Reference
Bulk Flavor Labeling in the Philippines
Drum rules and supporting documents
Published 3 October 2026. Identification, specifications and expiration dates, with the bulk labeling and CPR loose-label exemptions kept separate.
A flavor packed in a wholesale container for a manufacturer to use in further processing falls within the bulk food materials definition in AO 2014-0030. Section VIII.B exempts those materials from labeling on two conditions: they are properly identified and product specifications are provided in supporting documents.
The same order adopts Codex STAN 107-1981 for food additives sold as such. Annex B item a.4 says all food additives carry an expiration date, and its non-retail provisions include that rule. Read both provisions when checking a flavor drum. Confirm with the FDA how the exemption and Annex B apply together to your product.
Section 01
What counts as a bulk food material
The definition covers raw materials, ingredients and food additives packed in wholesale containers for further processing by the food industry.
raw materials, ingredients, and food additives that are packed in wholesale containers either for food industry use for further processing
Start with the intended use of the pack. A bulk ingredient going into a manufacturing process is the case addressed here.
Section 02
The labeling exemption has two conditions
AO 2014-0030 Section VIII.B exempts bulk food materials intended for further processing, repacking or food service and not for retail. Identification and supporting specifications remain conditions of that exemption.
on condition that these are properly identified as may be appropriate and product specifications are provided in supporting documents
Check the identification on the container alongside the supporting product specification. The exemption is conditional; it does not settle how Annex B applies to an additive sold as such.
Section 03
The expiration date rule includes non-retail containers
AO 2014-0030 Section VI.C adopts Codex STAN 107-1981 for food additives sold as such. Annex B item a.4 supplies the expiration date rule.
All food additives shall carry an expiration date
Annex B item 2 requires C.1.a to C.1.f on non-retail container labels, so the a.4 expiration date rule reaches those containers. Confirm with the FDA how this requirement applies alongside Section VIII.B.
Section 04
Naming a flavoring mixture
Annex B item a.3 permits the generic term flavor or flavoring for a mixture, together with a true indication of its nature. Natural, nature-identical or artificial may qualify it.
the name of each flavouring present in the mixture need not be printed
This is the mixture provision for additives sold as such. Check the finished-food ingredient declaration separately when the flavor reaches a consumer product.
Section 05
The CPR loose-label exemption is a separate provision
AO 2014-0029 Annex D exempts bulk raw materials, ingredients and food additives for further processing from submitting loose labels or artworks in initial CPR applications at A.3 and renewals at B.4.
loose labels or artworks ... except for bulk raw materials, ingredients and food additives intended for further processing
This concerns the label artwork submitted with a CPR application. Section VIII.B of AO 2014-0030 concerns labeling the material itself. Keep the two exemptions separate when preparing a filing and checking a shipment.
Section 06
Raw materials under FDA Circular 2026-0002
FC 2026-0002 defines raw materials used to process a finished product by their bulk packaging and requires product specifications that meet client requirements.
packed in bulk containers and not labelled as a finished product
product specifications that comply with the client requirements
Use the specification to check the material against the requirements of the manufacturer buying it.
Section 07
When the flavor reaches the consumer label
The Philippine flavoring reference covers finished-food flavor declarations and allergen provisions. Read those clauses when reviewing the finished product.
Section 08
What remains unsettled
As of October 2026, the repeal status of AO 2014-0030 and AO 2014-0029 remains unverified in the source review. Confirm their current application with the FDA.
FC 2026-0002 and AO 2026-0011 were checked; neither text addresses the bulk-label exemption. That does not establish FDA confirmation that the exemption survives unchanged in practice. The effectivity date of AO 2026-0011 itself remains unverified. Its label-stock transition and the separate FC 2026-0002 request-letter route are set out in section 11 of the flavoring reference.
Section 09
A specification and pack checklist for purchasing
Use the clauses above to check the bulk container, the supporting specification and the CPR submission separately.
| Check | Clause |
|---|---|
| Identify the bulk material and obtain the supporting product specification. | AO 2014-0030 VIII.B |
| Check the expiration date on the additive container, including non-retail packs. | AO 2014-0030 Annex B a.4 and item 2 |
| For a flavoring mixture, check the generic name and true indication of nature. | AO 2014-0030 Annex B a.3 |
| Check the loose-label or artwork exemption for the CPR application separately. | AO 2014-0029 Annex D A.3 and B.4 |
| Match the raw-material specification to client requirements. | FC 2026-0002 raw-material definition and specifications |
Section 10
How to cite this page
Suggested citation, with the retrieval date that applies to every clause quoted above:
VKA, “Bulk Flavor Labeling in the Philippines: Drum Rules”, vkaff.com, published 3 October 2026. Primary instruments: AO 2014-0030, AO 2014-0029 and FDA Circular 2026-0002.
Quotations are extracts from the cited instruments. Confirm current application and the open points in section 8 with the FDA before filing.
Sources
Bulk flavor labeling questions
What must a bulk flavoring label say?
AO 2014-0030 VIII.B makes the bulk food materials labeling exemption conditional on proper identification and product specifications in supporting documents. Annex B separately addresses food additives sold as such, including an expiration date at a.4. Confirm with the FDA how those provisions apply together to your flavor.
Do I need loose labels for a CPR on a bulk flavoring?
AO 2014-0029 Annex D A.3 and B.4 exempt bulk raw materials, ingredients and food additives intended for further processing from submitting loose labels or artworks. This application-document exemption is separate from the labeling exemption in AO 2014-0030 VIII.B.
Is an expiry date required on a drum?
AO 2014-0030 Annex B item a.4 says all food additives shall carry an expiration date. Annex B item 2 includes that rule for non-retail containers. Confirm the application alongside the VIII.B bulk food materials exemption with the FDA.
Can I list flavor on a mixture?
AO 2014-0030 Annex B item a.3 permits flavor or flavoring for a mixture with a true indication of nature, optionally qualified as natural, nature-identical or artificial. Each flavoring in the mixture need not be printed. The finished-food ingredient declaration is a separate provision.