3. Compositional Aspects

Beers & Whisky
Malaysia

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

3.1 Composition Requirements

General Food

The composition requirements of food should follow individual product standard requirements specified in the Food Regulation 1985 [1].

Category

Alcoholic drinks

• Flavor restrictions: refer to each particular standard set for each alcoholic drink in the Food Regulation 1985 [1].
• Alcohol content: more than 2 percent v/v of alcohol
• Tolerance limit for alcohol by volume: to check the specific standards for each alcoholic beverage to see if there are any set tolerance limits for alcohol content specified.
• Order of specific gravity (where applicable): to check the specific standards for the intended alcoholic beverage to see if there are any set of orders of specific gravity specified.

Product

1) Beer

• Flavor restrictions: in Regulation 374 (3) [1], "flavoring" is not included in the list of permitted ingredients. For further information, please refer to Section 3.6 below. 
• Alcohol content: shall contain more than 2 percent v/v of alcohol.
• Tolerance limit for alcohol by volume: no specific requirement is mentioned in the Regulation.
• Order of specific gravity (where applicable): no specific requirement is mentioned in the Regulation.
• For beers: wort concentration, dietary fiber content: no specific requirement mentioned in the Regulation.

2) Whisky

• Flavor restrictions: according to Regulation 381 (2), whisky may contain a permitted flavoring substance. For further information, refer to Section 3.6 below. 
• Alcohol content: it shall contain not less than 37.5 percent v/v of alcohol.
• Tolerance limit for alcohol by volume: no specific requirement is mentioned in the Regulation.
• Order of specific gravity (where applicable): no specific requirement is mentioned in the Regulation.

3.2 Raw Material Requirements

General Food

Raw materials for food products must comply with the specific standards outlined in the regulations for that product (if any).

Category

Alcoholic drinks

Raw materials for alcoholic beverages must comply with the specific product standards outlined in the regulations, if applicable.

Product

1) Beer

Beer shall be the product of the alcoholic fermentation of liquid derived from a mash of malted grain with hops or other harmless vegetable bitter [Regulation 374(1)]. 

2) Whisky

Whisky shall be the spirit produced by the distillation of cereal or cereal products Regulation 381(1). 

3.3 Fortification

General Food

The addition of nutrients to General Food products is voluntary but should comply with any individual product standards specified in the regulations. The permitted added nutrients are defined in Regulation 26[1] as below:

(1) In these Regulations, “added nutrient” includes any mineral, vitamin, amino acid, fatty acid, nucleotide, or other food components which, when added singly or in combination to food, improves the nutritional value of the food. 

(2) The added nutrients specified in Table I to the Twelfth Schedule or with prior written approval of the Director shall be the permitted added nutrient within the meaning of and for the purposes of these Regulations

(3) Except as otherwise provided in these Regulations, permitted added nutrients may be added to any food.

Category

Alcoholic drinks

While regulations do not specifically prohibit the fortification of alcoholic products, in practice, alcoholic beverages are not fortified. If nutrients are added, refer to "General Food" above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above. 

2) Whisky

Same as "Category" (alcoholic drinks) above. 

3.4 Other Permitted Ingredients

General Food

Other permitted ingredients for General Food should follow individual product standards specified in the Regulation, if any.

Category

Alcoholic drinks

Other permitted ingredients for alcoholic drinks should follow individual alcoholic product standards specified in the Regulation.

Product

1) Beer

There are no specific other permitted ingredients specified in the Regulation. 

2) Whisky

There are no specific other permitted ingredients specified in the Regulation. 

3.5 Permitted Additives

General Food

The requirements for permitted additives for General Food follow individual product standards specified in the Regulation if any. The permitted added additives are:

• Additives defined in Regulation 19 Food additive [1]
• Additives authorized by Codex Alimentarius
• Additives authorized in a product in its specific product Regulation.

Category

Alcoholic drinks

Permitted additives for alcoholic drinks follow individual alcoholic product standards specified in the Regulation, if any. 

Product

1) Beer

Additives permitted in Beer are listed in Regulation 374 on Beer. Beer may contain caramel as a coloring substance, ascorbic acid, and not more than 25mg/kg of sulfur dioxide or sulfite as permitted food conditioner. 

2) Whisky

According to Regulation 391 on Whisky, it may contain caramel as a coloring substance and permitted flavoring substance. 

3.6 Permitted Flavors and Colors 

General Food

The requirements for permitted flavors and colors for General Foods follow individual product standards specified in the Regulation, if any. The permitted flavors and colors are defined in Regulation 21 - Coloring Substance, and Regulation 22 - Flavoring Substance [1].

Flavoring

Permitted flavoring substances are as follows:

(a) Substances which are listed in at least one of the following publications: 

1. Generally Recognised As Safe (GRAS) Flavoring Substances published by the Flavor and Extract Manufacturers_’ _Association_ _of the United States (FEMA) contained in the Food Technology, a publication of the Institute of Food Technologists; or 
2. Flavorings, List of Codex Specifications for Food Additives (CAC/MISC 6); or 

(b) Natural flavoring substance either in its raw state or after processing by traditional preparation process including drying, roasting, and fermentation.  

The maximum permitted proportion of certain natural toxicants resulting from the addition of natural flavoring substances into food is specified in Table II of the Eighth Schedule.

The addition of the following substances is prohibited (Table I of Eighth Schedule):

• Cade oil 
• Cocaine 
• Nitrobenzene
• Any other flavoring substance that is injurious or likely to be injurious to health

Category

Alcoholic drinks

The requirement for permitted flavors and colors for alcoholic drinks follows individual alcoholic product standards specified in the Regulation, if any. 

Note: based on verbal communication with authorities, a proposal to allow flavoring in alcoholic beverages is currently under review. However, if approved, it will take 2 to 3 years to be gazetted.

Product

1) Beer

Beer may contain caramel as a coloring substance. There is no permitted flavoring substance allowed for beer.

2) Whisky

According to Regulation 381 (2), whisky may contain a permitted flavoring substance. The addition of permitted flavoring is allowed (please refer to the section on General Foods above for info on permitted flavorings). 

3.7 Permitted Processing Aids 

General Food

Processing aids used in the General Food shall conform to the “Guideline on the safe use of processing aid” (CAC/GL 75) [2].

Category

Alcoholic drinks

Same as "General Foods".

Product

1) Beer

Same as "Category" (alcoholic drinks) above. 

2) Whisky

Same as "Category" (alcoholic drinks) above. 

3.8 Additional Notes 

None.

3.9 References

1. Food Regulations 1985 Update December 2023 (PUA 209_2020) thereunder

https://hq.moh.gov.my/fsq/peraturanperaturan-makanan-1985

2. Guidelines on the safe used of the processing aids

https://hq.moh.gov.my/fsq/processing-aids-bahan-bantuan-pemprosesan