Page 34 - FoodFocusThailand No.234 September 2025

SPECIAL TALK BY FDA

Additionally, the requirements for displaying a “Warning” - Size: Small items that can be accidentally swallowed
label on instant jelly and jelly snacks have also been revised. whole typically have a transverse diameter of less than 4.5
The statement “Minimum consumption is recommended for millimeters for round shapes, or less than 3.2 millimeters
children” must appear in red font, at a size no smaller than 5 for other shapes.
millimeters, within a clearly defined white-framed display area - Texture: Smooth and slippery textures, commonly found
to ensure maximum clarity. Furthermore, brown rice starch in agar and jelly, may increase the risk of choking.
must bear the label “Not to be used as milk replacement - Viscosity or hardness of the snack: Studies report that
for infant” in red font, at a minimum size of 5 millimeters, on a jelly made with konjac requires significantly more pressure
contrasting background. This warning must be placed directly to break, ranging from 10 to 20 Newtons, compared to jelly
beneath the term “Brown Rice Starch” to avoid confusion and made with other gelling agents, which breaks under just 2–4
prevent the product from being misused as a substitute for Newtons of pressure.
infant formula, a problem frequently encountered in the past. 2. A mini cup, or any small container of similar design, is
A grace period of up to two years is granted to food intended to allow two methods of consumption. In the first
entrepreneurs whose products received food registration method, the mini cup is placed beneath the lips, and the
numbers before the effective date of this notification. In other jelly is quickly sucked into the mouth, increasing the risk of
words, products registered prior to the revision may continue the product entering and becoming lodged in the trachea.
to be sold for an additional two years, but no later than the In the second method, the mini cup is positioned above the
3 of May, B.E. 2570 (2027). This allows food entrepreneurs lips while the head is tilted back into a chin-up posture, which
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sufficient time to make necessary adjustments to their labels expands the trachea and further raises the risk of the jelly
and packaging before the deadline, after which additional costs becoming stuck in the airway.
related to labeling modifications may be incurred. Therefore, instant jelly or jelly snacks in mini cups or any
Additional information has been provided by the Food small containers of similar design are classified as food forms
and Drug Administration through the issuance of the FDA that pose a significant risk of being accidentally swallowed
notification titled “Clarifications on the Notification of the Ministry in a single motion, even with minimal force or pressure. This
of Public Health (No. 456) B.E. 2568 (2025)”. This document can lead to the jelly passing into and obstructing the trachea,
includes details of the repealed Ministry of Public Health resulting in choking, respiratory blockage, or even death.
notifications, definitions and conditions for certain processed These risks are consistent with product recalls involving jelly
foods, guidelines for food and nutritional labeling, warning label and jelly snacks in several international markets.
requirements, references to relevant Ministry of Public Health
notifications on microbiological pathogens in processed foods, Adaptation Guidelines for Food Entrepreneurs
as well as provisions on penalties, transitional measures, and 1. Food producers or importers of processed foods
enforcement guidelines. packaged in ready-for-sale containers — specifically, brown
As a result of the Notification of the Ministry of Public Health rice starch, instant jelly and jelly snacks, sauces in sealed
(No. 456), other related regulations also required revision containers, bread, chewing gum and toffees, meat products,
and updating. This led to the issuance of the Notification of as well as ready-to-eat and ready-to-cook meals — are
the Ministry of Public Health (No. 457) B.E. 2568 (2025), encouraged to carefully review the regulatory details outlined
issued by virtue of the Food Act B.E. 2522 (1979), Re: in the revised Notification of the Ministry of Public Health and
Prescription of Foods Prohibited from Production, Import, the corresponding clarification issued by the Food and Drug
or Sale. This notification, which also took effect on the 3 of Administration. Updates on past and potential amendments
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May, B.E. 2568 (2025), designates instant jelly and jelly snacks to the Ministry of Public Health’s food-related notifications,
containing glucomannan or konjac jelly in mini cups or similar issued by virtue of the Food Act B.E. 2522 (1979), are
containers with a diameter or transverse width not exceeding available on the Food Division’s website, under the Ministry
4.5 centimeters as high-risk items due to the potential for of Public Health and the Food and Drug Administration.
choking, throat obstruction, and fatality. 2. Producers or importers of instant jelly or jelly snacks
The reason for repealing the Notification of the Ministry of containing glucomannan, konjac flour, or the food additive
Public Health No. 100 B.E. 2529 (1986), Re: Label Display for INS 425 are strongly advised to use appropriate and safe
Instant Jelly and Jelly Snack, along with its original provisions, containers, avoid the use of mini cups, and reformulate
and for revising the container type description from “…all their products to reduce the jelly’s hardness and viscosity
types…” to “…konjac mini-cup jelly” or “…of similar nature,” to safer levels.
is to enhance clarity for practical compliance with relevant This regulatory revision presents both opportunities and
regulations and to support effective monitoring both before challenges for food entrepreneurs. On one hand, it can
and after the products enter the market. This surveillance is help elevate overall food product standards; on the other,
essential due to varying levels of food safety risks identified it requires all involved parties to swiftly adapt to the new
in academic studies published after the notification’s initial changes by thoroughly studying and understanding the
enforcement on the 7 of October, B.E. 2545 (2002), particularly updated regulations, enhancing manufacturing processes,
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regarding the risk of choking, which may result from the and properly modifying labeling practices. We firmly believe
following factors: that, with the support of available information and guidance,
• Food-related Factors food entrepreneurs will successfully navigate this transition
- Shape: Round, elliptical, or oval shapes are particularly into a new era of food safety and compliance.
prone to causing choking hazards. In a study by Riley et al.
(1995), medical records of 342 patients with tracheal obstruction
were analyzed. The findings showed that the majority of cases
were caused by round-shaped objects (252 patients or 73.7%),
followed by objects with sharp tips (80 patients or 23.4%), and More Information Service Info C002
square-shaped items (10 patients or 2.9%) .
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