AMCHAM Food & Agri-Alert: Thailand’s Upcoming Plant-Based Protein Regulation

AMCHAM Food & Agri-Alert: Thailand’s Upcoming Plant-Based Protein Regulation

VOL. 8 of June 5, 2024 

At present, alternative proteins are popular with consumers worldwide. Consumers are purchasing plant-based foods, especially protein alternatives in the meat and dairy aisles, in increasing numbers. This demand for plant-based proteins has risen due to the increasing trend towards a vegan lifestyle. There are various alternative protein products in the Thai market. However, there are no clear guidelines for controlling and regulating the safety of alternative protein products in Thailand.  

Hence, the Thai Food and Drug Administration (Thai FDA) is currently studying the situation of the production and importation of alternative protein products in Thailand and studying the regulations implemented in foreign countries with regard to alternative protein products in order to further develop the legislation and standards for regulating alternative plant-based protein products in Thailand. 

On May 23, 2024 the Thai FDA launched its public consultation process on its plans to introduce a (draft) proposal for developing regulations and measures to oversee alternative proteins in the plant protein group. The consultation runs until June 7, 2024. 

The draft proposal includes rules on the following: 

  • Scope of Plant-Based Protein: The regulation will cover plant-based meat, plant-based beverages, and plant-based milk, all of which should have a plant composition of not less than 90% by weight, exclusive of food additives, flavoring agents, processing aids, water, and salt. 
  • Ingredients: Plants that use raw materials must comply with Good Agricultural Practice (GAP), and plant production after harvest must comply with Good Manufacturing Practice (GMP). 
  • Nutritional Quality: Controlling factors, such as anti-nutritional factors and protease inhibitors, such as trypsin inhibitors, hemagglutinins, glucosinolates, and so on, must not remain in the final product after the recommended preparation process. 
  • Food Additives: The conditions of use of food additives must comply with the Notification of the Ministry of Public Health (MoPH) (No. 444) B.E. 2566 (2023) Re: Prescribing the Principles, conditions, Methods, and Proportions of Food Additives (No. 3).  
  • Food Contaminants: Food contaminants must follow MoPH Notification (No. 414) B.E. 2563 (2020) Re: Standards for Contaminants in Food. 
  • Pesticide residue: Food producers must follow MoPH Notification (No. 387) B.E. 2560 (2017), (No. 393) B.E. 2561 (2018) and (No. 419) B.E. 2563 (2020) Re: Pesticide Residues in Food 
  • Pathogens: Food producers must follow MoPH Notification (No. 416) B.E. 2563 (2020) RE: Prescribing the Quality or Standards, Principles, Conditions, and Methods of Analysis for Pathogenic Microorganisms in Foods. 
  • Product Names: Food producers can use names that correspond with the physical characteristics of the food (for example, nuggets, tenders, mince, fillet, burger, patties, sausage, bacon, cheese analogue, almond milk), followed by “. . . plant-based” or “. . . from the main type of raw material”, such as nuggets from plants or nuggets from soybeans, plant-based burgers, almond burgers, and more 

                     The name of the product may reflect the process by which the product is obtained, such as rice protein hydrolysate, formed mung bean protein, and so on.  

                     It is prohibited to use a term that could be mistaken as a food product made from meat or milk (for example, meat product, Angus, Wague, Kurobuta, clean meat, cheddar, mozzarella, and more.).  

  • Health Claims: Health Claims must follow MoPH Notification (No. 445) B.E. 2566 (2023) Re: Nutrition Labels and MoPH Notification (No. 447) B.E. 2566 (2023) Re: Health Claims. It is allowed to claim the flavoring agents used to imitate normal foods (for example, plant-based meatballs imitating pork flavor added, and more.). However, the flavoring agents used must not contain animal ingredients or animal extracts. 
  • Pictorial: Use of pictures, symbols or markings that indicate an animal origin on the front or back of the packaging is prohibited. However, it is allowed to use pictures of food on packaging. 
  • Certified Logo: It is allowed to display standards that have been certified by reliable organizations, either domestically or internationally, such as logos certified by the National Sanitation Foundation (NSF) or SCS standards. 

It is time to prepare for the upcoming plant-based protein regulation in Thailand. The public hearing for the draft Notification will be launched soon. Please exercise your right to comment on the draft notification. 

Related News / Blog