Consultation on Proposed Amendments to Food Regulations to Delete Standards of Identity

Singapore Food Agency

Consultation Period: 21 Jun 2021 - 20 Aug 2021

Status: Closed - Summary of Responses

Consultation Outcome

RESPONSE TO COMMENTS RECEIVED FROM THE PUBLIC CONSULTATION ON PROPOSED AMENDMENTS TO THE FOOD REGULATIONS TO DELETE STANDARDS OF IDENTITY

The Singapore Food Agency (SFA) initiated a public consultation from 21 June to 20 August 2021 on the proposed amendments to the Food Regulations to delete standards of identity.

Comments were sought from stakeholders (industry associations, local food manufacturers, retailers and importers), as well as interested parties, on the proposed amendments.

At the close of the public consultation exercise, SFA received comments from 18 respondents on the proposed deletion of standards of identity. SFA’s response to the comments received from the 18 respondents are summarised in the ANNEX.

SFA appreciates the time taken by all parties to submit feedback and comments which contribute to the decision-making process. Following this consultation, SFA will review the proposed amendments, taking into consideration the comments received.

SFA would like to encourage all parties to actively participate in future calls for comments.

Detailed Description

Aim

The Singapore Food Agency (SFA) is seeking feedback from the food industry, as well as interested parties, on proposed amendments to the Food Regulations to delete standards of identity. The amendments are planned to come into effect in April 2022.

Background

2 Standards of identity in the Food Regulations (referring to those standards in Regulations 39 to 260) were developed during the 1970s to early 1990s to ensure that food products conform to a certain standard of identity and minimum quality, thereby helping to ensure fair trade.

3 The context and circumstances leading to the promulgation of these standards of identity in the past are different from Singapore's current context. Some of these standards of identity were developed prior to the development of related international standards (namely those of the Codex Alimentarius Commission), as well as the Singapore Standards (developed under the Singapore Standards Council) which have since been established.

4 At present, there is a large variety of food products available in the market to meet different consumer needs and preferences. Many of these food products do not have a standard of identity prescribed in the Food Regulations, for example, breakfast cereals, 3-in-1 powdered beverages, frozen cooked meals etc. Nonetheless, they are still subject to food safety requirements under the Food Regulations and food businesses that import, manufacture and sell such products are responsible for ensuring that they are safe for human consumption.

5 SFA has, from time to time, received requests from the industry, to allow the import/manufacture and sale of food products which do not comply with the quality criteria in the Food Regulations, because of climate, environmental factors, production methods etc. Cases encountered include specific gravity / refractive index / iodine value for edible vegetable oils, milk solids content for milk, milk fat content for processed cheese, among others. The inability to meet quality criteria prescribed in the Food Regulations for these products does not mean that the products are unsafe for consumption. To restrict the import/manufacture and sale of such products would unnecessarily impede trade.

6 As the food industry innovates to produce variations of a product (for e.g., sugar-free kaya, egg-free mayonnaise), having to conform to a fixed standard of identity would stifle their efforts at innovation.

Proposed amendments

7 Recognising that it is in the interest of the food industry to produce food of good quality and to constantly innovate to produce new products to cater to consumer demand, and also to facilitate trade, SFA is proposing an amendment to the Food Regulations to delete the standards of identity in Regulations 39 to 260, except where these continue to be needed for food safety reasons, or to support the policies that have an impact on public health.

8 For the standards of identity that are retained in the Food Regulations, the industry is required to ensure compliance with these standards. For standards of identity that are deleted from the Food Regulations, industry can refer to available international standards (such as those of the Codex Alimentarius Commission) or the Singapore Standards.

9 The proposed deletion of the standards of identity does not affect food safety. All food products imported, manufactured and sold in Singapore must comply with prevailing food safety provisions, such as use of food additives and maximum limits for incidental constituents, as well as relevant labelling requirements. SFA will continue to work with the various stakeholders from farm to fork so that the food imported, produced and sold to the consumer is safe for human consumption.

10 SFA understands that, in the absence of the standards of identity, the industry may face challenges in determining whether a particular food can be added with certain food additives. SFA has plans, in future, to develop a food category system (with associated food category descriptors), to provide clarity to the industry regarding the food additive provisions. The food category system would be based on the Codex General Standard for Food Additives (CODEX STAN 192-1995). The descriptors for each food category will provide information on the types of food products that belong in the category, for e.g. "Yeast-leavened breads and specialty breads include all types of non-sweet bakery products and bread-derived products. E.g.white bread, rye bread, pumpernickel bread, raisin bread, whole wheat bread, pain courant francais, malt bread, hamburger rolls, whole wheat rolls, and milk rolls." SFA will work closely with the industry to develop the food category system with the associated descriptors.

11 The list of standards of identity proposed to be deleted / retained can be found in Annex I. The legal text for the amendments is not available at this time.

Request for comments

12 SFA invites views and comments on the proposed amendments to the Food Regulations to delete / retain the standards of identity as listed in Annex I. Please submit your comments or feedback in the form of the table provided in Annex II. All submissions should be clearly and concisely written and should provide a reasoned explanation for any proposed revisions.

13 Submissions should reach SFA no later than 5:00 p.m., 20 August 2021, through email, to the following addresses: cheng_chee _seng@sfa.gov.sg.

Annex I [PDF, 723 KB]

Annex II [PDF, 32 KB]

FAQs for consultation on Standards of Identity [PDF, 427 KB]