Key Compliances under Singapore’s Food Safety and Security Act 2025: Part 3

In previous blog posts relating to the Food Safety and Security Act 2025 (FSSA 2025), we’ve examined the key issues and compliance obligations arising from Singapore’s FSSA 2025. In Part 1 of the FSSA 2025 blog post, we have explored key compliance requirements for businesses involved in import, export and transhipment of food; traceability obligations; pre-market approval for defined foods and non-packaged drinking water. Part 2  of the FSSA 2025 blog post highlighted compliances relating to licensable food businesses, the newly introduced Minimum Stockholding Requirement (MSR), and directions relating to food safety and animal feed. To conclude the series with our final instalment (Part 3), we have focused on key compliance requirements relating to marketing and advertising requirements of food products, and animal feed producers and handlers of plant pesticides.

Marketing and Advertising of Food Products

FSSA 2025 mandates that food businesses declare information relating to the ingredients, constituents or their proportions in food products to prevent misleading or deceptive marketing practices. Such practices include falsely describing food, breaching the advertising regulations and promoting malpractices. A food will come under the purview of “falsely described” food if is not meeting the applicable standard it claims to meet, the packaging or labelling creates a false impression in the mind of the consumers about its composition, effect, nature or origin or if the description conceals the fact that the food is unsafe or unsuitable. Non-compliance can attract penalties of up to $30,000, extendable to $60,000 for repeat offences.

Key compliances

• Have processes in place to avoid supplying falsely described food. 
• Have systems and processes in place to prevent misleading or deceptive labelling of food.
• Identify all potential risks that may affect the safety or suitability of a food product to avoid concealing unsafe or unsuitable factor related to a food product.
• Identify “defined food” in your product range to ensure you do not advertise it unless permitted under the law.
• Maintain internal checks to prevent violations and respond promptly to issues relating to labelling, advertising or product description.
• Retain supporting documentation to substantiate marketing claims, warranties and regulatory compliance.

Obligations Relating to Agri-Food Production

FSSA 2025 under Part 11, Division 2 & Division 3 has outlined mandatory compliance obligations for producers of animal feed and operators of plant pesticides. These aim to streamline the licensed production of animal feed and to regulate unregistered and unauthorised plant pesticides. Under the Act, businesses involved in animal feed production must obtain a license. Similarly, plant pesticide products must be registered and approved labelling requirements must be met. The law has imposed a penalty of $30,000 for using unregistered plant pesticides, which can go up to $60,000 for repeat offenders.

Animal Feed

The FSSA 2025 under Sections 191 to 197, has laid down the criteria and conditions for application and renewal of animal feed production license, which must be accompanied by a feed control plan. The assessment is done based on compliance history, conditions of the premises and public interest. The applicant for an animal feed production licence might have to resubmit a feed control plan for the purpose of further assessment upon request by the Agency. Regulatory actions or past convictions can weigh heavily against an applicant; therefore, maintaining a clean compliance record is essential for license approval or renewal. The licence is valid for up to a period of five years but can be modified or revoked without compensation if there is non-compliance, fraud or risks to public interest. Regulatory actions include penalty of $20,000 upon producing animal feed without a valid animal feed production licence, which can go up to a fine of $40,000 and can lead to suspensions or additional security requirements. If a licence is revoked, the Agency may prohibit the sale of affected feed and require its disposal, with penalties for non-compliance.

Key compliances

• Obtain an Animal Feed production license.
• Submit a Feed Control plan along with the application for Animal Feed production License.
• Ensure required planning permissions (e.g. zoning approval) are secured.
• Comply with all the prescribed conditions of the Agency.
• Comply with the accepted feed control plan for producing animal feed.
• Furnish a performance bond, guarantee or any other form of security of such amount as per the requirement of the Agency.
• Regularly assess business practices for potential regulatory breaches.
• Have processes in place to cease sale of all feed produced under a revoked licence.
• Follow Agency directives to safely dispose of affected stock.

Traceability Obligations for Animal Feed Production

FSSA 2025 by virtue of Sections 198-201, delineates the traceability obligations of an animal feed production licensee for the purpose of producing animal feed even when such feed has not been supplied or is for export. The FSSA 2025 requires all animal feed production licensees to maintain and have ready access to the prescribed information as required by the Agency to trace feed from supplier to customer and retain it for a set period. They must have procedures to identify, locate, and recall feed if it’s unfit and notify the Agency within 24 hours of any recall. The obligations are focused on enhancing the traceability of the animal feed produced, supplied or exported by the animal feed production licensee. Upon contravening the obligations as related to the traceability obligations and maintenance of records, the law imposes a penalty up to $10,000.

Key compliances

• Maintain and have ready access to the information related to prescribed identity particulars and prescribed contact details of the person to whom you have supplied animal feed.
• Maintain and have ready access to the information related to prescribed contact details of the producer of the animal feed.
• Have systems and processes in place to identify and locate the animal feed produced, supplied or exported by the animal feed produced by you.
• Have systems and processes in place to trace animal feed as per the prescribed procedures.
• Have systems and processes in place to recall such animal feeds whose fitness for purpose are in doubt.
• Notify the Agency within 24 hours upon deciding to recall the animal feeds which are unfit.
• Provide information to the authorised officer or a food inspector within 24 hours upon request.

Plant Pesticides

Under the FSSA 2025, businesses must apply to register plant pesticide products by submitting the prescribed forms, fees, and information, including a local address and label details. The Agency evaluates the product’s quality, safety, and labelling before registration and may require sample testing or accept third-party evaluations. The labels must meet the “labelling criteria” and provide clear safety and usage instructions. Registration remains valid unless cancelled or suspended due to safety risks, regulatory breaches, or false advertising. Separately, certified pesticide operators must meet qualification and suitability criteria like relevant experience and a strong compliance record. The Agency also considers any past regulatory action or convictions and may reject or modify an appointment if it’s not in the public interest. Non- compliance penalty can be up to $30,000 for unregistered plant pesticide use and can go up to $60,000 for repeat offenders.

Key compliances

• Apply for registration of plant pesticide product including all prescribed details and provide a local service address or authorised representative.
• Bear all cost incurred by the Agency for the evaluation of a plant pesticide product for the purpose of granting registration.
• Comply with the labelling criteria for containers of a plant pesticide product.
• Have systems and processes in place to ensure active use post registration (inactivity exceeding 12-months may trigger cancellation of registration).
• Establish a review process to ensure all advertisements are accurate, compliant and not deceptive.

Conclusion

The FSSA 2025 introduces a more robust and unified compliance framework towards food safety and food security, with stricter penalties, including fines of up to $60,000 and imposes strict liability in many cases. These strengthened provisions reinforce Singapore’s intent to improve food security and its zero-tolerance approach to food safety lapses. It also underscores the need for businesses to implement proactive compliance frameworks, ensure end-to-end traceability, and maintain uncompromising standards throughout the supply chain. A strong compliance history is essential for securing licences and registrations. Whether applying for a food business licence, animal feed production licence, or registration of plant pesticides, prior non-compliance, regulatory actions, or convictions can weigh heavily against applicants.

As implementation progresses, businesses must act early to align their compliances with the Act’s requirements, whether in traceability, labelling, advertising or stockholding. Proactive planning, internal controls, and end-to-end compliance are not just legal necessities but critical to sustaining consumer trust and supply chain resilience in Singapore’s evolving food landscape.

In this three-part series we have aimed to highlight some of the key compliance obligations introduced under the Food Safety and Security Act 2025. However, given the breadth and complexity of the legislation, this overview is by no means exhaustive. Businesses are encouraged to closely review the full regulatory framework and seek professional advice where necessary to ensure full compliance with all applicable provisions.

How can Lexplosion assist with your compliance management automation?

To help food businesses in Singapore navigate the complex regulatory landscape under the Food Safety and Security Act 2025, Lexplosion Solutions offers a powerful regtech compliance automation system 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, centralised 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.

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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.