On 28 November 2025, the first tranche (“Tranche 1“) of the Food Safety and Security Act 2025 (“FSSA“), which was passed by Parliament on 8 January 2025, came into effect. The FSSA will be implemented in phases, and Tranche 1 comprises provisions concerning defined food and non-packaged drinking water.
For more information on the passing of the Food Safety and Security Bill, please see our December 2024-January 2025 NewsBytes article titled “Food Safety and Security Bill Passed – Enhancing Food Safety and Security Regime in Singapore“.
Defined Food and Pre-Market Approval
Parts 5 and 8 of the FSSA makes it an offence to supply any defined food in Singapore, handle food intended for supply in a manner that could render the food a defined food, or produce primary produce classified as defined food. Under the FSSA, defined food refers to food that is or contains: (i) a novel food without a pre-market approval; (ii) a genetically modified (“GM“) food without a pre-market approval; or (iii) an edible insect-like species which is not a catalogued insect-like species.
Subsidiary Legislation
The following pieces of legislation were issued to implement Part 5 of the FSSA.
- Food Safety and Security (FSSA Authorisations — Administration) Regulations 2025 (“FSS (FSSA Authorisations – Admin) Regulations“)
The FSS (FSSA Authorisations – Admin) Regulations outline the application process for pre-market approval from the Singapore Food Agency (“SFA“) for novel and genetically modified foods. This includes the documentation and information required by SFA to process the application, the person who needs to apply, the timing of the application, and the application fees.
For more information on novel and GM food, please refer to the following SFA resources:
Any edible insect-like species not included in the Order is defined food. To have an edible insect listed in the Order, applicants must submit the following information to SFA for assessment:
- the scientific name of the insect and the specific life stage(s) intended for human consumption;
- details of the farming or processing methods, including the type of substrate used to feed the insect;
- proof of history of use of the insect as human food in countries outside Singapore;
- information relied on to establish that the species and life stage is safe for consumption (e.g. scientific literature and laboratory reports); and
- the Singapore address or entity of the applicant.
For more information on catalogued insect-like species, please refer to SFA’s Insect Regulatory Framework.
Provision of Non-Packaged Drinking Water (“NPDW”)
Part 6 of the FSSA grants SFA the authority to regulate the quality of NPDW supplied by drinking water producers providing a drinking water service (“DWS“).
The FSSA defines “drinking water” as that which is intended for human consumption or for purposes connected with human consumption (such as the washing, and preparation or cooking of food). Drinking water producer includes any person (an entity or individual) who carries out drinking water production in the course of business, and DWS means a service that involves drinking water production and supplying drinking water to another person by means of a reticulation system or in bulk. Part 6 of the FSSA aims to ensure that NPDW provided in the course of business is wholesome and suitable for drinking.
Subsidiary Legislation
The Food Safety and Security (Non-Packaged Drinking Water) Regulations 2025 (“FSS (NPDW) Regulations“) set detailed requirements on the quality of NPDW and DWS, including:
- establishing specific criteria for assessing the wholesomeness of NPDW;
- setting out details on methodology and assessment to ensure drinking water quality; and
- impose additional duties on selected DWS providers capable of producing more than four cubic metres of NPDW daily, and are supplying the NPDW. These providers are called Water Quality Management Plan (“WQMP“) water providers.
WQMP water providers may only offer drinking water services after obtaining SFA approval for their WQMP. The FSS (NPDW) Regulations provide for the process for applying for WQMP approval and for its annual review. In this regard, SFA has released the Guidelines on Drinking Water Quality Management Plan for NPDW, which outline best practices on monitoring, assessment, and risk management which can be adopted by WQMP water providers in the preparation of a WQMP. The guidelines take reference from international guidelines such as those published by the World Health Organisation (WHO).
The FSS (NPDW) Regulations mandate WQMP water providers to review their WQMPs at least once a year with a view to updating and improving their plans. They are to submit a report of the review to SFA by 31 December of the year in which the review is conducted. The Report of Review on WQMP form is available here.
The FSS (NPDW) Regulations also specify offences and penalties for breaches of regulatory requirements, such as not sticking to an approved WQMP when supplying water as a DWS provider.
Click on the following links for more information:
- Food Safety and Security Act 2025 (Commencement) (No. 2) Notification 2025 (available on the Government Gazette website at egazette.gov.sg)
- SFA’s Food Safety and Security Act page (available on the SFA website at sfa.gov.sg):
Our Team has deep knowledge into the entire cycle of the food and beverage business from growth to import to sale to consumption, just to highlight some aspects. Do reach out to us for a one-on-one discussion on how the changes here will impact you.
Disclaimer
Rajah & Tann Asia is a network of member firms with local legal practices in Cambodia, Indonesia, Lao PDR, Malaysia, Myanmar, the Philippines, Singapore, Thailand and Vietnam. Our Asian network also includes our regional office in China as well as regional desks focused on Brunei, Japan and South Asia. Member firms are independently constituted and regulated in accordance with relevant local requirements.
The contents of this publication are owned by Rajah & Tann Asia together with each of its member firms and are subject to all relevant protection (including but not limited to copyright protection) under the laws of each of the countries where the member firm operates and, through international treaties, other countries. No part of this publication may be reproduced, licensed, sold, published, transmitted, modified, adapted, publicly displayed, broadcast (including storage in any medium by electronic means whether or not transiently for any purpose save as permitted herein) without the prior written permission of Rajah & Tann Asia or its respective member firms.
Please note also that whilst the information in this publication is correct to the best of our knowledge and belief at the time of writing, it is only intended to provide a general guide to the subject matter and should not be treated as legal advice or a substitute for specific professional advice for any particular course of action as such information may not suit your specific business and operational requirements. You should seek legal advice for your specific situation. In addition, the information in this publication does not create any relationship, whether legally binding or otherwise. Rajah & Tann Asia and its member firms do not accept, and fully disclaim, responsibility for any loss or damage which may result from accessing or relying on the information in this publication.