2nd reading of the Food Safety & Security Bill - Opening speech by SMS Koh Poh Koon

9 January 2025

Opening speech by SMS Koh Poh Koon at the 2nd reading of the Food Safety & Security Bill on 8 Jan 2025.

Introduction

Mr Speaker, my Minister has given Members an overview of the Food Safety and Security Bill and elaborated on some of the key proposed amendments to the food safety regime. I will further elaborate on four areas:
1. First, how the Bill will enable a shared commitment across Government, industry, and consumers in pursuit of food safety;
2. Second, how we aim to minimise regulatory burden on the food industry;
3. Third, how we intend to strengthen our food resilience in the face of emerging challenges;
4. Fourth, how the Bill will be implemented in stages.

Enabling shared commitment in ensuring food safety

The agri-food supply chain is getting increasingly complex, involving multiple stakeholders and more potential points of failure. Before food reaches our tables, the base ingredients are very likely grown in multiple countries, processed in yet another country, and then packaged and distributed to supermarkets and retail food businesses locally. Ensuring food safety from farm to fork requires every player across the food value chain to play their part. It requires a shared commitment from Government, industry and consumers.
The Bill therefore contains provisions aimed at two agri-food production inputs which, if not properly used or produced, can directly affect the safety of food produced namely, animal feed and plant pesticides.
Parts 3 and 11 of the Bill regulate the import and the production of animal feed for food-producing animals, and Part 11 regulates the use of plant pesticides that are for growing food.
1. Contaminated feed can expose food-producing animals to foodborne illnesses which can endanger consumer health and disrupt farm production.
2. Excessive use of plant pesticides can leave high levels of harmful chemical residues on fresh produce, which may be difficult to wash off and pose health risks to consumers when ingested.
Through amendments in Division 6 of Part 17 of the Bill, SFA will regulate animal feed for food producing animals while NParks will regulate animal feed for non-food producing animals. Through amendments in Division 4 of Part 17 of the Bill, SFA will regulate pesticides use on edible plants while the use of pesticides other than for growing of food will be deregulated.
1. The changes better match and support the respective regulatory missions of SFA and NParks.
2. SFA’s concern is one of food safety and security for humans, whereas NParks considers protection of animal health.
  1. Hence, under the Bill, businesses which manufacture animal feed for food producing animals will need to get a licence from SFA. Businesses which manufacture animal feed for non-food producing animals will need a licence from NParks. This will ensure that feeds used are fit for their intended purpose and makes it clearer for our businesses.
  2. Currently, plant pesticides for both food and non-food plants require registration. Going forward under the Bill, product registration will only be mandatory for pesticides used on edible plants. Given that such plants would be ultimately consumed by people, improper use of pesticides can pose food safety risks. Pesticides use for non-food plants will no longer require registration as they are not intended for human consumption and will not compromise food safety. Existing registrations of food plant pesticides will be transitioned without the need for re-registration.
  3. Certification will continue to be required for all pesticide operators applying or supervising pesticide use on edible plants that are intended for human consumption, to ensure that these individuals are trained to apply pesticides safely. This excludes the use of pesticides on edible plants grown for personal consumption, such as those in home gardens, or whole edible plants which are retailed in pots, such as potted herbs.

Water is another key component, integral to every stage of the food value chain from production to preparation for sale or supply. Under Part 6 of the Bill, we will continue to require those providing a drinking water service to supply wholesome drinking water that is safe for human consumption.

As technology advances, we are seeing innovations across different parts of the food value chain, along with the emergence of innovative food types. Their long-term effect on human health needs to be evaluated. We must therefore indicate clearly to businesses which are developing or selling these products what their responsibilities are.
To achieve this, Part 5 of the Bill will introduce a category of “defined food” to help industry navigate the types of food that are of higher regulatory concern and therefore require prior approval before they can be supplied or advertised in Singapore as food. This category will comprise yet-to-be approved novel foods, genetically modified (GM) foods and insect-like species. Once approved, such food will then be taken off the defined food list and may be freely supplied in Singapore.
1. The Bill formalises SFA’s existing practice for novel foods, insects and GM foods, and seeks to ensure any food safety risks are identified early, without stifling innovation. Over time, this would foster greater trust and confidence among consumers and industry stakeholders.
2. We do not expect the Bill to lengthen the approval process. SFA will continue to engage with food companies and provide guidance to facilitate the approval process.

Alongside safety regulations, marketing plays a crucial role in communicating critical information about food such as ingredients, allergens and nutritional value. Modern marketing strategies have also transformed how businesses influence consumers’ food purchase decisions.
Hence, Part 10 of the Bill sets out offences relating to misleading or deceptive marketing, covering newer forms of advertising and innovations in food labelling such as the use of QR codes. It also more clearly defines the parties responsible for ensuring accurate and substantiated food labelling and advertising.
1. It can be hard for consumers to verify the credibility of claims such as the composition, effect and origin of food before consumption. Misinformation can potentially compromise food safety and consumer health.
2. Provisions under the Bill will place the onus on food suppliers to provide accurate information and representations of the food, so that consumers can make informed choices.

Between 2022 and 2024, an average of 43% of foodborne gastroenteritis outbreaks resulted from poor food safety practices by food workers. Therefore, foodborne illnesses can be reduced significantly when food workers:
1. Understand the importance and the basics of food handling and safe practices; and
2. Are subject to monitoring of their food handling proficiency.

Under clause 103, it is an offence if a licensed food business deploys an untrained individual as a food worker in that business. A food business licensee should be proactive in ensuring that food workers are current in their food safety knowledge and attend refresher training before their training certifications expire. These measures will help to foster a strong food safety culture, reinforce food safety protocols, reduce the risk of safety lapses and ultimately protect consumers.
1. Businesses can use SFA’s newly launched Food Handler Digital Data Hub to track the expiry dates of their workers’ certification.
The food industry is responsible for ensuring their food is safe. It is not practical nor possible for SFA to verify and test all food items before consumption. We take a risk-based approach, aligned with international standards, to inspecting the safety of our food at the border, prioritising checks on food items that have higher safety risks. Hence, food products may sometimes still be found to be unsafe for consumption after they enter the market. When this happens, the food industry and SFA must be able to swiftly recall products to prevent the products from further circulating in the market and to reduce the potential for widespread illness or harm from occurring.
1. To implement swift recalls of products, there must be proper record-keeping. While some progressive industry players practice record-keeping, it is not consistently implemented across the sector. As a result, significant effort is often required to trace implicated food batches during incidents.
2. To address this, Parts 3, 4 and 11 of the Bill imposes traceability and record-keeping obligations on selected licensed food businesses, licensed importers and licensed animal feed producers.
  1. In cases of voluntary recalls initiated by industry due to food safety concerns, the industry will also be required to inform SFA as soon as practicable or within 24 hours after making the decision to recall. SFA will then identify other affected companies to ensure coordinated and timely responses to protect consumers.
  2. For example, through SFA’s proactive surveillance, a potential outbreak was averted last September when some mooncakes were found with excessive Escherichia coli (E. coli) levels. Effective traceability allowed for the swift identification and recall of the affected mooncakes, as the business had a good record-keeping system in place. The business was able to isolate the contaminated mooncakes and recall them swiftly with precision. This minimised the cost impact for the business as well because the alternative would have been to recall every single batch of mooncakes.
  3. To support the industry in this transition, SFA will undertake consultations in detailing records to be kept in subsidiary legislation. SFA will provide guidance documents to help compliance with the regulations. SFA is also developing a portal to facilitate the submission of documents from those required to maintain traceability records.

Minimising regulatory burden on the industry

Let me move on to how we aim to minimise regulatory burden on the industry, through providing greater operational flexibility and decriminalising less egregious offences. We are mindful of striking a balance between ensuring food safety and minimising compliance costs for businesses.
We are calibrating and updating our regulations to align with SFA’s risk-based approach to food safety.
Instead of prescribing requirements across businesses’ different operating contexts, each business will have the flexibility to devise and implement preventive measures suited to their operational model to ensure safe food and animal feed that is fit-for-purpose. This will be done through the Food Control Plan and Feed Control Plan which will be introduced as licence conditions under Part 4 and Part 11 of the Bill respectively.
1. All licensable food businesses which are not in primary production must design and implement a Food Control Plan while licensed animal feed producers must design and implement a Feed Control Plan.
  1. Today, businesses are already required to show they have measures to ensure food safety before SFA grants a licence.
  2. By taking an outcome-based approach, the Food Control Plan would not prescribe specific measures, but allow businesses to consider what works for them to meet food safety outcomes. This approach also recognises that food business licensees understand their operations best and are well-positioned to design effective food safety solutions.
  3. They will need to maintain these solutions to ensure hygienic and safe conditions and implement them throughout the licence period. It also ensures that food business licensees stay accountable even as new food products and business models emerge while encouraging innovative means to ensure food safety.
  4. SFA will provide guidance on the scope of the Food Control Plan and Feed Control Plan according to the operating modality of the different businesses.

My Minister also earlier mentioned how some breaches which are offences under existing law will be decriminalised. Under Parts 3, 4 and 11 of the Bill, SFA will decriminalise non-compliances such as breaches in licence or permit conditions that are less egregious in nature. Proportionate regulatory actions such as suspension of licence, imposing of financial penalties and issuance of directions, may be taken instead to avoid over-penalising less serious infringements.

Prepare for emerging challenges to safeguard food security

As Minister mentioned earlier, Singapore is no stranger to food supply disruptions.
As a small country which imports most of our food, we will not be able to insulate ourselves entirely from global food supply disruptions and the risks of unsafe food.
Local production buffers against the impact of supply disruptions and add to Singapore’s food security. For farms to viably produce and scale up in the long-term, we must balance sustainability with productivity to ensure that farming activities do not harm the environment in which animals and plants need to grow. Currently, all farms are already required to maintain their farms in clean and sanitary conditions. We will strengthen farm management and animal husbandry practices by introducing the Farm Management Plan (FMP) as a new requirement for those licensees undertaking primary production activities.
1. The FMP is aimed at mitigating risks to food safety, disease spread and ensuring sustainable production. Farmers will need to come up with their methods and processes addressing the key areas of waste, feed, fish stocking, biosecurity and disease management. Sea-based aquaculture farmers will also have to state how they will monitor water and sediment quality. All licensed farmers will need to appoint trained personnel to oversee implementation of the FMP.
  1. Two farming enterprises that have already benefited from having comprehensive farm management and documentation systems are Metropolitan Fishery Group, a local fish farm, and Sustenir Agriculture, a local vegetable farm. Both farms are certified under Singapore’s Good Agricultural Practices (SG GAP), a farm management standard that ensures food safety, produce quality and environmental sustainability.
  2. These practices have improved the farms’ operational efficiency, leading to higher productivity and safer, higher-quality products for their customers. The practices have also helped the farms to foster a culture of continuous improvement in farm management and production. Hence, we are optimistic that similar requirements in the FMP will benefit farms as well.
2. The FMP implementation will be phased to allow time for transition and SFA will provide the necessary support to help farms adjust to the new regulations.
  1. This includes working with Temasek Polytechnic’s Aquaculture Innovation Centre to conduct training to guide farms. The training course will be subsidised for Singaporeans and Permanent Residents.
  2. SFA will also provide guidance documents to help farmers understand the requirements and implementation of the FMP, and work with relevant agencies to contextualise requirements for different farm types.
  3. SFA will continue to support the industry in overcoming challenges through other practical means. This includes supporting capability development by co-funding the adoption of technology through the S$60 million Agri-food Cluster Transformation (ACT) Fund. SFA had also rolled out the Aquatic Animal Health Service (AAHS) in Aug 2023 to provide aquaculture farms with funded veterinary consultations, to assist them in farm management, disease diagnoses, prevention and control. More recently, in Nov 2024, SFA had announced the updated Singapore Aquaculture Plan (SAP) and initiatives that seek to uplift the aquaculture sector to be one that is more productive and sustainable.

The COVID-19 pandemic highlighted the fragility of global food supply chains, as unprecedented lockdowns disrupted production and logistics, causing delays and shortages. Geopolitical tensions and climate change also continue to add pressure to food systems worldwide.
As a small country with limited natural resources, import diversification remains a key strategy alongside efforts to build up our local production as a buffer against supply chain shocks. However, in the face of severe food supply disruptions or emergencies, these measures alone may not be enough.
Any food supply disruption could have significant impacts on businesses, consumers, and the Singapore economy. But it is hard to predict when a significant food disruption might occur.
1. On the other hand, food importers and wholesalers have limited incentives to hold reserve stocks above the commercial stockholding level and to invest in back-up food storage and distribution facilities.
2. In the absence of government intervention, Singapore may not keep sufficient domestic food stocks or back-up arrangements to mitigate the impact in food supply disruption scenarios adequately.
As such, another key food security measure the Bill introduces is the Minimum Stockholding Requirement (MSR) in Part 2 of the Bill.
1. The MSR would help to ensure that we have a certain level of in-country stocks to tide over impacts to supply during potential disruptions in the future.
2. Today, SFA only administers a Rice Stockpile Scheme, requiring rice importers to stockpile rice as an import licence condition under MTI’s Price Control Act. With the Bill, the powers to administer the RSS will be right sited with MSE. Instead of a licence condition, the MSR is a legal obligation under the Bill. The Minister will appoint a Director-General, Food Security (DG(FS)) to administer Part 2 of the Bill. The role of the DG(FS) will be to oversee and coordinate the formulation and implementation of our food security strategies in a comprehensive and effective manner.
  1. Part 2 of the Bill will enable the Minister to declare other essential food items or agri-food production inputs to be subject to stockpiling requirements if the need arises in the future.
3. That said, there are currently no plans to extend the stockholding requirement to entities other than rice importers, or to commodities beyond rice. We will consult closely with industry before prescribing any other food or an agri-food production input as an MSR product and any activity as an MSR activity attracting the stockholding requirement and provide sufficient lead time for the industry to meet the new requirements. For rice importers, the shift in legislative regime to the Minimum Stockholding Requirement will not change what they basically need to do today, which is to continue to stockpile prescribed quantities of rice.
  1. Under clause 23, a stockpiling obligation arises for an entity (called an MSR entity) when the entity is given a formal written notice (“Trigger Notice”) from the DG(FS). The trigger notice will indicate the specific requirements such as minimum stockholding quantity (daily and average monthly minimum), storage location, duration of the obligation, and implementation timelines.
  2. Every MSR entity will need to maintain a minimum daily MSR product stock, and a minimum average MSR product stock over a prescribed period. Unlike today where the only recourse is to revoke the rice import licence upon non-compliance, the Bill will deter non-compliance through a range of enforcement actions such as civil and/or criminal penalties.
Part 2 of the Bill will also confer powers on the DG(FS) to collect data and information from participants in the agri-food supply chain (other than the ultimate consumer) and others closely connected to the agri-food supply chain. This is to allow the DG(FS) to monitor and assess ways to strengthen Singapore’s food resilience in a timely manner. This information will also be used to support the administration of the MSR scheme. Steps will be taken to ensure only what is necessary is collected, and that what is collected is kept confidential.
1. First, the DG(FS) will specify the data required, how and when it should be provided and for what purpose.
2. Second, the DG(FS) will also work closely with relevant industry stakeholders to build up data reporting capabilities. This includes reviewing data collection processes and encouraging the adoption of technological solutions.
3. Third, the DG(FS) will take the appropriate data protection measures to ensure the data will not be mishandled. Information will not be disclosed to persons outside of the Singapore Public Sector except in an anonymised form or as required by an order of court.

Phased implementation approach to support industry in achieving regulatory compliance

Finally, let me talk about implementation.

We will implement changes in phases to facilitate a smooth transition for the industry.

To support the industry in the transition, the Bill will be implemented in phases by 2028, starting with that for defined foods and non-packaged drinking water in the second half of 2025. The industry and public will be informed ahead of the implementation of relevant provisions to allow time for them to prepare for the changes.
1. The Second Schedule spells out savings and transitions to ensure a smooth transition to the new regulatory regime.

We will also make consequential amendments to existing legislation that SFA leverages today, and repeal and replace the Sale of Food Act and the Wholesome Meat and Fish Act.

Conclusion

Let me conclude.
Given the complexities of our food supply chains today, strengthening food safety and security requires joint responsibility and collective effort. I thank the industry and members of the public who have contributed your views in shaping this Bill which marks a crucial step towards enabling this joint responsibility.
Thank you.