Thailand: Change to import requirements for honey, honeycomb and royal jelly (2018-05)

Date of issue: 9 September 2018

Date of effect: Immediate

Reference Number: MAA2018-05

Attention:

Industries—Industry bodies – Australian Food and Grocery Council, Australian Honey Bee Industry Council
Department of Agriculture and Water Resources—Central and Regional offices

Purpose

To notify exporters that, from 9 September 2018, Thailand will implement new product and establishment registration requirements for ‘cooked foods’ (see definition below) including honey, honeycomb and royal jelly.

Summary of key points

  • Thailand has notified of regulations requiring importers to register all cooked food imported into Thailand with Thailand’s Food and Drug Administration (FDA) by 9 September 2018. For the purposes of the regulation, ‘cooked food’ is defined as ‘food which people can eat immediately and includes food which must go through certain steps in order to be edible’. The regulation includes honey, honeycomb and royal jelly Refer Attachment 1 PDF [4 pages, 140 KB].
  • The FDA classifies cooked foods into two different categories, ‘high risk’ and ‘low risk’.

    Low risk products are defined as those which have been cooked to a minimum of 70oC for a minimum of 30 minutes or, cured with salt for a minimum of 313 days.

    High risk products are defined as those which have not undergone cooking or curing as defined for low risk products.

  • Each risk category has different registration requirements and exporters are encouraged to work with their importers to ensure all required documentation is provided to the FDA to complete the registration process by 9 September 2018.

  • The department is seeking further clarification from Thai regulators on the scope of the notification and effects on current trading arrangements, as well as future audit requirements. A longer transition period will also be requested by the department to allow importers/exporters to complete the registration process. An updated Market Access Advice will be issued as additional information is known.

Background

Thailand’s Ministry of Agriculture and Cooperatives (MOAC) is in the process of implementing the Animal Epidemics Act, BE 2558 (2015), BE 2018 (the Act). MOAC have developed a number of regulations under the Act which specify requirements for the importation of agricultural and food products. It was recently brought to the Department of Agriculture and Water Resources’ attention that MOAC had released a notification informing of new product and establishment registration requirements for importers of ‘cooked food’ derived from ‘carcases’. The Act defines cooked food from a ‘carcass’ as ‘anything derived from living or dead animals’ including honey, honeycomb and royal jelly.

An unofficial translation of products MOAC classifies as ‘cooked’ food is provided at Attachment 1. The department understands that Thai authorities would classify honey, honeycomb and royal jelly exported to Thailand as ‘cooked food’.

Under the Act, establishments producing high risk cooked foods are also required to be audited by Thailand’s Department of Livestock Development (DLD). The department understands that, provided the products have been registered with the FDA by 9 September 2018, Thai importers can seek interim access for high risk products prior to export establishments being audited by the DLD. The department will continue to encourage DLD to adopt a systems approach for any necessary audits and coordinate these through the department.

The Manual of Importing Country Requirements (MICoR) will be updated to reflect this change.

Further information

Contact Exports if you have any queries.

The information provided above is current at the time of writing and is intended for use as guidance only and should not be taken as definitive or exhaustive.  The Commonwealth endeavours to keep information current and accurate, however, it may be subject to change without notice.  Exporters are encouraged to verify these details with their importers prior to undertaking production/exports.  The Commonwealth will not accept liability for any loss resulting from reliance on information contained in this notice.

Last reviewed: 4 November 2019
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