How to Declare a Flavouring on a Singapore Food Label

On a Singapore label a flavouring is declared by a generic term, not by a chemical name and not by a number. Item 11 of the First Schedule to the Food Regulations permits “Flavour or flavouring, qualified by the words “natural”, “nature identical” or “artificial”, or a combination of any of these words, if applicable”. Regulation 5(4)(b)(vii), inserted with effect from 30 January 2026, now states expressly that an allergen carried over into a finished food may not be declared by that generic term, so your supplier's allergen statement is the evidence your ingredient list stands on.

The Generic Term Is an Exception, Not the Default

The generic term is an exception, not the default. Regulation 5(4)(b) requires a list of ingredients carrying the appropriate designation of each one, and defines the phrase: ““appropriate designation” means a name or description (being a specific and not a generic name or description) that indicates the true nature of the ingredient or constituent to which it is applied except as provided in the First Schedule”. In other words, specificity is the rule and the First Schedule is the carve-out.

Natural, Nature Identical or Artificial

Item 11 permits a flavour or flavouring qualified by the words natural, nature identical or artificial, or a combination of them, “if applicable”. The text does not say whether the qualifier may be left off where none of the three fits, so confirm that point with SFA rather than assuming a bare “flavouring” will pass. Where a qualifier is used it has to be true, and the underlying definitions sit in regulation 22. Regulation 22(6) provides that “Natural flavouring essences or extracts shall be preparations in any permitted solvent or any combination of permitted solvents, with or without sweeteners other than sweetening agents, permitted colouring matter or chemical preservatives, of sapid or odoriferous principles, or both, derived from a plant after which the flavouring extract or essence is named.”, which ties “natural” to the plant the essence is named after rather than to a general impression of wholesomeness. Regulation 22(9) defines the other side by origin: “Synthetic flavouring essences or extracts shall include any artificial flavour or imitation flavour which may resemble the sapid or odoriferous principles of an aromatic plant, fruit or vegetable or any other food, except that the flavouring principle shall be derived in whole, or in part, from either chemical synthesis or any other sources that does not involve extraction or isolation therefrom of the sapid or odoriferous principles present in an aromatic plant, fruit or vegetable or any other food.”

Why Codex Cannot Settle the Qualifier

One term on that list has no international counterpart. Codex CAC/GL 66-2008 defines natural flavouring substances as “Natural flavouring substances are flavouring substances obtained by physical processes that may result in unavoidable but unintentional changes in the chemical structure of the components of the flavouring (e.g. distillation and solvent extraction), or by enzymatic or microbiological processes, from material of plant or animal origin. Such material may be unprocessed, or processed for human consumption by traditional food-preparation processes (e.g. drying, torrefaction (roasting) and fermentation). This means substances that have been identified / detected in a natural material of animal or vegetable origin.” and gives their counterpart as synthetic: “Synthetic flavouring substances are flavouring substances formed by chemical synthesis.” Read the whole of that guideline and there is no definition of “nature identical” anywhere in it, and none of “artificial” either. “Nature identical” is a permitted Singapore label qualifier, which is a different thing from an international category, so a supplier specification written to Codex will not resolve which of the three words belongs on your pack.

English, Lot Marks and Biotechnology

The particulars themselves must be in English. Regulation 5(2) provides that “Every package of prepacked food shall, unless otherwise provided in these Regulations, bear a label” with the required particulars, statements, information and words in English. Two further particulars now sit in the same regulation and both bear on flavourings. Regulation 5(4)(da) requires “an identification number or mark (like a lot number, batch number or serial number) that identifies the producing factory and production lot of the food”, and regulation 5(4)(eb) requires declaration of “in any food or food ingredient obtained through biotechnology, the presence of any allergen transferred from a food or an ingredient mentioned in sub‑paragraph (ea)”. A lot mark on your finished pack is only meaningful if it can be traced back through the supplier's own batch records, which is why a certificate of analysis carrying a batch identifier is the practical partner to that clause.

The Eight Allergen Classes

Allergens are where a bare “flavouring” declaration most often fails. Regulation 5(4)(ea) names the classes that must be declared: “the following foods and ingredients that are known to cause hypersensitivity: (i) cereals containing gluten, i.e. wheat, rye, barley, oats, spelt or their hybridised strains and their products; (ii) crustacea and crustacean products; (iii) eggs and egg products; (iv) fish and fish products; (v) peanuts, soybeans and their products; (vi) milk and milk products (including lactose); (vii) tree nuts and nut products; and (viii) sulphites in concentrations of 10 mg/kg or more”. Seven of the eight carry no threshold; only sulphites do, at 10 mg/kg or more.

Carried-Over Allergens Must Be Named

Regulation 5(4)(b)(vii), inserted by the Food (Amendment) Regulations 2025 with effect from 30 January 2026, states the position expressly. It provides that “where any food or ingredient mentioned in sub‑paragraph (ea) is carried over from an ingredient into a finished food product, the food or ingredient mentioned in that sub‑paragraph (as the case may be) must be specified by its appropriate designation, but not by the generic term for it in the second column of the First Schedule” Read plainly, that means a dairy note, a nut derivative or a soy-derived carrier reaching your product through a flavouring must be named specifically on your label. It can no longer sit inside the word “flavouring”. The supplier's allergen declaration is therefore the document your compliance rests on, and it has to cover carry-over, not merely what was intentionally added.

Carry-Over: the Additives Travelling With a Flavour

Additives inside a flavouring follow a functional test rather than a disclosure rule. Regulation 5(4)(b)(vi) provides that “where any food additive is carried over from an ingredient into a finished food product”, and then splits the outcome: “(A) where the food additive is in an amount sufficient to perform a technological function in that product, the food additive must be specified by its appropriate designation; and (B) to avoid doubt, where the food additive is in an amount that is not sufficient to perform any technological function in that product, the food additive need not be specified” The consequence for a buyer is direct. You cannot apply that test to an additive whose presence and level you have not been told, so an ingredient breakdown identifying every carried-over additive is a precondition of an accurate ingredient list, not a nice-to-have.

What a Flavouring May Not Contain

A flavouring can also be unlawful in Singapore for what it contains rather than for how it is declared, and two provisions decide it. Regulation 22(7) prohibits sixteen named substances outright, coumarin, safrole and volatile bitter almond oil containing hydrocyanic acid among them, and the full list is set out word for word in our guide to choosing a flavour supplier in Asia. There is no permitted level for any of them. Regulation 22(2) separately closes the solvent list, and regulation 22(3) sets the grade: “The permitted solvents referred to in paragraph (2) other than water shall conform with the British Pharmacopoeia standard.” A flavouring lawfully sold elsewhere in a solvent outside that list is not lawful here, and neither the prohibition nor the solvent rule appears anywhere on your finished label, so both have to be settled at the supplier specification stage.

Two Beliefs About SFA That Do Not Hold

Two beliefs about SFA reach specifications more often than they should. The first is that individual flavourings are approved or registered. They are not: SFA licenses food businesses and registers importers of processed food, and its guidance on permitted additives says of itself that “This guidance document is not legally binding, and should be read together with the Food Regulations.”. What that guidance does say about flavourings is an accommodation rather than an approval: “In principle, SFA has no objection to the use of flavouring substances that have been evaluated and endorsed by recognised international bodies such as the Joint FAO/WHO Expert Committee on Food Additives (JECFA), the Flavour and Extract Manufacturers’ Association (FEMA), or the European Food Safety Authority (EFSA), under good manufacturing practice (GMP), provided that the flavouring preparations do not contain any of the prohibited substances listed under Regulation 22(7) of the Food Regulations.” The second belief is that flavourings are permitted from a fixed list. Regulation 22(1) defines a flavouring agent by what it does, as any wholesome substance capable of imparting taste or odour to a food, and the definition is quoted in full in our guide to choosing a flavour supplier in Asia. The closed list in Singapore belongs to flavour enhancers, under regulation 23, which is a different regime.

What Did Not Change in 2026

One thing is worth stating plainly, because trade coverage regularly gets it wrong: nothing in Singapore's flavour labelling moved in 2026. Read on 13 September 2026, the amendment annotation to the Food Regulations still tops out at S 92/2025, in force 30 January 2026, and the 2026 Subsidiary Legislation Supplement carries no instrument made under the Sale of Food Act at all. Nutri-Grade is a separate scheme and it did not move either: every operative provision still carries the stamp “[S 451/2023 wef 30/12/2023]”, so freshly prepared beverages have been in scope since 30 December 2023 rather than from some coming date. The extension to 23 sub-categories of prepacked salt, sauces, seasonings, instant noodles and cooking oil was announced on 6 April 2025 for mid-2027, and as at 13 September 2026 the enabling regulations have not been made. Plan against the clauses above, not against an announcement.

The Six Documents to Request

For a manufacturer the practical output of all this is a short document request, each item tied to the clause that makes it necessary. Ask for the declaration wording and the qualifier the supplier supports, against First Schedule item 11. Ask for an allergen declaration covering all eight classes with carry-over addressed, against regulation 5(4)(ea) and 5(4)(b)(vii). Ask for an additive breakdown with levels, against regulation 5(4)(b)(vi). Ask for a solvent declaration and a written statement that no regulation 22(7) substance is present. Ask for a certificate of analysis per batch with a lot identifier, against regulation 5(4)(da), and an origin statement covering biotechnology, against regulation 5(4)(eb). A supplier who can answer all six in writing is a supplier whose flavours you can declare with confidence.

How VKA Approaches Flavour Declaration

At VKA we treat the declaration as part of what we deliver, not an afterthought. 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, 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. Every clause cited above, and the rest of regulation 22, regulation 23 and the First Schedule, is set out with its own citation and retrieval date in our clause-by-clause reference to the Singapore flavouring regulations. For a specific declaration question, talk to a flavourist directly.