Key Compliances under Singapore’s Food Safety and Security Act 2025: Part 2

The Food Safety and Security Act 2025 (FSSA 2025) sets out a comprehensive and robust compliance framework for stakeholders across the food supply chain. In Part 1 of our FSSA blog post, we have explored key compliance obligations for businesses involved in import, export and transhipment of food; traceability obligations; pre-market approval for defined foods and non-packaged drinking water.

In Part 2, we are highlighting some of the compliances relating to licensable food businesses, the newly introduced Minimum Stockholding Requirement (MSR), 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.

Food Business Licensing Requirements

FSSA 2025 mandates licensing requirements for a food business to carry out a licensable food business as per the First Schedule to the FSSA. An application for the license must be accompanied by a Farm Management Plan if engaged in primary production or a Food Control Plan in other cases required by regulations under the Act. These plans must be accepted by the Agency, and it requires applicants to demonstrate clear and structured measures for maintaining food safety standards across their operations. The plans must outline how the business will manage risks, maintain hygiene, ensure traceability, and respond to food safety incidents. Licences are valid for up to five years but can be modified, suspended or revoked for non-compliance, fraud or safety concerns. Post-revocation, the Agency may order unsold food or produce to be withheld or destroyed. Non-compliance with such directions can result in fines up to $30,000 and/or imprisonment, especially for repeat offences.

Key compliances

• Apply for license if the activity is a licensable food business.
• Prepare and submit the relevant plan with your application: Farm Management Plan (for primary production businesses), Food Control Plan (for all other licensable food businesses, as prescribed).
• Ensure compliance with licence conditions including hygiene and sanitation.
• Ensure a clean compliance history. This is a factor in the Agency’s decision to grant a license.
• Maintain records that enable the Agency or its authorised officers to verify compliance with the accepted farm management plan or food control plan as the case maybe.
• Track and apply for renewal of licence before expiry (valid for up to 5 years).
• Follow the prescribed traceability compliance obligations.

Traceability Obligations for Licensable Food Businesses

As per the FSSA 2025, prescribed licensable food businesses must maintain traceability records to identify and track food supplied, handled, or produced. Businesses must keep and readily access prescribed information for a specified period after supply. This includes the identity and contact details of the recipient, the manufacturer or primary producer, the supplier, and a description of the food (commodity, brand and lot) along with any other prescribed data. Failure to comply is an offence and may attract a fine of up to $10,000.

Key Compliances

• Ascertain if your licensable food business is prescribed under the Gazette to be subject to this Division [Section 98(1)].
• Maintain and have ready access to the traceability information such as contact details of the supplier, description of the food.
• Establish systems and processes in place to identify and locate the food supplied, handled or produced.
• Have proper tracing mechanisms in place to track the source of supplied food.
• Establish and document food recall procedures.
• Conduct tests / simulations of recall procedures (if required) to ensure preparedness.
• Notify Singapore Food Agency (SFA) within 24 hours of any recall by the proprietor.
• Provide required records to authorised officers / inspectors.

Compliance with Minimum Stockholding Requirements (MSR)  

The FSSA  2025 has stipulated Minimum Stockholding Requirement (MSR) for entities that are subject to holding minimum stock of MSR products to strengthen the resilience of its food supply. This requires certain agri-food supply chain participants to maintain Minimum Stockholding Requirements (MSRs) under Sections 20, 21 and 22 of the  FSSA 2025. Once a Trigger notice is issued by the authorities, an entity to whom such notice has been issued will be required to hold a minimum quantity of stock daily (daily MSR) and over a set period (average MSR). The notice specifies the period, quantities and storage locations. Entities must report changes in their capacity or intent to cease MSR activities and may assume or divide MSR obligations with other entities. Non-compliance with daily or average MSRs can lead to civil penalties or criminal offences, especially if the failure is intentional or reckless.

Key compliances

• Identify if your business engages in MSR activities (e.g., producing, importing, storing, or distributing MSR products).
• Check if you have received a trigger notice from the Director-General, Food Security.
• Once the Trigger notice is received monitor the daily MSR and the average MSR.
• Comply with trigger notice conditions like period, quantities and storage locations and maintain records.
• Report any material changes, including intention to undertake or stop MSR activities or any operational changes that can affect your MSR capacity.
• Submit reports as required.
• Hold daily designated quantity of stocks (Daily MSR).
• Hold average quantity of stocks for the relevant period (Average MSR).

Food Safety Requirements and Sustainable Primary Production Measures

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. Part 7 directions will bind many key stakeholders including, food business proprietors (licensed or not) and producers of animal feed (whether licensed or not), Non-compliances or contravention with such directions will lead to an offence and the businesses will be liable to pay a fine up to $30,000 which can go up to $60,000 for repeat offenders.

A. Food safety

It is important to note at the outset that the directions are binding even on proprietors of food businesses that are not licensed. The Director‑General may issue binding directions to address food safety risks, including orders to clean or upgrade premises or equipment, stop unsafe activities, restrict movement of contaminated items or recall unsafe food. Directions can also apply to food workers including the handling of food and may require training, hygiene compliance or ceasing food handling. Where contamination is suspected, movement control or declaration directions may be issued. The Director-General may also direct certain persons to publish a public statement in Singapore to safeguard the public. The contents of the publication may also be specified.

Key compliances

• Establish a process to monitor directions and act on them promptly.
• Inform the Director‑General of the measures that will be taken to follow the directions for maintaining food safety.
• Regularly inspect your food premises, vending machines, and equipment for any posted directions from the authorities as the directions take effect immediately.

• Regularly notify the Director‑General about steps taken for complying with the direction for maintaining food safety and give written notice to the Director‑General after complying with the direction.
• Maintain clean and sanitary conditions of the food premises to the satisfaction of an authorised officer or food inspector.
• Ensure food workers meet hygiene, training and health requirements and cease their food handling if so directed.
• Have systems and processes in place to prevent processing of unsafe and unsuitable food in premises.
• Remove all sources of suspected hazards and contamination.
• Issue public statements to alert consumers when directed.
• Pay up costs incurred by the Agency if it must act due to non-compliance on part of the business.
• Maintain record of all directions received and ensure policies processes are put in place to prevent reoccurrence.

B. Animal feed and primary production  

The Director‑General may issue binding directions to manage risks related to animal feed and primary production activities. These include directions to impose movement controls, recall or manage unfit animal feed, contain biosecurity threats affecting food-producing animals or their habitats and require corrective actions. Powers may also extend to requiring the revision of farm management plans to mitigate significant hazardsNon-Compliance with these directions will lead to a fine of up to $30,000 and can rise to up to $60,000 for repeat offenders.

Key compliances

• Have systems and processes in place to prohibit and restrict the movement or relocation of any biosecurity matter or biosecurity carrier.
• Comply with the obligation to isolate or destroy, spread biosecurity matter or biosecurity carrier in the premises.
• Conduct recall of unsafe or mislabelled feed and notify the Director‑General upon completion.
• Take follow-up action such as destruction, reprocessing, storage or relabelling of affected feed as directed
• Revise and submit farm plans when directed to address production or hazards.
• Keep and have ready access to the prescribed particulars and contact details of the person to whom the animal feed was supplied or exported.
• Carry out and notify the Director General corrective actions.

The compliance obligations outlined above address additional requirements under the consolidated food safety and security regime, building on the key issues discussed in Part 1 of our blog series. In Part 3, we will explore further provisions of the FSSA 2025 and their corresponding compliance obligations, underscoring the importance of proactive planning and system readiness.

How Lexplosion can assist you?

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 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.

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.