Malaysia Food Preservative Labelling and Permitted Limits

In Malaysia, food preservatives are governed by the Food Regulations 1985 (P.U.(A) 437/85) made under the Food Act 1983, and enforced by the Food Safety and Quality Division (FSQD) of the Ministry of Health. The Regulations bring "preservative" within the definition of food additives and take a "positive list" approach: the permitted preservatives, together with the foods they may be added to and their maximum limits, are set out in the Sixth Schedule. In other words, only a preservative named in the Regulations may be used, in the specified food and up to the specified ceiling; anything outside the list is prohibited. Food with added preservatives must also be declared on the label as required.

Main permitted preservatives

Common permitted preservatives in Malaysia include the following classes; the actual foods and limits are governed by the corresponding columns of the Sixth Schedule:

How to read the "maximum permitted limit"

Table I of the Sixth Schedule is structured so that column (1) lists the food and the other columns list the maximum permitted proportion of each preservative for that food (expressed in mg/kg). The same preservative can have very different ceilings across foods, so you cannot memorise one "universal number"; instead you must identify "which food category your product is" and look up the limit on that food's row. For example, sulphur dioxide and benzoic acid in carbonated beverages fall in a lower ceiling band (below a few hundred mg/kg), but the actual figure is still governed by the corresponding food column of the Sixth Schedule. Before introduction, check each preservative in the formula against the schedule one by one, confirm it is not over the limit, and also confirm that the food is "permitted" to use that preservative (some foods may not have any preservative added at all).

Labelling declaration duties

1. Ingredient-list declaration: preservatives must be listed in the ingredient list by "functional class (preservative) + specific name or INS identification number", for example "Preservative (sodium benzoate)" or by its INS number.
2. No misleading: if a product contains no preservative at all and you want to label "no added preservative", it must be true and must not imply that similar products are harmful; such claims fall within the advertising and claims regime.
3. Cross-check with other additives: preservatives are often used together with colourings and antioxidants; declare all of them correctly at labelling time and do not omit any.

Common mistakes

• Treating a preservative that is "generally permitted" as usable in every food, ignoring that its row for that food may not permit it or may set a lower ceiling.
• Calculating the dose by "total amount" when the Regulations control by proportion in the finished product (mg/kg), so a conversion error leads to exceeding the limit.
• Writing only "preservative" in the ingredient list without the specific name or INS number.
• Using several preservatives together without confirming whether each meets its own limit.
• Importing cured meat containing nitrite without confirming it meets the meat-specific limit.

Frequently asked questions (FAQ)

Q: Which preservatives are permitted in Malaysia? Mainly benzoic acid, sorbic acid, sulphur dioxide (sulphites), propionic acid, p-hydroxybenzoate esters, and nitrate / nitrite for cured meat. The complete list and each food's limits are governed by the current version of the Sixth Schedule of the Food Regulations 1985.

Q: Is the maximum limit for a preservative one fixed number? No. Limits are "prescribed separately by food"; the same preservative has different ceilings in different foods, and you must look up your product's food row in the Sixth Schedule.

Q: Does the ingredient list need an INS number? Additives must be declared by functional class plus the specific name or identification number; writing the preservative's name or its INS number is fine, but you cannot write only "preservative" without specifying which.

Q: Is sulphur dioxide an allergen that needs special labelling? Sulphur dioxide / sulphites are listed as ingredients requiring notice in many markets. Beyond using it within the limit, confirm against the current labelling guidance whether it must be spelt out clearly in the ingredient list, to avoid disputes.

Q: Is it acceptable to label "no added preservative"? It is fine as long as it is true and does not mislead or disparage similar products; but if the product actually contains an ingredient with a preservative function, such a claim would be regarded as misleading.

Self-check list

• [ ] All preservatives used are on the Sixth Schedule permitted list
• [ ] Confirmed that the food is "permitted" to add that preservative
• [ ] The dose is checked against that food's limit by finished-product proportion (mg/kg) and does not exceed it
• [ ] For blended use, each preservative individually meets its limit
• [ ] The ingredient list declares by "functional class + name or INS number"
• [ ] Any "no added" claim is true and not misleading

Summary: Preservative compliance in three steps — first confirm the preservative is permitted in the Sixth Schedule, then confirm your food's row permits it and find the ceiling, and finally declare it correctly in the ingredient list. Always look up ceilings by "specific food", never apply a universal number. Further reading: Food additive labelling overview, Sweetener / sugar-substitute labelling, Colouring / colour labelling, and the Malaysia food labelling master guide.

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This article is compiled from official sources for reference only; actual compliance is subject to the latest text and review by the competent authority.