FOOD ADDITIVE & SWEETENING LABELLING

(NUR LIYANA BT MOHAMAD NIZAR)

FOOD SAFETY AND QUALITY DIVISION
MINISTRY OF HEALTH MALAYSIA
 FOOD REGULATIONS 1985
PART I PART VII
PRELIMINARY INCIDENTAL CONSTITUENT
PART II
WARRANTY PART VIII
PART III STANDARDS AND PARTICULAR
PROCEDURE FOR TAKING LABELLING REQUIREMENTS FOR FOOD
SAMPLES
PART IV PART IX
LABELLING USE OF WATER, ICE OR STEAM
PART V
FOOD ADDITIVE AND NUTRIENT
SUPPLEMENT PART X
MISCELLANEOUS
PART VI
PACKAGES FOR FOOD
 YOUR LOGO

To understand the labelling

YOUR
LOGO requirements for food additive
and sweetening substances
under Malaysia Food
Regulations 1985.
 TO UNDERSTAND THE
TO UNDERSTAND THE REQUIREMENTS FOR
REASONS WHY FOOD FOOD ADDITIVE
PROVISIONS
ADDITIVES ARE USED

TO IDENTIFY WHAT TO UNDERSTAND

ARE THE FOOD THE DIFFERENT
ADDITIVE ROLES OF FOOD
ADDITIVE IN FOOD
 WHY FOOD ADDITIVES ARE USED
Preservation and Safety of the product
Enhanced appearance, flavour or texture product
Essential for certain product or processing
Maintain freshness, can reduce food spoilage
 FOOD ADDITIVE
REG 19 REG 20
Food Additive Preservatives
01 04
REG 20A REG 21
Antimicrobial Agent Colouring Substance
02 05
REG 22 REG 23
Flavouring Substance Flavour Enhancer
03 06
REG 24 REG 25
Antioxidant Food Conditioner
 REG. 19. FOOD ADDITIVE
“FOOD ADDITIVE” – any SAFE substance that is intentionally
added to food in SMALL quantities to affect the food’s

QUALITY
TEXTURE
APPEARANCE
ODOUR
TASTE
ALKALINITY OR ACIDITY
TO SERVE ANY FUNCTION.
 REG. 20 PRESERVATIVE

 Definition
Any substance that when added to food is capable of
inhibiting, retarding or arresting the process of
decomposition, fermentation, or acidification of such food.

 Refer to Sixth Schedule

Preservatives aim to:

Prevent the growth of micro-organisms which could cause

Spoilage and lead to food poisoning;
Extend the shelf-life of products, so that they can be distributed and
sold to the consumer with a longer shelf-life.

For example, bacon, ham, corned beef and other ‘cured’ meats are often
treated with nitrite and nitrate during the curing process.
REG. 20A ANTIMICROBIAL AGENT

 Definition
Any substance used to preserve food by preventing the
growth of microorganisms and subsequent spoilage or to
sterilize polymeric food-contact surfaces.

 Refer to Sixth (A) Schedule

 REG. 21 COLOURING SUBSTANCE

 Definition
Any substance that when added to food is capable of
imparting colour to the food and includes colouring
preparation.

 Refer to Seventh Schedule

Colours aim to:

Restore colour lost Ensure that each Reinforces colour Give colour to foods which
during processing or batch produced is already in foods, e.g. otherwise would be
storage, identical in appearance Enhance the colourless (e.g soft drinks)
or does not appear yellowness of a and so make them more
‘off custard attractive.
REG. 22 FLAVOURING SUBSTANCE

“Synthetic flavouring” :
“Natural flavouring” : any chemically-defined
any flavouring substance obtained by substance by chemical
 physical

vs
synthesis with flavouring
 enzymatic or properties
 microbiological processes

 Refer to Eighth Schedule

 REG. 23 FLAVOUR ENHANCER

 Definition
Any substance that, when added to food, is capable of
enhancing or improving the flavour of that food

 Refer to Ninth Schedule

REG. 24 ANTIOXIDANT

 Definition
Any substance that, when added to food, is capable of
delaying or retarding the development in food of rancidity or
other deterioration due to oxidation.

 Refer to Tenth Schedule

 Antioxidants aim to

Prevent food containing fat or oil For example, vitamin C, also

from going rancid due to oxidation, known as ascorbic acid is one of
i.e. developing an unpleasant odour or the most widely used antioxidants.
flavour;

Prevent the browning of cut fruit,

vegetables and fruit juices (and so
increase shelf life and appearance).
 REG. 25 FOOD CONDITIONER
 Definition
Any substance that is added to food for a technological purpose
to obtain the desired food.
 Refer to Eleven Schedule
 SWEETENERS

Reg 118A
Reg 118B 01 Stevia extract
Enzymatically modified 02
stevia Reg 132A
03 Artificial sweetening
Reg 133 substance
04
Non-nutritive sweetening
substance 05 Reg 134
Aspartame, glycerol and
sorbitol
 Sweeteners Include:

 INTENSE SWEETENERS
e.g. saccharin, have a sweetness many times that of sugar and
therefore are used in small amounts, e.g. in diet foods, soft
drinks, sweetening tablets;

 BULK SWEETENERS
e.g. sorbitol, have a similar sweetness to sugar and are used at
similar levels
 Sweetening Other Sweetening
Non-nutritive Sweetening
Substances Substance Substances:

SACCHARIN GLYCEROL

SODIUM SACCHARIN ISOMALT

NEOTAME
STEVIA EXTRACT MALTITOL

ACESULFAME
POTASSIUM MANNITOL
Artificial Sweetening
Substances
XYLITOL
ASPARTAME
 New requirement

 19 (2) No person shall import, manufacture, advertise for sale or sell or introduce into or
on any food-

a) any food additive other than a permitted food additive;

b) any permitted food additive which does not comply with

(i) the standard prescribed in these Regulations;

(ii) the Codex Alimentarius standards; or
c) any food additive other than food additive which has been approved by the Director in
writing.

(3) Notwithstanding subregulation (2), the addition to food is prohibited except as

otherwise permitted by these Regulations, permitted under the Codex Alimentarius or
with prior written approval of the Director.
MECHANISM
FOOD COMMODITY UNDER FOOD REGULATIONS 1985

27
 REFER GARIS RUJUKAN SILANG / CROSS REFERENCE
GUIDELINE

CROSS
REFERENCE
Guidelines can be downloaded via fsq website
http://fsq.moh.gov.my/v6/xs/page.php?id=194
 CHOOSE FOOD CATEGORIES (GSFA)

GSFA
List of food List of food
Definition of Principles for
additives and category and
food additive the use of food
its maximum description
additives
use levels
GSFA can be downloaded via Codex website at:
http://www.fao.org/fao-who-codexalimentarius/codex-texts/list-standards/en
(Appendix 2)
 CHOOSE COMMODITY STANDARD (CCS)

DESCRIPTION

LIST OF FOOD
QUALITY
ADDITIVES WHICH CODEX SPECIFICATIONS
MAY BE USED COMMODITY
STANDARD
(CCS)
PACKAGING AND
LABELLING
REQUIREMENTS.
CONTAMINATION
PROVISIONS

CCS can be downloaded via Codex website at:

http://www.fao.org/fao-who-codexalimentarius/codex-texts/list-standards/en/ (Appendix 3)
 MAXIMUM PERMITTED LEVEL

Under Regulation 19, permitted food additives which can be

added into food for sale in Malaysia are:

FOOD GSFA CCS

REGULATION 1985
 Example:
Flour : benzoyl peroxide

a b c
FR 1985 GSFA CCS

Category/ Reg. 42 FC 6.2.1 CCS Wheat Flour

Standard
Max. Level 60 mg/kg 75 mg/kg 60 mg/kg
(Sixth Schedule)
Allowed or not?

Therefore, the maximum permitted level

for benzoyl peroxide in flour is 75mg/kg.
Example:
Milk Shake Powder: sorbic acid

a b c
FR 1985 GSFA CCS

Category/ Reg. 354 FC 14.1.4.3

Standard (notes 17 &
127)
Max. Level 350 mg/kg

Allowed or not?

Therefore, the maximum permitted level

for sorbic acid is 350 mg/kg.
Example:
Fish snack: benzoic acid

a b c
FR 1985 GSFA CCS

Category/ Reg. 168 FC 15.3 -

Standard
Max. Level - - -

Allowed or not?

Therefore, benzoic acid is NOT PERMITTED in kerepok ikan.

LABELLING FOR FOOD ADDITIVE

36
 LABELLING REQUIREMENT
FOR FOOD ADDITIVES WHEN SOLD AS SUCH

When food The words "(state the chemical name of the

additive is imported, food additive) as permitted
manufactured, (state the type of food additive);
advertised for sale
or sold, there shall A statement giving direction for its use
be written on label:

**For colouring substance or flavouring substance it shall be sufficient to state the

common name
LABELLING REQUIREMENT FOR FOOD ADDITIVES WHEN
ADDED INTO FOOD
Regulation 11 (1)(g) :
When food
additive have “contains permitted
been added to (state the type of the relevant food additive-
any food product, preservative, colour, flavouring, antioxidant)”
a statement
below shall be The statement usually appear immediately
labelled: below the list of ingredients of such food.
 EXAMPLE:

Ingredients:
Water, Glucose, Kacip Fatimah Extract, Date Extract
and Lempoyang Extract

Contains permitted colouring and

flavouring substance.

This product has been added with allura

red and strawberry flavour
 Flavour Enhancer - Regulation 23(4) :
When a permitted flavour enhancer has been added
to any food there shall be written in the label :

“contains
(state the chemical name of the flavour enhancer)as permitted flavour
enhancer”

“contains monosodium
Ingredients in Product A: glutamate as permitted
Starch, wheat flour, prawn, sugar, flavour enhancer”
rice flour and monosodium
glutamate “contains permitted flavour
enhancer”
 Food Conditioner - Regulation 25 (6):

When a permitted food conditioner has been added

to any food, there shall be written in the label:
“contains (state the class name of the food conditioner) as permitted food
conditioner”

“contains acidity regulator

Ingredients in Product B: as permitted food
Apple powder, dextrose conditioner”
monohydrate, maca
powder, tea extract and “contains permitted food
acetic acid conditioner”
 LABELLING & WARNING
STATEMENT FOR SWEETENER

42
 LABELLING FOR ARTIFICIAL SWEETENING
SUBSTANCE PREPARATIONS
“NOT RECOMMENDED FOR
REG. 132A (6) CHILDREN EXCEPT ON MEDICAL
ADVICE”,
Concentration except where the artificial sweetening
statement: substance preparation contains
aspartame only
Tablets:mg per tablet
“ARTIFICIAL SWEETENING “NOT RECOMMENDED FOR
SUBSTANCE” PHENYLKETONURICS” or
followed by the names of “UNSUITABLE FOR
PHENYLKETONURICS”
the artificial sweetening . where the artificial sweetening
substances in substance preparation contains
not less than 10 point aspartame/neotame.
lettering Equivalence sweetness
. vs energy: “It should be taken only
Aspartame: Low calorie on the advice of a
and contains sweetness physician””.
of more than 200 times
sugar
 ADDITIONAL LABELLING REQUIREMENT FOR
CERTAIN FOOD ADDITIVES
NEOTAME/ MANNITOL/
ASPARTAME SORBITOL Food Conditioner -
“UNSUITABLE FOR “EXCESSIVE USE CAN Regulation 25 (5)
Food Preservative - PHENYLKETONURICS” HAVE LAXATIVE
Regulation 20 (6) EFFECT” Where any food is added
added with 25 g per 100
g polydextrose or more
When sulphite or sulphur
polydextrose there
dioxide has been added
into shall be written in the
food more than 10 label:
“Sensitive individuals may
mg/kg, there shall be experience a laxative effect
written in the label : from the excessive
“Contains sulphur consumption of food
dioxide” containing polydextrose”
 NEW LABELLING REQUIREMENT
FOR FOOD ADDITIVES WHEN SOLD AS
SUCH

46
 Enforced on 22 July 2022

19 (6) There shall be written in the label on a package containing food additive
imported, manufactured, advertised for sale or sold-

(a) the words “(state the chemical name of the food additive or the International
Numbering System (INS) for Food Additive number)) as permitted (state the type
of food additive; provided that in the case of flavouring substances it shall be
sufficient to state the common name or the appropriate designation of that food
additive in place of the chemical name.”; and

(b) a statement giving direction for its use; and

(c) the words ‘For Food Use’ or any other words of the same significance in
close proximity with the name of food additive or International Numbering
System (INS) for Food Additive number .
47
 LABELLING REQUIREMENT
FOR FOOD ADDITIVES WHEN SOLD AS SUCH

For Food Use A statement giving

,

03 direction for its use

The words "(state the 02

chemical name of the
food additive or the
01
International Numbering
REG. 19 (6)
System) as permitted
(state the type of food
additive)

**For flavouring substance it shall be sufficient to state the common name

 EXAMPLE
Tartrazine as permitted colouring substances
‘For Food Use’

or

INS 102 as permitted colouring substances

‘For Food Use’

Mix 1 drop with 1 liter Water

49
NEW LABELLING REQUIREMENT FOR
FOOD ADDITIVES
WHEN ADDED INTO FOOD

50
 Enforced on 22 July 2022
11 (1) Every package containing food for sale shall, unless otherwise provided in these Regulations, bear
on it a label containing the following particulars, namely –

(g) where the food contains food additive —

(i)_with the International Numbering System (INS) for food additive number, a statement of the
functional class of the relevant food additive followed by the name of the food additive or INS
number in brackets; or

(ii) without the International Numbering System (INS) for food additive number, only a statement of
the functional class and the name of the food additive;

(ga) where the food contains food additive with more than one functional class, a statement of one
functional class only;”;

2A) Notwithstanding paragraph (1)(g), where a food additive is a flavouring substance, only the
functional class shall be stated.
 LABELLING REQUIREMENT FOR FOOD ADDITIVES
WHEN ADDED INTO FOOD
REG.11 (1)(g)(i)&(ii),(ga),(2A)

with the International without the

Numbering System International
(INS) for food additive, a Numbering System
statement: For food products Where the food
(INS) for food additive,
containing food additive additive is a flavouring
“(Functional class of with more than one substance, only the
a statement:
food additive followed by functional classes, a functional class shall “(Functional class of
the name of the food statement of one be stated food additive followed
additive or INS number functional class only by the name of the food
in brackets)” additive)”
With the International Numbering System (INS) for food additive, a
statement:
“(Functional class of food additive followed by the name of the
food additive or INS number in brackets)”

Option 1
Ingredients:
Whole wheat flour, water, vital wheat gluten, vegetable fat,
sugar, yeast, salt, dough, vitamins and minerals,
preservatives ( INS 282)

Option 2
Ingredients:
Whole wheat flour, water, vital wheat gluten, vegetable fat,
sugar, yeast, salt, dough, vitamins and minerals,
preservatives (Calcium propionate)
 For food products containing food additive with more than one
functional classes,
a statement of one functional class only

Option 1
Ingredients:
Whole wheat flour, water, vital wheat gluten, vegetable fat,
Silicon dioxide
sugar, yeast, salt, dough, vitamins and minerals, Anticaking
agent ( INS 551) or Antifoaming agent ( INS 551)
Function:
Anticaking agent Option 2
Antifoaming agent Ingredients:
Whole wheat flour, water, vital wheat gluten, vegetable fat,
sugar, yeast, salt, dough, vitamins and minerals,
Anticaking agent (Silicon dioxide) or Antifoaming
agent (Silicon dioxide)
Where the food additive is a flavouring substance,
only the functional class shall be stated

Ingredients:
Whole wheat flour, water, vital wheat gluten,
vegetable fat, sugar, yeast, salt, dough, vitamins
and minerals, Flavoring substance
Without the International Numbering System (INS) for food additive, a
statement:
“(Functional class of food additive followed by the name of the
food additive)”

Ingredients:
Whole wheat flour, water, vital wheat gluten,
vegetable fat, sugar, yeast, salt, dough, vitamins
and minerals, Flavour Enhancer (Yeast Extract)
INS NUMBER VERSUS
E NUMBER

57
 INS Number E Number

INS127 Erythrosine E127 Erythrosine

INS129 Allura Red AC E129 Allura Red AC
INS 131 Patent Blue V E131 Patent Blue V

INS Number and E number are arranged in group to make it easier to

identify. For example:
•E/ INS number 100 – 199 : Colouring substance
•E/ INS number 200 – 299 : Preservative
•E/INS number 400 – 499 : Stabilizer/ anticaking / thickener/ emulsifier
•E/ INS number 600 – 699 : Flavour enhancer
Nur Liyana Bt Mohamad Nizar
Senior Assistant Director
Office no: 03-8885 0797 ext 4057
emel:norhidayah@moh.gov.my

Food Safety And Quality Division

Ministry Of Health Malaysia
International Food Safety Training Centre (IFSTC) Malaysia
Food Safety and Quality Division
Ministry of Health Malaysia
Level 4, Menara Prisma, Precint 3, PUTRAJAYA

03-8885 0797(ext.) 4032/4301

03-8885 0798
ifstc@moh.gov.my