AO 2026-0011 for Flavour Buyers: Carry-Over, JECFA Specifications and the CPR Transition

Administrative Order No. 2026-0011, dated 2 July 2026, adopts the Codex General Standard for Food Additives (GSFA) in the Philippines. Section IX repeals specified earlier issuances, including AO 88-A s. 1984 and Bureau Circular 2006-016, together with other related issuances inconsistent with or contrary to the order. For a flavour buyer it matters in four places: the routes for flavouring substances (Section VI.D), purity specifications (Section VI.F), carry-over of additives from a flavour into your food (Sections VI.G to VI.I), and the move of existing product registrations to the new rules (Section VII). Section XI provides for effectivity after fifteen days following publication in the Official Gazette or a newspaper of general circulation and filing with the Office of the National Administrative Register of the UP Law Center. Confirm the publication, filing and resulting effectivity dates with the FDA before planning around them.

What the order covers

Section III applies the order "to all manufacturers, distributors (importer, exporter, wholesaler), and traders of food products, including food additives." Section V.A provides that "The latest Codex GSFA, and its future revisions/amendments/updates, shall be adopted automatically by the FDA", and Section V.E adopts the food category system in Annex B of the GSFA. Where a product has an FDA-adopted Philippine National Standard, Section VI.B requires additives and their maximum levels to follow the latest GSFA under the product's food category, and additives in that standard that are not listed in the latest GSFA "shall not be allowed."

Flavourings and flavouring substances

Section IV.K defines flavourings as substances added to food "to impart, modify, or enhance the flavor of food", and says they "may be of natural, nature-identical, or artificial origin." Flavour enhancers are excluded from that definition and are treated as food additives under the Codex class names. For flavouring substances, Section VI.D sets the routes: "If food additives are to be used as flavoring substances, they must comply with the Codex Guidelines for the Use of Flavorings (CAC/GL66-2008) or be listed as safe by the United States Flavor Extracts Manufacturers Association (US FEMA), the International Organization for the Flavor Industry (IOFI), and/or Generally Recognized as Safe (GRAS)." Ask your supplier which route it relies on for the flavour you are approving, and keep that document with the specification. The supplier approval guide covers the importer and registration checks that sit alongside it.

Purity specifications

Section VI.F says food additives "should at all times conform with the applicable Specifications of Identity and Purity recommended by JECFA as adopted by Codex Alimentarius Commission." Where no such specification exists, "they should conform to appropriate specifications developed by responsible national or international bodies (e.g., the Association of Southeast Asian Nations/ASEAN)." When a flavour contains a food additive, ask which specification the supplier works to for that additive, and whether it is a JECFA specification or another body's.

Carry-over from a flavour into your food

Section IV.E defines carry-over as "the presence of additives in food as a result of the use of raw materials or other ingredients in which these additives are used." Section IV.Q describes non-flavouring food ingredients as "food additives and foodstuffs, that can be added to flavorings and are necessary for dissolving, dispersing, or diluting flavorings". Where an additive is present in the finished food because a flavour containing it was used as an ingredient, that presence fits the Section IV.E definition of carry-over, and its acceptability is assessed under Sections VI.G to VI.I. Section VI.G sets three conditions for carry-over of food additives from ingredients and raw materials:

1. The additive is acceptable for use as per Table One of Codex GSFA in the raw materials or other ingredients (including food additives).
2. The amount of the additive in the raw materials or other ingredients does not exceed the maximum use level listed in Table One of Codex GSFA.
3. The food into which the additive is carried over does not contain the additive in greater quantity than would be introduced by the use of the raw materials or ingredients under proper technological conditions or manufacturing practice.

Section VI.H adds a second route. A food additive not directly authorised in an ingredient may still be used in it "if the raw material or ingredient is used exclusively in the preparation of a food that is in conformity with these guidelines, provided that any maximum level applying to the food is not exceeded as specified in Table Two of the Codex GSFA." To support your assessment under either route, ask the supplier for the identity and level of each food additive in the flavour.

Infant foods

Section VI.I makes carry-over from a raw material or ingredient "unacceptable" for two food categories, unless a food additive provision in the category is listed in the order: 13.1, infant formula, follow-up formula and formula for special medical purposes for infants, and 13.2, complementary foods for infants and young children. Section V.D applies the same section to carry-over in those foods, in line with Executive Order No. 51 of 1986, the Milk Code. If your product falls in either category, tell the supplier before it proposes a flavour.

The CPR transition

Section VII sets the transition for "All affected manufacturers, traders and distributors of processed food products distributed in the Philippines":

1. Products with a Certificate of Product Registration expiring within five years from effectivity file initial applications complying with the order after the original registration expires (Section VII.A).
2. Affected products with a remaining CPR validity of three years or less after effectivity are granted a maximum three-year validity on renewal "to give ample time for reformulation", after which an initial application is filed (Section VII.B).
3. Where stocks of labels on the current CPR remain at the filing and approval of the new CPR, exhaustion may be allowed within a maximum of six months, and the corresponding inventory and period utilised are submitted to the FDA (Section VII.C).

Section VII.A measures its five-year window from effectivity, and Section VII.B applies to products with three years or less of CPR validity remaining after effectivity. List your Philippine CPRs with their expiry dates now, and set the timeline once the FDA confirms the effectivity date. Section V.B deems any food additive used outside the order's requirements "misbranding or adulteration, as the case may be", and Section VIII makes a violation a ground for disapproval of an application and suspension or cancellation of a CPR or authorisation.

What to ask your flavour supplier

Before a reformulation or renewal, ask for:

1. For each flavouring substance, the Section VI.D route the supplier relies on.
2. Each food additive in the flavour, with its level, so you can check the Section VI.G and VI.H conditions.
3. The specification each food additive is made to, and whether it is a JECFA specification.
4. Confirmation of whether the flavour is intended for a food in category 13.1 or 13.2.
5. The importer's basis for the Certificate of Product Registration, as the supplier approval guide describes.

VKA develops flavours for food and beverage brands across Southeast Asia. For the wider rules on registration and labelling, see the Philippine flavouring regulations reference. To discuss the documents your product needs, contact our team.