Question

Is it possible to only mention “Packed for” or “Distributed by” for a product imported to Malaysia, Philippines, Indonesia, Thailand, Vietnam, Sri Lanka & China? How about when a product is produced locally & sold locally in those countries?

ANSWER

China

According to Section 4.1.6 of National Food Safety Standard – General Standard for the Labeling of Prepackaged Foods (GB7718-2011), name, address and contact information of manufacturer shall be declared.

In one of the following circumstances, the labeling shall be made according to the following requirement.

  • Any group company or its branch office (subsidiary) which by law bears independent statutory responsibilities shall have their respective name and address declared separately.
  • Any branch office or production facility of a group company which by law does not bear independent statutory responsibilities shall have the names and addresses of the group company and its branch office (production facility) declared; or only have the name, address and production facility of the group company declared. The production facility shall be declared to municipal region according to administrative divisions.
  • In the case of contract packer authorized to produce the prepackaged food, the name and address of the company that authorizes the contract packer and commissioned company shall be declared; or only have the name, address and production facility of the company that authorizes the contract packer declared. The production facility shall be declared to municipal region according to administrative divisions.

The contact information of manufacturer or distributor which by law bears independent statutory responsibilities shall be declared including at least one item of the following: telephone number, fax number, contact information on web and so on, or post address declared accompanied with address.

For imported prepackaged food, the country or region (Hong Kong, Macao or Taiwan) of origin, and the name, address and contact information of the agent, importer or distributor registered in the People’s Republic of China, shall be declared. The declaration of name, address and contact information of the manufacturer does not need to be declared.

In conclusion, for imported food it is possible to only mention “distributed by” while food produced locally need to mention information of manufacturer.

Reference

Ministry of Health of the People’s Republic of China. (2011). National Food Safety Standard – General Standard for the Labeling of Prepackaged Foods (GB7718-2011). Section 4.1.6.

 

Thailand

According to the Clause 4 of Notification of the MOPH (No. 367) B.E. 2557 (2014) Re: Labeling of Packaged Foods, name and address of manufacturer or packers or importers or head office, the rules are divided into 2 cases, as follows:

Case 1) Domestic produced food shall display name and address of manufacturer or packer or name and address of head office of manufacturers or packers and shall have the following texts appeared together;

  • Text of “Manufacturers” or “Manufactured by” in case of manufacturer
  • Text of “Packers” or “Packed by” in case of packer
  • Text of “Head office” in case of manufacturer or packer intends to display name and address of head office.

Case 2) Food imported from foreign countries shall display name and address of importers by having text of “importer” or “imported by” appeared together and also display name and country of manufacturers.

In conclusion, information of manufacturer or packer shall be declared for domestic produced food while information of importer and manufacturer shall be declared for imported food.

Reference

Ministry of Public Health Thailand. (2014). Notification of the MOPH (No. 367) B.E. 2557 (2014) Re: Labeling of Prepackaged Foods. Clause 4.

 

Malaysia

According to Regulation 11 of Food Regulation 1985, label of imported food should list the name and address of manufacturer, name and address of importer and the name of the country of origin of the food while for food locally manufactured the label must bear the name and address of the manufacturer.

It is not allowed to use “manufactured for” and “packed for” in the labels of both imported food and food produced locally. It is allowed to only mention “distributed by” in the labels of food produced locally. Imported food can mention “distributed by” after the word “importer”.

Examples of accepted wordings are “distributed by”, “packed by & distributed by” for food produced locally and “imported by/distributed by” for imported food.

Reference

Ministry of Health Malaysia. (2017). Food Regulations 1985. Regulation 11.

 

Philippines

According to Rules and Regulations Governing the Labeling of Prepackaged Food Products Distributed in the Philippines (AO No. 2014-0030), for imported products, name and address of manufacturer, name and address of importer and the country of origin shall be declared while the name and address of the manufacturer, repacker, importer, trader or distributor of the food shall be declared on the label of locally manufactured products.

It is allowed to use “distributed by” for food produced locally only.

It is allowed to mention “manufactured for” or “packed for” in the labels. For example, if the product is import from Belgium, the label can mention “manufactured for & imported by: ABC company” or if the product is locally manufactured, the label can mention “packed for & distributed by: ABC company”.

Reference

Republic of the Philippines Department of Health. (2014). Rules and Regulations Governing the Labeling of Prepackaged Food Products Distributed in the Philippines (AO No. 2014-0030).

 

Vietnam

According to Article 12 of Decree No. 43/2017/ND-CP on Goods Label, for domestically manufactured goods, the labels must show the name of the entity and the address of the manufacturer.

For goods imported for circulation in Vietnam, the labels must show the name and address of the manufacturer and the name and address of the importer.

For goods imported into Vietnam by organizations or individuals acting as sale agents directly for foreign traders, the labels must show the name and address of the manufacturer and the name and address of the organization or individual acting as agents to sell such goods.

As a conclusion, information of manufacturer should be declared on products produced locally while information of manufacturer and importer/ sale agents must be declared on labels of imported goods.

Reference

Government of Vietnam. (2017). Decree No. 43/2017/ND-CP on Goods Label. Article 12.

 

Sri Lanka

According to Regulation 04 of Food (Labeling and Advertising) Regulations 2005, name and address of manufacturer/ packer/ distributor should be declared on products produced locally while name and address of importer and packer/ distributor in Sri Lanka should be declared on labels of imported goods. Thus, it is acceptable to only mention “Packed for” or “Distributed by”.

Reference

Minister of Health Sri Lanka. (2015). Food (Labelling and Advertising) Regulations 2005. Regulation 04.

 

Indonesia

According to Peraturan Label Pangan Olahan (Nomor 31 Tahun 2018), label of imported food should list the name and address of manufacturer. The name and address of the importer and/or distributor may precede by a description in the form of “Imported/ distributed by … “.

For locally manufactured products, the name and address of the manufacturer, contract giver and receiver and processed food licensing party shall be declared on the label. It may precede by “Produced by … for …”, “Packed by … for … “.

Reference
Badan Pengawas Obat Dan Makanan Republik Indonesia. (2018). Peraturan Label Pangan Olahan (Nomor 31 Tahun 2018).

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