5. Claim Requirements

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5. Claim Requirements

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Nutritional Milk Powder and UHT Milk
Singapore

This section provides information on the definition of different types of claims and any restrictions or allowance of claims as well as claim registration processes.

5.1 Overview of Claims

5.1.1 Types & Definitions

General Foods [1]

“Nutrition claim” means a representation that suggests or implies that a food has a nutritive property, whether general or specific and whether expressed affirmatively or negatively and includes reference to energy; salt, sodium or potassium; amino acids, carbohydrates, cholesterol, fats, fatty acids, fiber, protein, starch or sugars; vitamins or minerals; or any other nutrients.

Health Claims - Nutrient function claims and other function claims
"Health claim" means any representation that states, suggests, or implies that a relationship exists between a food or a constituent of that food and health. It includes nutrient function claims, other function claims, and reduction of disease risk claims.

Health Claims - Nutrient-specific diet-related health claims.

Product

1) Milk Powder

Same as "General Foods" above.

2) Ultra Heat Treated Milk

Same as "General Foods" above.

5.1.2 List of Prohibited Claims

General Foods [1]

The product should not carry any claims or suggestion whether in the form of a statement, word, brand, picture, or mark purporting to indicate the nature, stability, quantity, strength, purity, composition, weight, origin, age, effects, or proportion of food or its ingredients that is false, misleading or deceptive, or is likely to create an erroneous impression regarding the value, merit or safety of the food.

Product label must not include any claim or suggestion in relation to food that implies that the food has therapeutic or prophylactic action; the food will prevent, alleviate, or cure any disease or condition affecting the human body; or that health or an improved physical condition may be achieved by consuming the food.

Product labels must not include any claim or suggestion that may be interpreted as advice of a medical nature from any person whatsoever.

No written, pictorial, or other descriptive matter appearing on or attached to, or supplied or displayed with food is to include the word “pure”, or any word of the same significance, in relation to food unless the food is free from other added substances or is of the composition, strength, and quality required under these Regulations.

A label must not include the word “organic”, or any word of the same significance, in relation to food unless the food is certified as organic under an inspection and certification system that complies with section 6.3 of the Codex Guidelines for the Production, Processing, Labeling, and Marketing of Organically Produced Foods, GL 32-1999; or that substantially complies with the Codex Guidelines mentioned and is acceptable to the Director-General as being a suitable system for the certification of organic food.

Product

1) Milk Powder

There are no prohibited claims specific to milk powder. This product should comply with the requirements described under "General Foods" above.

2) Ultra Heat Treated Milk

There are no prohibited claims specific to UHT milk. This product should comply with the requirements described under "General Foods" above.

5.2 Nutritional Claims

5.2.1 Permitted Claims

General Foods

Foods that carry claims on the presence of vitamins or minerals, including claims relating to “a source of" are required to contain at least one-sixth of the daily allowance for the relevant vitamin or mineral per reference quantity for that food (i.e. per 60g for milk powder (full cream or skimmed) and food containing not less than 51% of milk powder; or per 200ml for liquid food in the case of UHT milk).
Foods that claim to be an excellent source (including words like “good”, “rich” and “high”) of vitamins or minerals are required to contain at least 50% of the daily allowance for the relevant vitamin or mineral per reference quantity for that food.
A label can claim or suggest that a food is a source of or an excellent source of protein provided that the label states information of daily serving suggestion, nutrition panel and the protein consumed is at least 10 g per day. Food is a source of protein if at least 12% by weight of the calorie yield of the food is derived from protein. Food is an excellent source of protein if at least 20% by weight of the calorie yield of the food is derived from protein.

Product

1) Milk Powder

There are no requirements specific to milk powder. This product should comply with the requirements of "General Foods" above.

2) Ultra Heat Treated Milk

There are no requirements specific to UHT milk. This product should comply with the requirements of "General Foods" above.

5.2.2 Nutritional Claim Registration

General Foods

No registration is required. Food products for sale in Singapore carrying claims on the presence of vitamins and minerals listed under Table 1 of Regulation 11 under the Food Regulations, must meet the respective criteria stipulated under the said regulation [1].

For claims on the presence of vitamins and minerals that are not listed under Table 1 of Regulation 11 under the Food Regulations [5], reference to the criteria published in the following Codex guidelines can be applied:

Codex Guidelines for Use of Nutrition and Health Claims (CXG 23-1997) [6]
Codex Guidelines on Nutrition Labeling (CXG 2-1985) [7]

Product

1) Milk Powder

There are no requirements specific to milk powder. It should comply with Section 5.2.2 - "General Foods" - above.

2) Ultra Heat Treated Milk

There are no requirements specific to UHT milk. It should comply with Section 5.2.2 - "General Foods" - above.

5.3 Health Claims

5.3.1 Permitted Claims

General Foods [1,2,3]

There are allowed nutrient function claims and other health claims and their criteria stipulated in the “Guide to Food Labeling and Advertisements” shall be complied with. Nutrient-specific diet-related health claims are set out in the Fourteenth Schedule of the Food Regulations and may be made if the food meets the corresponding criteria per reference quantity of food, and is approved by the Health Promotion Board (HPB) to carry the Healthier Choice Symbol (HCS).

Product

1) Milk Powder [1]

For milk powder, allowed nutrient function claims and other health claims criteria shall be per reference quantity of 60g milk powder (full cream or skimmed) and food containing not less than 51% milk powder. They must not be truncated or reworded to deviate from the original intended meaning. These claims are permitted as they are about essential nutrients that have established their recommended intakes and/or are of nutritional importance; there is enough generally accepted scientific evidence to prove the suggested function or role of the nutrient as claimed; the claim enables the public to understand the information provided and its significance to their overall daily diet; the claim does not state or imply that the nutrient is for prevention or treatment of a disease.

Health Claims - Nutrient-specific diet-related health claims: The health claims set out in the Fourteenth Schedule may be made if the food meets the corresponding criteria per reference quantity of 60g milk powder (full cream or skimmed) and food containing not less than 51% of milk powder, and is approved by the Health Promotion Board (HPB) to carry the Healthier Choice Symbol (HCS) for dried milk powder. Refer to HCS Nutrient Guidelines [3] for details.

2) Ultra Heat Treated Milk [1]

For UHT milk, allowed nutrient function claims and other health claims criteria shall be per reference quantity of 200ml liquid food. They must not be truncated or reworded to deviate from the original intended meaning. These claims are permitted as they are about essential nutrients that have established their recommended intakes and/or are of nutritional importance; there is enough generally accepted scientific evidence to prove the suggested function or role of the nutrient as claimed; the claim enables the public to understand the information provided and its significance to their overall daily diet; the claim does not state or imply that the nutrient is for prevention or treatment of a disease.

Health Claims - Nutrient-specific diet-related health claims: The health claims set out in the Fourteenth Schedule may be made if the food meets the corresponding criteria per reference quantity of 200ml liquid food and is approved by the Health Promotion Board (HPB) to carry the Healthier Choice Symbol (HCS) for liquid milk (plain or flavored). Refer to HCS Nutrient Guidelines [3] for details.

5.3.2 Health Claim Registration

General Foods

Registration is not required for health claims that are already permitted for use.

Applicants who wish to apply for a new health claim (except disease risk reduction claims) on their food product, may submit the completed application form attached with the relevant scientific papers for review. The application form can be downloaded from https://www.sfa.gov.sg/docs/default-source/e-service/food/applicationforuseofnewhealthclaimsforfoodintendedforsaleinsingapore-v1-0.

The Application shall be submitted to the Health Promotion Board through the Singapore Food Agency (SFA). The scientific evaluation of the new health claim would be conducted by the Advisory Committee on Evaluation of Health Claims. The Committee comprises members from academia and relevant public agencies.

Applications for use of new health claims (except disease risk reduction claims) should include the following information [4]:

name and address of the applicant;
identity of the nutrient, food constituent, food or food category, in respect of which the health claim is to be made and its characteristics;
a copy of independent peer-reviewed reports of human intervention studies (at least 5 but not more than 10, and preferably published in the last 10 years), which have been carried out regarding the health claim;
where available, the official statements by recognized expert scientific bodies (for example, World Health Organization and food authorities of major developed countries) that have been verified and validated over time regarding the health claim to be made;
a proposal for the wording of the health claim for which the application is intended, and the specific conditions for use;
where appropriate, an indication of the information that should be regarded as proprietary accompanied by verifiable justification; and
a summary of the application.

No administration fee is mentioned by the regulation.

Upon receiving a new health claim application, the secretariat would conduct a preliminary screening to ensure that all documents received are in order, before forwarding to the Committee for evaluation. Subsequently, the opinions from the Committee will be gathered for consideration on the outcome of the evaluation. The evaluation process would take up to 9 months or longer, from the time the complete application documents are received from the applicant, depending on the complexity of the application.

Following that, claims of nutrient function in nature (i.e. describes the physiological role of nutrients in growth, development and normal functions of the body), will be published in the Guide to Food Labeling and Advertisements, upon approval. However, claims that suggest an improvement in health and physical condition, or prevention of disease would have to be gazetted in the Singapore Food Regulations. The gazettal process would take another 6 to 9 months.

Product

1) Milk Powder

There are no requirements specific to milk powder. This product should comply with the Health Claim Registration requirements described under "General Foods" above.

2. Ultra Heat Treated Milk

There are no requirements specific to UHT milk. This product should comply with the Health Claim Registration requirements described under "General Foods" above.

5.4 Other Notes or Requirements for Claims

General Foods [1]

No claim based on the presence of a vitamin or a mineral or implying the presence of a vitamin or a mineral in a food shall be made on the label unless the reference quantity for that food as laid down in Table II contains at least one-sixth of the daily allowance as laid down in Table I for the relevant vitamin or mineral.
No label shall claim that any article of food is enriched, fortified, ennobled, vitaminized or in any way imply that the article is an excellent source of one or more vitamins or minerals unless the reference quantity for that food as laid down in Table II contains not less than 50% of the daily allowance as laid down in Table I for the relevant vitamin or mineral.
Referring to Table II Regulation 11, the reference quantity for the food is 60 g applying for milk powder (full cream or skimmed) and food containing not less than 51% milk powder, or 200ml applying for liquid food not specified in the case of UHT milk.

Product

1) Milk Powder

Same as "General Foods" above.

2) Ultra Heat Treated Milk

Same as "General Foods" above.