Food Safety And Security Act 2025 Compliance Update: Key Takeaways From The Commencement Notification (Building On Our Part 1–3 Series)

Singapore has notified the Food Safety and Security Act 2025 (Commencement) (No. 2) Notification 2025 (Notification), effective from 28.11.2025, to bring into force selected definitions like 'advertise', 'drinking water', 'content', 'label', among others, under Section 3 (General Interpretation) of the Food Safety and Security Act 2025 (FSSA) which support the compliance obligations under Part 5, Part 6, Part 12, Part 13, Part 14 and Part 16 of the FSSA, to the extent that these have been commenced.

In our previous blog posts on the Food Safety and Security Act 2025 (Part 1, Part 2 and Part 3) we have provided a useful context for food businesses seeking to understand the compliance implications associated with the FSSA. In this blog post, we have highlighted the compliance impact associated with the commencement of these provisions, to help businesses to reassess and update their compliance processes accordingly.

List of Commenced Provisions

By way of the Notification, the following provisions of FSSA have come into effect –

• Section 2(c) which states that the purpose of the Act is "to ensure that food in Singapore is safe and suitable for human consumption and that non‑packaged drinking water in Singapore is not unwholesome".
• 'Food Business' under Section 5.
• 'Primary Produce' and 'Unsafe Primary Produce' under Section 14.
• 'Primary Production Activity' under Section 15.
• 'Animal Feed' under Section 16.
• 'Part 5' – Defined Food and Pre-Market Approval.
• 'Part 6' – Compliance Related to Non-Packaged Drinking Water.
• 'Part 12' – Appeals (Section 224-229)
• 'Part 13' – Monitoring and Enforcement (Sections 230-273)
• 'Part 14' – Administration (Sections 274-306)
• 'Part 16' – Miscellaneous (Sections 319-321).

Key sections in the Notification

1. Definitions in Section 3(1)

What it covers

The Notification activates an extensive list of definitions, including terms such as Advertise, Advertisement, Agency, SFA officer, Food, Food additive, Defined food, Novel food, among others. While definitions themselves do not create duties, they determine the scope of regulatory obligations and support the legal framework for the operative provisions that have been commenced or will commence in future phases.

Compliance impact

• Businesses must now classify themselves correctly (e.g., whether they fall within the definition of "food business"?) as many future obligations depend on these terms.
• Online sellers must understand and assess "advertising", "online location", "content".
• The commencement of these definitions enables the Singapore Food Agency (SFA) to apply enforcement powers, once linked operative Parts of the FSSA effectuate, and ensure these Parts operate as intended from their effective date.

2. Section 3(2) to Section 3(8)

What it covers

These provisions determine what counts as "content", a "label", how information must be produced (in legible form and in English), the continuing nature of obligations after deadline lapses and territorial application.

Compliance impact

• Maintain internal checks to prevent violations and respond promptly to issues relating to labelling, advertising or product description.
• Maintain processes to ensure that content and labels are not misleading or incomplete, given the expanded treatment of linked content.
• Businesses must ensure ongoing monitoring of linked digital content as hyperlink or QR-accessible content is treated as part of the "content" or "label".
• Maintain version control and records for digital content and labels for audit purpose.
• Have systems and processes in place to prevent misleading or deceptive labelling of food.
• Where information is not in English, ensure accurate translation and ensure content is legible.

3. Section 4 (Meaning of Food)

What it covers

The commencement notification brings Section 4 into force. This section defines the meaning of "food", and the definition encompasses any substance or thing that is used, capable of being used, or represented as being for use in human consumption, whether live, raw, prepared, or partly prepared. The commencement of this definition does not itself create any compliance obligation on food businesses, but it provides greater clarity on the scope and coverage of the operative provisions for food businesses to determine whether their operations and products fall within the FSSA or not.

Compliance Impact

• Have systems and processes in place to assess whether your business operation falls under the purview of the definition of 'food' or not.
• Businesses producing products that qualify as defined foods (e.g., novel or genetically modified food) will need to comply with Part 5.
• Have systems and processes in place to prevent misleading or deceptive labelling of food. Businesses must implement internal compliance monitoring to ensure that products classified as "food" are continuously reassessed as new Parts of the Act commence and additional obligations become applicable.

4. Section 5 (1) to Section 5 (3) (Food business)

What it covers

Singapore has operationalised the definition of 'food business'. Part 4 of the FSSA 2025 mandates licensing requirements for a food business to carry out a licensable food business, prelisted in the First Schedule to the FSSA. Businesses must be compliance ready when Part 4 of the FSSA will gain force in a future phase.

Compliance Impact

• Have systems and processes in place to determine whether your business operation falls under the purview of the definition of 'food business' or not.
• Businesses whose activities will be licensable in future should begin preparing relevant internal processes (e.g., management plans, hygiene controls) in anticipation of commencement of Part 4.

5. Section 7 to Section 10 (Meaning of advertise, sell, supply, handling, etc.)

What it covers

Section 7 to 10 of the FSSA 2025 stipulates the meaning of the terms like – 'advertise', 'sell', 'supply', 'handling', 'manufacturing' and 'preparing'. Businesses must evaluate and review their operations against the scope of these definitions to stay ahead of the compliance curve.

Section 9 defines "handling" and therefore determines whether an act constitutes "handling" for the purposes of offences prescribed under Part 8 of the FSSA 2025, including provisions such as sections 142, 152 and 153, which are commenced under the Notification.

Compliance Impact

• Maintain records showing reasonable precautions taken to prevent unauthorised supply, as due diligence is a defence available.
• Have processes in place to avoid supplying falsely described food.
• Maintain internal checks to prevent violations and respond promptly to issues relating to labelling, advertising or product description.
• Identify "defined food" in your product range to ensure you do not advertise it unless permitted under the law.

6. Section 13 (Defined Food)

What it covers

The notification brings Section 13 of the FSSA Act into force, which defines the term "Defined Food." Under the FSSA 2025 businesses must obtain pre-market approval from the Singapore Food Agency before supplying novel or genetically modified foods (collectively referred to as "defined foods").

Compliance impact

• Ensure compliance with all conditions attached to the pre-market approval.
• Keep track of the validity of the pre-market approval.
• Do not transfer or assign the approval unless there is a provision to do so in the approval or with written consent of the SFA. This could be a relevant factor in the event of any business restructuring.
• Maintain records, showing reasonable precautions taken to prevent unauthorised supply, as due diligence is a defence available.

7. Section 14 (Primary Produce & Unsafe Primary Food)

What it covers

The commencement notification brings into force Section 14, which stipulates the terms 'primary produce' and 'unsafe primary produce'. FSSA 2025 under Part 7 outlines the requirement to strictly adhere to the directions of the Director-General for maintaining food safety and executing sustainable primary production measures. Hence though Part 7 has not commenced yet, businesses can prepare for compliance obligations that will arise in future.

Compliance Impact

• Businesses involved in early-stage food production must correctly identify whether their output constitutes "primary produce".
• The distinction between "primary produce" and "unsafe primary produce" will become relevant once the operational Parts governing safety measures are commenced.
• Businesses should develop internal processes to assess safety risks in primary produce in preparation for future commencement of related Parts.

8. Sections 15 & 16 (Primary Production Activity and Animal Feed)

What it covers

Singapore has brought the definitions of 'Primary production activity' and 'Animal feed' into force through the commencement notification. Once the related parts commence in future phases, the Director‑General may issue binding directions to manage risks related to animal feed and primary production activities.

Compliance Impact

• Businesses must determine whether their activities fall under "primary production activity" for the purposes of future licensing and operational requirements.
• Businesses supplying or using animal feed, should understand the statutory definition, as this will trigger obligations under future commenced Parts relating to feed safety.

Part 5 (Pre-Market Approval for Defined Foods)

What it covers

Under the FSSA 2025 businesses must obtain pre-market approval from the Singapore Food Agency before supplying novel or genetically modified foods (collectively referred to as "defined foods"). This approval is granted after a safety assessment considering factors such as potential health risks, composition, production methods, source and consumption levels. A defence of due diligence is available under limited circumstances. Supplying defined food without approval, whether knowingly or not is an offence, with strict liability applying and penalties including fines and imprisonment.

Key compliances

• Determine and submit a complete application for a pre-market approval to the Singapore Food Agency (SFA) if your product qualifies as a defined food under the FSSA 2025 (which includes novel food or genetically modified food).
• Ensure compliance with all conditions attached to the pre-market approval.
• Keep track of the validity of the pre-market approval.
• Do not transfer or assign the approval unless there is a provision to do so in the approval or with written consent of the SFA. This could be a relevant factor in the event of any business restructuring.
• Maintain records showing reasonable precautions taken to prevent unauthorised supply, as due diligence is a defence available.
• Implement internal controls to identify defined foods in your product portfolio to ensure necessary protocol is followed.

10. Part 6 (Compliance Obligations for Non-Packaged Drinking Water)

What it covers

Under the FSSA 2025, supply of unwholesome non-packaged drinking water by a drinking water producer is an offence, regardless of whether it knew that the water was unsafe. Non-packaged drinking water must meet prescribed requirements of quality.

The Director-General (Food Security) may issue written directions to food businesses or water suppliers where there is a risk to public health, such as suspected contamination or illness transmission.

Key compliances

• Set up a protocol for regularly testing water to ensure that it meets standards under Part 6 Regulations i.e. non-packaged drinking water.
• Ensure proper maintenance of infrastructure affecting water quality.
• Maintain records and evidence of all reasonable measures and controls as due diligence is a defence available.
• Monitor for any written directions issued regarding water safety.
• Prepare response plan in the event of a Director- General directive to suspend supply.
• Notify affected consumers (e.g. water treatment advisories), if directed by the Director- General.

11. Other provisions that commence with effect from November 28, 2025

While Parts 12, 13, 14 and 16 have also commenced, these provisions primarily relate to appeal mechanisms, regulatory powers, administrative arrangements, and miscellaneous matters. They do not impose direct operational obligations on food businesses at this stage and are not discussed in this compliance-focused update.

Conclusion: Preparing for the next phase of FSSA 2025 Compliance

The commencement of selected definitions and operative Parts of the FSSA 2025 marks a significant shift in Singapore's food-safety compliance landscape. While many of the newly commenced sections do not impose immediate operational duties, they now activate the legal framework for how future licensing, advertising, labelling, enforcement and pre-market approval obligations will apply across the food supply chain.

For food businesses, this means:

• Reassessing internal product classifications, including whether products fall within "food", "defined food", "primary produce", or "animal feed".
• Understanding the expanded scope of "content", "label" and "advertising", especially where digital platforms, QR codes or hyperlinks are used.
• Identifying compliance gaps early, particularly for novel foods, genetically modified foods, drinking-water operations, and activities that may later require licensing.
• Building tracking mechanisms for ongoing commencement notifications, as obligations will continue to activate in phases.
• Establishing documentation, due-diligence and record-keeping systems to prepare for SFA's monitoring and enforcement powers under Part 13.

In short, businesses that start strengthening their internal governance, product assessments and control frameworks now, will find themselves well-positioned when additional provisions of the FSSA 2025 come into force.

How Komrisk, our compliance management solution can help?

To help businesses in Singapore navigate the complex regulatory landscape under the Food Safety and Security Act 2025, Lexplosion offers a powerful compliance automation platform named Komrisk. Designed to simplify compliance management, Komrisk is a robust, tech-enabled platform that provides a centralised repository of compliance obligations, presented as actionable tasks across legislations and jurisdiction. With features like automated alerts, compliance calendars, centralized documentation and audit readiness tools, Komrisk empowers businesses to proactively stay compliant, reduce legal risk and respond quickly to regulatory changes. By transforming manual compliance into a streamlined digital process, Lexplosion helps businesses build a culture of compliance while focusing on what they do best. Whether you are a food manufacturer, importer, retailer, online seller, Komrisk helps you stay ahead of changing regulatory requirements ensuring that your compliance processes evolve in step with the FSSA 2025.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.