How to Declare a Flavouring on a Singapore Food Label

Declaring a flavouring on a Singapore food label looks like a small detail, until a shipment is held because the ingredient list is wrong. In Singapore, prepacked food is governed by the Food Regulations made under the Sale of Food Act, both administered by the Singapore Food Agency (SFA), and SFA sets its labelling rules with reference to the Codex Alimentarius Commission, the international food standards body established by the Food and Agriculture Organisation and the World Health Organisation. A set of amendments, the Food (Amendment) Regulations 2025, came into operation on 30 January 2026 and changed several details that touch flavourings directly. This guide explains how a flavouring, and the additives that travel with it, must be declared on a Singapore label, written for the product developers, procurement and regulatory teams who have to get the statement of ingredients right.

Who Must Comply, and Who Is Exempt

The labelling rules apply to prepacked food offered for sale in Singapore, and the mandatory information must appear in English. Under Regulation 5 of the Food Regulations, a prepacked food must carry a name or description, a statement of ingredients, the net quantity, the name and address of the local business responsible for it, the country of origin, a lot identification mark and, where incorrect handling would make the food unsafe, directions for use. The last two became mandatory on 30 January 2026. One exemption matters to flavour suppliers: the general labelling requirements do not apply to food packed in non-retail containers for supply to manufacturers or food services for further use. A drum of flavour shipped to a factory is not a retail product, so it does not carry a consumer ingredient list, but every flavour in it still has to be declarable on the finished product that does. That is why the burden lands on the manufacturer, and why the supplier's documentation decides whether the manufacturer can comply.

The Statement of Ingredients

A prepacked food made of two or more ingredients must bear a clear statement of ingredients, and that statement now has to be preceded by an appropriate heading such as 'Ingredients'. Every ingredient and additive is listed in descending order of its proportion by ingoing weight at the time of manufacture, so the component that weighs most appears first. Each one is declared by its exact identity, meaning a specific name that reflects its true nature, unless the First Schedule of the Food Regulations provides a permitted generic term that consumers can understand. Where an ingredient is itself made of several components, that compound ingredient is declared with its constituents in brackets, for example 'soy sauce (soybean, black bean, salt, sugar)'.

How a Flavouring Is Declared

For a flavouring, the First Schedule supplies the permitted generic term. A flavouring may be declared simply as 'flavour' or 'flavouring', optionally qualified by the words 'natural', 'nature identical' or 'artificial', or a combination of those words where applicable. The qualifier is not mandatory. SFA has confirmed that food businesses may declare a flavouring as 'flavour' or 'flavouring' on its own, or choose to add the source qualifier, for example 'nature identical flavours' or 'artificial flavours', if they wish. This mirrors the Codex general standard, which lists 'flavour(s)' and 'flavouring(s)' as class titles for label use and states that the expression may be qualified by natural, nature identical or artificial as appropriate. Some trade summaries describe the source qualifier as newly compulsory; the primary text makes it optional, and confirming that one point against the regulation rather than the secondary coverage can save an unnecessary label change.

Why a Flavouring Carries No INS Number

A common mistake is to expect a flavouring to have an International Numbering System (INS) number, the way a colour or a preservative does. It does not. The INS, set out in the Codex guideline on class names and the International Numbering System for food additives, is a harmonised way of naming additives as an alternative to a long chemical name, and the guideline states plainly that it does not include flavourings, which instead carry a JECFA number as their identifier. So the flavour itself is declared by the generic term, while the additives inside a flavour system, a colour such as tartrazine (INS 102), a preservative such as sorbic acid (INS 200) or an acid such as citric acid (INS 330), each have their own number. Singapore's format is more flexible than the Codex baseline here: an additive may be declared by its specific chemical name, its INS number, its E number or a permitted generic term, and it is not a requirement to state the additive's functional class. One additive is singled out, however: synthetic tartrazine must be declared as 'tartrazine', 'colour (102)' or similar words, so that consumers who are sensitive to it can see its presence.

Carry-Over: the Additives Travelling With a Flavour

A flavour preparation rarely arrives as a single substance. It can carry a solvent or carrier, a colour, an antioxidant or a preservative, and those additives can pass into the finished product. The rule for these carried-over additives is functional: an additive carried from an ingredient into the finished food in an amount that is still enough to perform a technological function there must be declared, while one present below the level needed to do anything need not be, a position that took effect on 30 January 2026 and follows the Codex approach. Processing aids, which are used during manufacture but leave only an unintended and unavoidable residue, do not have to be declared at all. The practical consequence is direct: a manufacturer can only build an accurate ingredient list if the flavour supplier discloses the full make-up of the flavour, including any carry-over additives and their numbers.

Allergens Cannot Hide Inside 'Flavouring'

This is where a bare 'flavouring' declaration most often goes wrong. The Food Regulations name eight groups of foods and ingredients known to cause hypersensitivity: cereals containing gluten, crustaceans, eggs, fish, peanuts and soybeans, milk including lactose, tree nuts, and sulphites at a total concentration of 10 mg/kg or more. These must always be declared, and they must never be hidden behind a generic term. If an allergen is carried into the finished food through a flavour, for instance a dairy note or a nut derivative, it has to be named specifically and not folded into the word 'flavouring'. SFA gives the parallel example of peanut oil reaching a salad through its dressing: it must be declared as peanut oil, not as the permitted generic 'vegetable oil'. A 'Contains' statement, such as 'Contains milk', may be added immediately after the ingredient list, but it does not replace the specific declaration.

Naming the Product, and What Cannot Go In

The flavouring rules sit inside a wider honesty principle. Under Regulation 9 a label must not be false, misleading or deceptive about the nature or composition of the food, and the product name has to reflect what is actually inside. SFA's own example is instructive: a product called 'fruit biscuits' must contain a fruit component, whether fruit pulp, fruit juice or natural fruit flavouring, and if it contains none, the word 'fruit' should not be used at all. Separately, a small group of substances is prohibited as flavouring agents under Regulation 22(7), among them coumarin, tonka bean, safrole and sassafras oil, so a flavour built for the Singapore market has to avoid them. The 2025 amendments also added new prohibited claims, including suggestions that a permitted ingredient is unsafe or that a product is free of a substance that is not allowed in food in the first place.

What This Means for Sourcing

For a manufacturer, the finished-product declaration is only as accurate as the data the flavour supplier hands over. Before committing to a formulation, ask the supplier for the full compositional breakdown of the flavour: the generic term and source category it should be declared under, every carry-over additive with its specific name and INS or E number, the presence of any of the eight allergen groups including added or carried-over sulphites, and confirmation of whether anything is present only as a processing aid. Getting this wrong is an offence: under Regulation 261 of the Food Regulations a contravention carries a fine of up to $1,000, rising to $2,000 for a second or subsequent conviction, on top of the commercial cost of relabelling or recalling stock. A supplier that cannot provide this documentation is a supplier whose flavours cannot be declared with confidence.

How VKA Approaches Flavour Declaration

At VKA we treat the declaration as part of what we deliver, not an afterthought. Because a flavour shipped in bulk to your factory is itself exempt from retail labelling, the documentation we provide is what lets your finished product comply: a specification that states how each flavour should be declared, the carry-over additives it contains with their INS or E numbers, its allergen status including any sulphites, and its halal and FSSC 22000 documentation where you need it. We develop flavours for the Singapore and wider ASEAN market with those declarations in mind from the first sample. To see how we work as a flavour supplier in Singapore, browse our Capabilities page or our guide to halal flavour certification, and for the natural, nature-identical and artificial distinction behind the label term, see what natural flavours are. For a specific declaration question, talk to a flavourist directly.