G/TBT/N/THA/576  
14 May 2020  
(20-3582) Page: 1/3 
Committee on Technical Barriers to Trade  Original:  English  
 
  NOTIFICATION  
The following notification is being circulated in accordance with Article 10.6  
 
1. Notifying Member:  THAILAND   
If applicable, name of local government involved (Article 3.2 and 7.2):   
2. Agency responsible:  Food and Drug Administration (Thai FDA)  
Name and address (including telephone and fax numbers , email and website 
addresses, if available) of agency or authority designated to handle comments 
regarding the notification shall be indicated if different from above:   
3. Notified under Article 2.9.2 [X], 2.10.1 [   ], 5.6.2 [   ], 5.7.1 [   ], other :  
4. Products covered (HS or CCCN where applicable, otherwise national tariff 
heading. ICS numbers may be provided in addition, where applicable):  Fish oils  
5. Title, number of pages and language(s) of the notified document:  Draft Ministry of 
Public Health Notification, No. … B.E. …. (....) Issued by virtue of the Food Act B.E. 2522 
entitled "Fish oils" (6 page(s), in Thai)  
6. Description of content:  The Ministry of Public Health (MOPH) considered that 
requirements of safety and quality for fish oils have been issued to comply with Codex 
standard regarding fish oil leading to protect consumer health as well as to facilitate trade 
as follows:  
Clause 1 – Fish oils are prescribed food to have qualities or standards and definition is 
defined to comply with codex standard for fish oils as follows;  
"Fish oils are composed of glycerides of fatty acids including fatty acids in ethyl esters 
form obtain ed from  fish or shellfish that are commonly used as food. Fish oils may 
contain other lipids and unsaponifiable constituents naturally present. Fish oils in dried 
form are also included in this notification. Fish and shellfish are defined based on 
Section 2 of the Code of Practice for Fish and Fishery Products (CAC/RCP 52 -2003) as 
follows:  
Fish means any of the cold -blooded (ectothermic) aquatic vertebrates. Amphibians 
and aquatic reptiles are not included;  
Shellfish means those species of aquatic mollusc s and crustaceans that are commonly 
used as food.  
Clause 2 – Fish oils are classified in 5 categories as follows:  
1) Named fish oil that derived from specific species of fish or shellfish;  
2) Unnamed fish oil that derived from mixed fish oil from more th an one type or 
mixture of fish oil and fish liver oil;  
3) Fish liver oil that derived from the livers of fish and are composed of fatty acids, 
vitamins or other components that are representative of the livers from the species 
from which the oil is extrac ted;  
4) Concentrated fish oils that derived from fish oil classified in 1) or 2) or 3) which 
have been subjected to processes in order to increase the concentration of specific 
fatty acids; and  G/TBT/N/THA/576  
 
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  5) Concentrated fish oils ethyl esters that derived from fis h oil classified in 1) or 2) or 
3) and are primarily composed of fatty acids ethyl esters form.  
Clause 3 – The production processes of fish oil shall be refined process intended for direct 
human consumption that includes, but are not limited to, extraction  of crude oil from raw 
material and refining of that crude oil by heating at high temperatures as well as 
alkali/acid treatments, removing free fatty acids and may be treated for decolourization or 
deodorization. The refined fish oil process typically incl udes several steps such as 
hydrolysis, winterization, fractionation, full hydrogenation, re -esterification, or inter -
esterification.  
Clause 4 - Fish oils shall be complied with the following qualities or standards;  
1) For fish oils in liquid form  
- Colour, odour and flavour inherent of that specific characteristics of fish oils and free 
from foreign matter and rancid odour;  
- Fatty acid composition of some fish oils shall be complied with requirements 
specified in Annex 1 of this notification as well  as essential composition for some 
fish oils shall be complied with specification in Annex 2 of this notification;  
- Acid value shall not be more than 3 mg of potassium hydroxide per 1 g of fish oil, 
except for the acid value of fish oils with a high phosp holipid concentration of 30% 
or more shall not exceed 45 mg of potassium hydroxide per 1 g of such fish oil;  
- Peroxide value shall not be more than 5 mg equivalent per 1 kg of fish oil;  
- Anisidine value shall not be more than 20 only for fish oils with p hospholipid 
concentration lower than 30%   by weight.  
- Total oxidation value (ToTox) shall not be more than 26 only for fish oils with  
phospholipid concentration lower than 30% by weight.  
- Fish liver oils, except deep sea shark liver oil, shall comply wi th following:  
1) Vitamin A shall not be less than 40 μg of retinol equivalent/mL of oil; and  
2) Vitamin D shall not be less than 1.0 μg/mL of oil  
2) For fish oils in dried form  
- Moisture content shall not be more than 5 % by weight.  
- Fish oil used as raw material shall comply with requirements for particular fish oils in 
liquid form mentioned in Clause 4.  
- In case of other ingredients are contained, their qualities and standards shall be 
complied with relevant requirements approved by Thai FDA. 
Clause 5  – Usage of food additives and containers for fish and oil shall be complied with 
the Notification of MOPH regarding Food additives and Standard of Containers, 
respectively.  
Clause 6  – Contaminants, pathogens shall not exceed the maximum limi ts as specified in 
the Notification of MOPH regarding Standard of Foods contained contaminants and 
Standard of Pathogenic Microorganisms in Food, respectively.  
Clause 7  – Producers or importers of fish oils for sales shall follow the notification of MOPH 
regarding Production processes, production equipment and foods storages.  
Clause 8  – Labeling of fish oils shall follow the Notification of Ministry of Public Health 
regarding labeling of prepackaged foods. In addition, the following information shall be 
expressed on its label as the case may be.  
1) Name of fish used as raw material shall display with name of food, for fish oils in 
classification of named fished oils and Cod liver oils;  
2) Source of fish used as raw material for salmon fish oils;  
3) Content of vitamin A and vitamin D for liver fish oils;  
4) Content of EPA and DHA for Anchovy oil, Concentrated fish oils, and Concentrated 
fish oils ethyl esters;  
5) Types of fish oil used as ingredients in descending orders  shall be displayed with 
name of food f or unnamed fish oils, liver fish oils, and fish oils in dried form.  
Clause 9 – Whenever food products contained fish oils under this notification shall comply 
with relevant notifications of MOPH for such food products (For example, food supplement 
consist ed of fish oil, the food supplement shall comply with requirements for safety, 
qualities, labeling or warning statement as specified in the notification of MOPH regarding G/TBT/N/THA/576  
 
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  Food supplements).  
Clause 10  – Producers or importers of fish oils for sales, whose p ermission issued prior to 
this notification, shall follows:  
1) Existing fish oils can be sold in the market not exceed 2 years after this notification 
comes into force;  
2) Existing fish oils shall be complied with this notification within 2 years after thi s 
notification comes into force.  
Clause 11  –This notification shall come into force as from the day following date of its 
publication in the Government Gazette.  
7. Objective and rationale, including the nature of urgent problems where 
applicable:  Protection of human health or safety  
8. Relevant documents:   
1. The notification of the Ministry of Public Health regarding Food additives;  
2. The notification of the Ministry of Public Health regarding Containers;  
3. The notification of the Ministry of Public Health regarding Standard of Foods 
contained contaminants and foods storages;  
4. The notification of the Ministry of Public Health regarding Standards for Pathogenic 
Microorganisms in Food;  
5. The notification of the Ministry of Public Health regarding Pr oduction processes, 
production equipment and foods storages;  
6. The notification of the Ministry of Public Health regarding Labeling of Prepackaged 
Foods, etc.  
9. Proposed date of adoption:  To be determined  
Proposed date of entry into force:  On the date afte r being notified in the Official 
Gazette  
10. Final date for comments:  60 days from notification  
11. Texts available from:  National enquiry point [X] or address, telephone and fax 
numbers and email and website addresses, if available , of other body:   
National Bureau of Agricultural Commodity and Food Standards (ACFS)  
50 Phaholyothin Road, Ladyao  
Chatuchak, Bangkok 10900  
Thailand  
Tel: +(662) 561 4204  
Fax: +(662) 561 4034  
E-mail: spsthailand@gmail.com  
Websites:  http://www.acfs.go.th  - http://www.spsthailand.net/  
https://members.wto.org/crnattachments/2020/TBT/THA/20_3180_00_x.pdf