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The Food (Amendment No. 3) Regulations 2020 ("Amendments") came into operation on 31 August 2020. The Amendments aim to align the Food Regulations with international standards by allowing the use of new food additives already permitted in other jurisdictions, extending the use of existing food additives, and updating several food standards.
The introduction of new permissible food additives and extension of existing additives may be welcome news for traders. By updating the Food Regulations' existing provisions to reflect the legal positions and practices of regions with developed food manufacturing sectors like Australia, the United States, and the European Union, it is hoped that the Amendments will facilitate trade by potentially reducing the need to conduct different tests to enter the Singapore market.
Such efforts to standardise food compliance laws appear to form part of the SFA's ongoing commitment to align with international standards, in light of its recent introduction of new maximum residue limits for mercury, bromate and mycotoxins in specific foods, as covered in our August 2020 newsletter here. While traders may wish to make use of the provisions permitting new food additives, they must still ensure that their food products comply with the requirements and conditions laid out in the Food Regulations.
The Food (Amendment No. 3) Regulations 2020 ("Amendments") came into operation on 31 August 2020. The Amendments aim to align the Food Regulations with international standards by allowing the use of new food additives already permitted in other jurisdictions, extending the use of existing food additives, and updating several food standards.
With the implementation of the Amendments, the following new food additives may now be used for certain permitted purposes as set out in the table below.
Three new types of steviol glycosides:
Soy leghemoglobin derived from genetically modified Pichia pastoris
General purpose food additive in meat analogues, up to a level of 0.45% (w/w)
Lutein esters from Tagetes erecta
Alpha, alpha-trehalase (EC 3.2.1.28) produced from genetically modified Trichoderma longibrachiatum containing the alpha, alpha-trehalase gene from Trichoderma longibrachiatum
The Amendments also extend the use of food additives already permitted under the Food Regulations, by either allowing them to be used in new product categories, or by revising the maximum limits established in existing provisions. Broadly,
Finally, the Amendments update three existing food standards in the Food Regulations to bring them in line with international standards. To this end,
The Amendments have been made following assessments from the Joint FAO/WHO Expert Committee on Food Additives ("JECFA") and the Codex Alimentarius Commission ("CAC"), both of which are routinely involved in evaluating additives, contaminants, toxicants and residues of veterinary drugs in food. In its response to feedback received following a public consultation conducted from April to June 2020, the SFA also noted that it has carried out independent assessments to determine the safety of the new additives.
To address concerns over the removal of Regulation 240(2), the SFA has emphasized that the change will neither impact the protection already conferred to Scotch Whisky under the Geographical Indications Act 2014, nor remove the requirement for Scotch Whisky to comply with food safety requirements under the Food Regulations.
The SFA Circular may be assessed here. The full list of changes made by the Amendments to the Food Regulations may be found here.
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