the provisions in a clearer manner.

A detailed description on the proposed changes can be found in ANNEX I.

Request for comments

AVA invites views and comments on the draft Food (Amendment) Regulations 2015. All submissions should be clearly and concisely written, and should provide a reasoned explanation for any proposed revisions.

Submissions should reach AVA no later than 12:00 p.m., 21 December 2015, through mail, or email, to the following addresses:

Mail:
Regulatory Programmes Department
Agri-Food and Veterinary Authority
52 Jurong Gateway Road #14-01
Singapore 608550
Tel: +(65) 6805 2910
Fax: +(65) 6334 1831
(Attention: Mr Cheng Chee Seng)
Email: cheng_chee_seng@ava.gov.sg

Annex I - Consultation on Draft Food (Amendment) Regulations 2015 [PDF, 131 KB]

Summary of Responses - Annex - Comparison Of Proposed Regulations 9, 9A & 9B with Current Regulation 9 of Food Regulations [PDF, 214 KB]