The Agri-Food and Veterinary Authority of Singapore (AVA) initiated a public
consultation on the draft Food (Amendment) Regulations 2018 from 7 December 2017
to 6 February 2018. Concurrently, trading partners and interested parties were notified
via WTO notification G/SPS/N/SGP/60 (4 January to 5 March 2018).
Feedback was sought from stakeholders (local food manufacturers and importers) as
well as trading partners and interested parties, on views and comments with regard to
the proposed amendments.
At the close of the public consultation exercise and WTO notification period, AVA has
received 3 responses: 2 from the industry and 1 from a foreign government. One
industry member indicated agreement with the proposed amendments while the other
industry member requested for clarification on the new provisions for the use of
phylloquinone and menaquinone-7. AVA clarified that, with the proposed amendments,
phylloquinone (a form of vitamin K1) and menaquinone-7 (a form of vitamin K2) will be
listed as permitted nutrient supplements under the Seventh Schedule of the Food
A foreign government requested for the scientific rationale for prohibiting the use of
propyl para-hydroxybenzoate (also known as propyl paraben) in food. AVA explained
that Singapore takes reference from the safety evaluations of food additives conducted
by the Joint FAO/WHO Expert Committee on Food Additives (JECFA). In this case,
JECFA had evaluated the safety of propyl para-hydroxybenzoate and concluded that
it was no longer safe for use as a food additive. Arising from JECFA’s assessment,
the Codex Alimentarius Commission (CAC) had discontinued work on draft provisions
for the use of propyl para-hydroxybenzoate in the Codex General Standard for Food
Additives and also revoked provisions for the use of propyl para-hydroxybenzoate in
relevant Codex commodity standards. Taking reference from the CAC decision,
Singapore had proposed to delete the provisions for the use of propyl parahydroxybenzoate
in food. Our surveillance data also indicates that the preservative is
rarely used in food imported/manufactured and sold in Singapore.
Based on the responses received, we note that the food industry would be able to
comply with future requirements proposed under these amendments.
AVA appreciates the time taken by individuals and organisations to submit feedback
and responses, and would like to encourage all food industry members to actively
participate in future calls for comments.
The Agri-Food and Veterinary Authority (AVA) is seeking feedback from stakeholders (local food manufacturers and importers, as well as interested parties) on the draft Food (Amendment) Regulations 2018, which is targeted to come into effect in the first quarter of 2018.
Summary of amendments
The draft Food (Amendment) Regulations 2018 contains trade facilitating measures, such as provisions for the use of new additives and ingredients in food, as well as the extension of use of existing food additives.
In order to better protect consumers, provisions for the use of two chemical preservatives, propyl para-hydroxybenzoate and sodium propyl para-hydroxybenzoate will be deleted, due to potential negative effects on human health. Maximum residue limits for 6 legacy pesticides will be deleted from the Food Regulations.
A detailed description on the proposed changes can be found in the ANNEX. The legal text of the amendments can be downloaded from AVA’s website at:
http://www.ava.gov.sg/legislation (select “Sale of Food Act”, then click on “Draft Food (Amendment) Regulations 2018)
Request for comments
AVA invites views and comments on the draft Food (Amendment) Regulations 2018. 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 6:00 p.m., 6 February 2018, through mail, or email, to the following addresses:
Regulatory Programmes Department
Agri-Food and Veterinary Authority
52 Jurong Gateway Road #14-01
Tel: +(65) 6805 2931
Fax: +(65) 6334 1831
(Attention: Mr Tay Geng Yu / Mr Cheng Chee Seng)
PROPOSED AMENDMENTS TO THE FOOD REGULATIONS
(A) TO ALLOW THE USE OF NEW FOOD ADDITIVES AND INGREDIENTS
1. Partially hydrolysed lecithin (INS 322(ii)) and amidated pectin (INS 440), will be included in the Sixth Schedule as permitted emulsifiers/stabilisers, and allowed for use in food under good manufacturing practice. Both of these emulsifiers/stabilisers are permitted for use in food by the authorities of major developed countries, including the European Union, the United States, Australia, and New Zealand.
2. Three new nutrient supplements will be included under the Seventh Schedule. Calcium L-methylfolate will be listed as a permitted source of folate, which is one of the B vitamins. New provisions for the use of phylloquinone (a form of vitamin K1) and menaquinone-7 (a form of vitamin K2) will also be included.
3. Two new ingredients, namely 2’-fucosyllactose (2’-FL) and Lacto-N-neotetraose (LNnT), will be permitted for use in infant formula, at levels up to 120 mg and 60 mg respectively per 100 ml. Both ingredients have been assessed to be safe for use in infant formula, follow-on formula, and milk-based drinks for young children by the European Food Safety Authority. The United States Food and Drug Administration has no objections to industries’ conclusions that these ingredients are Generally Recognised as Safe (GRAS) for use in infant and toddler foods.
(B) TO EXTEND THE USE OF EXISTING FOOD ADDITIVES TO ADDITIONAL FOOD CATEGORIES
1. Benzoic acid (and its sodium and potassium salts) (INS 210, 211 and 212) and sorbic acid (and its sodium, potassium and calcium salts) (INS 200, 201, 202 and 203) will be allowed in a new food category “Semi-preserved caviar and other fish roe products” at levels up to 2000 ppm and 1000 ppm respectively. Internationally, the use of benzoates and sorbates in fish roe (including caviar) has been endorsed by the Codex Alimentarius Commission and is also permitted in the EU, Australia and New Zealand.
2. A list of sodium, calcium and potassium salts of phosphoric acids, currently permitted for use in food as either Class I chemical preservatives, sequestrants, nutrient supplements and/or general purpose food additives, will also be included under the Sixth Schedule as permitted emulsifiers and/or stabilisers. The use of these salts as emulsifiers are recognised by Codex and/or the Joint FAO-WHO Expert Committee on Food Additives (JECFA). Following this amendment, the industry will be accorded greater flexibility in terms of using the generic term “emulsifiers” to declare the use of phosphates under the statement of ingredients on the product label. These phosphate salts are:
• Sodium dihydrogen phosphate (INS 339(i))
• Disodium hydrogen phosphate (INS 339(ii))
• Trisodium phosphate (INS 339(iii))
• Potassium dihydrogen phosphate (INS 340(i))
• Dipotassium hydrogen phosphate (INS 340(ii))
• Tripotassium phosphate (INS 340(iii))
• Tricalcium phosphate (INS 341(iii))
• Disodium diphosphate (INS 450(i))
• Trisodium diphosphate (INS 450(ii))
• Tetrasodium diphosphate (INS 450(iii))
• Tetrapotassium diphosphate (INS 450(v))
• Dicalcium diphosphate (INS 450(vi))
• Calcium dihydrogen diphosphate (INS 450(vii))
• Pentasodium triphosphate (INS 451(i))
• Pentapotassium triphosphate (INS 451(ii))
• Sodium polyphosphate (INS 452(i))
• Potassium polyphosphate (INS 452(ii))
• Calcium polyphosphate (INS 452(iv))
3. Sucralose (INS 955), a sweetening agent, will be permitted for use in a new food category “cheese-based preparations” at levels up to 500 ppm. This category includes products made primarily of cheese, blended together with other ingredients. Internationally, the use of sucralose in this type of food is permitted in the US, Australia and New Zealand.
(C) DELETION OF ADDITIVE PROVISIONS
Propyl para-hydroxybenzoate (INS 216) and sodium propyl para-hydroxybenzoate (INS 217) are Class II chemical preservatives currently permitted for use in food categories specified under Part I of the Fourth Schedule, up to the maximum levels specified therein. AVA has reviewed the safety of use of INS 216 and INS 217 based on the latest scientific evidence. In view of the potential for adverse effects on human health and the availability of alternative preservatives, these two preservatives will no longer be allowed for use in food. Internationally, INS 216 and INS 217 are not permitted for use in food in a number of countries, such as Australia, New Zealand, the European Union, Hong Kong, Malaysia and Indonesia. Local surveillance data also indicates that the two preservatives are rarely used in food imported/manufactured and sold in Singapore.
AVA had conducted a public consultation exercise between April and June 2016 to seek the food industry’s feedback on the proposed ban on INS 216 and 217, and its impact on trade. It was noted that the industry was ready for the implementation of the ban, given that majority of feedback providers indicated that these additives were not used in their food products, while a number expressed support for the proposed ban.
(D) ADOPTION OF EXTRANEOUS MAXIMUM RESIDUE LIMITS FOR PESTICIDES
6 legacy pesticides, (Aldrin, DDT, Dieldrin, Endrin, Heptachlor and Lindane) and their corresponding maximum residue limits (MRLs) will be deleted from the Ninth Schedule. These 6 pesticides are legacy organo-chlorinated pesticides considered as persistent organic pollutants. Internationally, their usage has been phased out in 2004 under the Stockholm Convention, an international treaty that aims to protect human health by addressing global chemical pollution from persistent organic pollutants. As such, their presence in food is due to potential uptake arising from historical use, and not from direct application on crops. Local surveillance data shows that these pesticides are rarely detected in food sold in Singapore. With the deletion of these MRLs from the Food Regulations, by default extraneous maximum residue limits (EMRLs) established for these 6 pesticides by the Codex Alimentarius Commission will apply to food imported/manufactured and sold in Singapore.