5. Claim Requirements

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5. Claim Requirements

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Beers, RTDs, Whisky
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 Food

Nutrition claim [1]

According to Regulation 8A(3), a 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 claim [2,3]

As of May 2nd, 2024, regulatory control on nutrition labeling, nutrition, and health claims are regulated by the Ministry of Health and the Health Promotion Board. Previously, Singapore referred to the Codex Guidelines for Use of Nutrition and Health Claims for the definition of health 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.

Health claims include:

Reduction of disease risk claims
- Claims relating to the consumption of a food or food constituent, in the content of the total diet, to the reduced risk of developing a disease or health-related condition.
- Example: “A healthful diet rich in nutrient or substance A may reduce the risk of disease D. Food X is high in nutrient or substance A.”
- A list of nutrient-specific diet-related health claims is maintained.

Nutrient function claims
- Nutrition claims that describe the physiological role of the nutrient in growth, development, and normal functions of the body.
- Example: “Nutrient A (naming a physiological role of nutrient A in the body in the maintenance of health and promotion of normal growth and development). Food X is a source of/ high in nutrient A.”
- A list of acceptable nutrient function claims is maintained.

Other function claims
- Claims concerning specific beneficial effects of the consumption of foods or their constituents, in the context of the total diet on normal functions or biological activities of the body and relating to a positive contribution to health or to the improvement of a function or to modifying or preserving health.
- Example: “Substance A (naming the effect of substance A on improving or modifying a physiological function or biological activity associated with health). Food Y contains x grams of substance A.”
- A list of acceptable other function claims is maintained.

5.1.2 List of Prohibited Claims

General Food [1]

1. Based on Regulation 9(1) of the Food Regulations,

False, misleading, or deceptive statement, word, brand, picture, or mark purporting to indicate the nature, stability, quantity, strength, purity, composition, weight, origin, age, effects, or proportion of the food or any ingredients likely to create an erroneous impression regarding the value, merit or safety of the food are not allowed to be used on food labels and advertisements unless otherwise stated.

2. Based on Regulation 9(2) of the Food Regulations,

The use of claims for therapeutic or prophylactic action; claims which could be interpreted as advice of a medical nature from any person; claims that a food will prevent, alleviate, or cure any disease or condition affecting the human body; and claims that health or an improved physical condition may be achieved by consuming any food, is prohibited.

A list of non-exhaustive prohibited claims for food is maintained in the Guide to Nutrition Labeling for Food Products (Singapore), published by the Health Promotion Board [3]. These prohibited claims are claims related to diseases, conditions, and disorders to which no reference may be made, to health or improved physical condition or of medical nature, or misleading statements.

Note: The Food Safety and Security Act (FSSA) [4], with its implementation done in phases and full implementation by 2028, defines more tightly what constitutes to “falsely describe” food compared to the Sale of Food Act (SOFA) [6] which has provisions on false labeling and unsafe or unsuitable food. Section 178 of FSSA defines “falsely describe” as (a) the food is represented as being of a particular composition or nature for which there is an applicable standard and the food does not comply with that standard; (b) any content used on the packaging or in the labeling in or with which the food is packed, labeled or offered for supply would create a false impression as to the composition, effect, nature or origin of the food, in the mind of a reasonable person; (c) the food is not of the composition, effect, nature or origin represented by the manner in which the food is advertised, packed, labeled or offered for supply; and (d) the description of the food conceals the fact that the food is unsafe or unsuitable; all of which are prohibited.]

Category

Alcoholic drinks

Same as "General Food" above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

5.2 Nutritional Claims

5.2.1 Permitted Claims

General Food

Nutrition claims are allowed if 1) the requirements of the Food Regulations (under the Singapore Food Agency) and 2) the nutrient claims guidelines published in “A Guide to Nutrition Labeling” by Singapore’s Health Promotion Board are complied with [3].

1. Food Regulations [1]

Based on Regulation 11 of the Food Regulations,

a. Food that carries claims on the presence of vitamins and/or minerals, including claims relating to “a source of vitamins/minerals”, is required to contain at least one-sixth of the daily allowance as laid down in Regulations 11 Table I for the relevant vitamin or mineral, per reference quantity for that food as laid down in Regulations 11 Table II of the Food Regulations.

b. 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 and mineral.

c. No label shall contain any statement claiming or implying that the article of food is a source of one or more vitamins or minerals if it contains less than 50% of the recommended daily allowance as laid down in Table I unless the recommended daily intake of the food contains not less than 50% of the recommended daily allowance and unless the recommendation is declared on the label.

2. A Guide to Nutrition Labeling [3]

Guidelines for nutrition claims of different nutrients (i.e. energy, protein, carbohydrate, sugar, dietary fiber, total fat, fatty acids, cholesterol, sodium/salt, vitamins/minerals, low glycemic index, and whole grains) are maintained.

Category

Alcoholic drinks

While regulations do not specifically prohibit nutrition claims on alcoholic products, in practice alcoholic beverages do not bear nutritional claims. However, if a nutrition claim is used, it should comply with “General Food” requirements above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

5.2.2 Nutritional Claim Registration

General Food

(a) For nutritional claims that are already permitted for use:

No need to be registered prior to use.

(b) For nutritional claims that are not currently permitted for use:

N/A.

Category

Alcoholic drinks

Same as "General Food" above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

5.3 Health Claims

5.3.1 Permitted Claims

General Food

The following lists of permitted health claims are maintained in the Guide to Nutrition Labeling [3]:

Reduction of disease risk claims
Nutrient function claims
Other function claims

Category

Alcoholic drinks

While regulations do not specifically prohibit health claims on alcoholic products, in practice, alcoholic beverages do not bear health claims. However, if a health claim is used, it should comply with the “General Food” requirements above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

5.3.2 Health Claim Registration

General Food

(a) For health claims that are already permitted for use :

Health claims do not need to be registered prior to use.

(b) For health claims that are not currently permitted for use:

For new health claims, approval would need to be sought from the Health Promotion Board (HPB) [2]. Based on correspondence with the HPB, HPB has taken over the evaluation of health claims since early 2024, which used to be under the purview of the Singapore Food Agency. The approval process, as elaborated by HPB during further correspondence, is as follows:

For nutrient function claim or other function claim:

An application form titled “Application for Use of Health Claims for Food Intended for Sale in Singapore”, requesting information such as applicant information, proposed claim, relevant studies, and supporting documents would need to be filled up for evaluation.
Once HPB ensures that all documents received are in order, the application will be forwarded to an advisory committee for evaluation. Opinions from the committee would be gathered for consideration by HPB on the outcome of the evaluation.
Once approved, the claim would be published and it can be used.
There is no cost involved.
The process would take up to 9 months or longer, from the time the complete set of application documents is received.

For reduction of disease risk claims:

The same application form titled “Application for Use of Health Claims for Food Intended for Sale in Singapore”, requesting information such as applicant information, proposed claim, relevant studies submitted, and supporting documents would need to be filled up for evaluation.
Once HPB ensures that all documents received are in order, the application will be forwarded to an advisory committee for evaluation. Opinions from the committee would be gathered for consideration by HPB on the outcome of the evaluation.
The claim would have to be gazetted in Singapore’s Food Regulations before it can be used.
There is no cost involved.
The process would take up to 9 months or longer from the time the complete set of application documents is received to the approval of the claim by HPB. Thereafter, the gazettal process would take another 6 to 9 months. The whole process would take up to 15 to 18 months.

Category

Alcoholic drinks

Same as "General Food".

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3) Whisky

Same as "Category" (alcoholic drinks) above.

5.4 Other Notes or Requirements for Claims

Other relevant claims regulated by the Singapore Food Agency:

Organic [2]

Products that are specified as organically produced, must be accompanied by a certificate to substantiate that the product 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 its equivalence.

Gluten-free [2]

The Food Regulations do not specify the requirements for use of claims suggesting that a food product is free of gluten (e.g. claims are represented by using words like “gluten-free).

The Singapore Food Agency currently adopts the guidelines and standards established by the international food standards-setting body, Codex Alimentarius Commission, for the use of such claims. Products labeled as “gluten-free” must meet the Standard for Foods for Special Dietary Use for Persons Intolerant to Gluten (CODEX CXS 118-1979) established by the Codex Alimentarius Commission.

# The Food (Amendment) Regulations 2025 [5], which will come into operation on 30 January 2026, amends the Food Regulations, whereby a new regulation 250B is added – defining “Gluten-free and reduced gluten food” as follows :

“gluten-free food” means food that is not or does not contain a cereal (i.e. barley, oat, rye, wheat, a hybridized strain of cereal, a product of cereal) and contains 20mg/kg or less of gluten by weight of the food as sold to the purchaser or that is or contains a cereal but has been processed so that it contains 20 mg/kg or less of gluten by weight of the food as sold to the purchaser.

“reduced gluten food” means food that is or contains a cereal (i.e. barley, oat, rye, wheat, a hybridized strain of cereal, a product of a cereal) but has been processed so that it contains more than 20 mg/kg but less than or equal to 100 mg/kg of gluten by weight of the food as sold to the purchaser.