Key Compliances under Singapore’s Food Safety and Security Act 2025: Part 1

Food safety and security laws are critical for safeguarding public health. It is essential that businesses comply with the applicable regulatory requirements to ensure food quality, hygiene and consumer protection. Adherence to these standards also help prevent risks and disruptions across the supply chain.

Singapore recently overhauled its food legislation framework by enacting the Food Safety and Security Act 2025 (FSSA 2025). The FSSA 2025 consolidates various food-related regulations and repeals both the Sale of Food Act 1973 and the Wholesome Meat and Fish Act 1999. To ensure a smooth transition, the FSSA 2025 will be implemented in phases. Provisions relating to defined foods and non-packaged drinking water will take effect in the second half of 2025, with full implementation by 2028. In addition to repealing existing laws, the FSSA 2025 introduces consequential amendments to several related statutes including the Animals and Birds Act 1965, Control of Plants Act 1993, Fisheries Act 1966, Environmental Public Health Act 1987, Feeding Stuffs Act 1965, Consumer Protection (Trade Descriptions and Safety Requirements) Act 1975 and others.

The FSSA 2025 also includes transitional and savings provisions to manage the shift from the repealed and amended laws. While awaiting full implementation, stakeholders can begin assessing the requirements envisaged in the FSSA 2025 and aligning their processes accordingly to remain compliant.

In Part 1 of this post, we highlight key compliance obligations for businesses involved in the import, export and transhipment; traceability obligations; pre-market approval for defined foods and non-packaged drinking water.

In Part 2, we have highlighted some of the compliances relating to licensable food businesses, the newly introduced Minimum Stockholding Requirement (MSR), and directions relating to food safety and animal feed. We will be concluding this series in Part 3 by covering compliances relating to marketing & advertising of food products, agri-food, and plant pesticides and by summarising the consequences of non-compliance. As the FSSA 2025 is a comprehensive piece of legislation, please note that this blog series highlights only some of its key requirements and is not intended to provide an exhaustive account of all compliance obligations.

Licensing and Permit Requirements – Import, Export, Transhipment

The FSSA 2025 requires businesses involved in the import, export and transhipment of food, food contact article or a prohibited animal feed by virtue of Section 76 of the Act to obtain licenses and permits. Import, export and transhipment businesses must comply with the law by applying for the relevant licenses and consignment permits (the two- tier approach):

• Import and export license for controlled items (this is usually granted for a period not exceeding five years) and
• Import, export and transhipment consignment permit which is granted for a period stated in the permit.

The FSSA 2025 imposes serious penalties including fines and imprisonment for offences such as unlicensed dealings, non-conforming consignments or proceedings without required inspection approvals. Both intentional breaches and strict liability offences are covered, reinforcing the importance of regulatory compliance across the supply chain.

Key compliances

• Apply for the appropriate license or permit and submit FSSA applications.
• Maintain a clean compliance history as this is a factor in the Agency’s decision to grant a license/permit.
• Comply with any restrictions on import/export/transhipment from/to certain countries.
• Monitor your license and permit validity periods.
• Do not import/export items that are unsafe, unsuitable or contaminated.

Traceability Obligations for Licensed Importers

As per the FSSA 2025, licensed importers have an obligation to comply with record keeping and traceability requirements. These provisions ensure that importers cantrack the source and movement of import-controlled food and related items throughout the supply chain by maintaining detailed records of supplier and manufacturer information, product identification and distribution channels. It also enables to pin-point the origin and journey of any food item in the event of any directions for recall issued.

Key compliances

• Check and maintain records of any import that requires you to adhere to traceability obligations.
• Meticulous record-keeping and retain all information in accessible form.
• Implement procedures to identify supplier and manufacturer information to locate imported items.
• Establish and document recall procedures.
• Conduct tests / simulations of recall procedures (if required) to ensure preparedness.
• Notify Singapore Food Agency (SFA) within 24 hours of any recall.
• Provide required records to authorised officers / inspectors.

Pre-Market Approval for Defined Foods

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. The approval, which is generally non-transferable, may include conditions and can be cancelled if obtained through misrepresentation, if conditions are breached, or if public interest so requires. 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.

Compliance Obligations for Non-Packaged Drinking Water

Under the FSSA 2025, supply of unwholesome non-packaged drinking water by a drinking water producer is an offence, regardless of whether it knew the water was unsafe. Non-packaged drinking water must meet prescribed standards of quality. Offenders may face fine of upto $20,000 with additional daily penalties for ongoing violations. A due diligence defence is available if the producer can prove reasonable precautions were taken.

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. These directions may include suspension of water supply, testing, reporting or requiring consumer warnings (e.g. boil water).

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. 
• Proper maintenance of infrastructure.
• 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.

These compliances represent a few critical requirements in the consolidated food safety and security regime. In Part 2 of the post, we will explore other key aspects of the FSSA 2025 and the corresponding compliance requirements to highlight the importance of proactive planning and systems readiness.

How Lexplosion Can Help?

To help food businesses in Singapore navigate the complex regulatory landscape under the Food Safety and Security Act 2025, Lexplosion Solutions Private Limited offers a powerful compliance automation platform named Komrisk. Designed to simplify compliance management, Komrisk enables businesses to track, manage, and monitor all regulatory obligations in real-time, including those related to licensing, food safety plans, minimum stockholding requirements, and traceability protocols. With features like automated alerts, compliance calendars, centralized documentation, and audit readiness tools, Komrisk empowers food 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 — delivering safe, high-quality food to the market.

Authored by: Soumya Shuvra Das

Co-Authored by: Swapna Umakanth

Disclaimer

The information provided on this blog is for general informational purposes only and is not a substitute for professional legal advice. We are not a law firm and are not authorized to practice law in your jurisdiction. Laws and regulations are complex and constantly changing, and information that may be true in one jurisdiction may not apply in another. Before acting on any information you read here, you should consult with a qualified lawyer practicing in the relevant jurisdiction for your specific legal issues or concerns. While we strive to provide accurate and up-to-date information, we make no guarantees that the information on this blog is completely current or error-free. We disclaim any liability for any actions taken or not taken based on the information on this blog.