Malaysia Sweetener / Sugar-Substitute Labelling Rules

In Malaysia, sweeteners used in food (commonly called sugar substitutes) 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 take a "positive list" approach to sweeteners: any sweetener not on the permitted list may not be added to food at all. Regulations 118 to 134 divide permitted sweeteners into artificial sweeteners (such as saccharin), non-nutritive sweeteners (such as acesulfame-K, sucralose and aspartame) and sugar alcohols / polyols (such as sorbitol, maltitol and xylitol). Each has its own permitted foods and maximum limits, and products containing added sweeteners carry extra declaration and warning duties on the label.

Permitted sweeteners fall into three classes

Every sweetener that may lawfully be added can be traced to a permitting provision of the Regulations. If your formula uses a sweetener outside the list — however common it is overseas — it is non-compliant in Malaysia.

The Regulations expressly provide that, apart from those listed in Regulations 118 to 133, only aspartame, erythritol, glycerol, isomalt, lactitol, maltitol, maltitol syrup, mannitol, sorbitol, sucralose, thaumatin and xylitol are treated as permitted sweeteners. Which foods a given sweetener may be used in, and at what level, must always be checked against the corresponding provision and the current version of the relevant schedule — do not extrapolate from overseas experience.

Three duties on the label

Food with added permitted sweeteners must, in addition to general labelling, observe the following three points:

1. Ingredient-list declaration: food additives must be listed in the ingredient list by "functional class + specific name or INS identification number", so that consumers can see which sweetener was used.
2. Aspartame phenylalanine warning: products containing aspartame must be labelled "Contains a source of phenylalanine" (Mengandungi sumber fenilalanina), to alert people with phenylketonuria (PKU).
3. Polyol laxative warning: products containing sorbitol and other polyols, or polydextrose, must carry a warning that excessive consumption may have a laxative effect.

Be careful with "sugar-free / low-sugar / reduced-sugar" claims

When you swap sugar for a sugar substitute and want to headline "sugar-free", "low-sugar" or "reduced-sugar", it is not enough merely to have added a substitute — you must meet the threshold conditions the Regulations set for nutrition claims (for example, the sugar content per 100 g / ml must fall below a prescribed value). Such claims belong to the nutrition-claim regime and are a separate matter from the sweetener itself; we recommend reading this together with Food nutrition claims vs health claims rules. In addition, featuring a sugar substitute does not license claims of therapeutic or weight-loss benefit — that crosses the line into exaggerated claims.

Key points for each sweetener class

• Saccharin: an artificial sweetener; very sweet and often blended with other sweeteners. It must be used within the permitted foods and limits and may not be added freely to every category.
• Aspartame: close in sweetness to sucrose but breaks down under heat, so watch out in baked formulations; if it is present, the phenylalanine warning is mandatory.
• Acesulfame-K, sucralose: non-nutritive sweeteners with better heat stability, common in beverages; still bound by the permitted scope and limits.
• Polyols (sorbitol, maltitol, xylitol, etc.): combine sweetness with humectant / bulking functions, but carry calories and can cause a laxative effect in excess, hence the laxative warning.
• Blended use: when several sweeteners are combined, each must individually meet its own permitted foods and limits — you cannot look only at total sweetness.

In practice, once the formula is fixed, check each sweetener one by one against the corresponding provision of the Food Regulations 1985, confirm that all three conditions hold — "category permitted + within limit + warnings complete" — and only then send the artwork to print.

Common mistakes

• Reusing a foreign formula that uses a sweetener outside the Malaysian list (breaching the positive list).
• Containing aspartame but omitting the phenylalanine warning — one of the most common findings in factory inspections and sampling.
• Writing only "sweetener" in the ingredient list without the specific name or INS number.
• Labelling "sugar-free" just because a substitute is used, when overall sugar content has not met the sugar-free threshold.
• Failing to add the laxative warning on polyol products.

Frequently asked questions (FAQ)

Q: Can stevia (steviol glycosides) be used in Malaysia? Sweeteners are always governed by whatever is on the current permitted list in the Food Regulations 1985. If a given sweetener is not in the schedule you find, you may not add it on your own; before introducing it, confirm its permitted status and limits with FSQD or by checking the latest text of the Regulations.

Q: Must a phenylalanine warning always be shown for aspartame? Yes. This is a mandatory warning and has nothing to do with whether the product is "sugar-free"; as long as the ingredients contain aspartame it must be shown. It is common to use Malay and/or English, either alone or side by side.

Q: Do polyols (such as maltitol, xylitol) count as sugar? Can I label sugar-free? Polyols are permitted sweeteners but still carry calories. Whether you may label "sugar-free" depends on whether the overall sugar content meets the threshold, not on whether a polyol was added; a laxative warning is also required.

Q: Do sweeteners need an INS number in the ingredient list? Additives must be declared by functional class plus the specific name or identification number. Writing the sweetener's name or its INS number is fine, but you cannot write only the generic word "sweetener".

Q: Are labelling rules for imported sugar-substitute food the same as for local manufacture? The permitted list, limits and warnings for sweeteners apply equally to imported and local products; imports must additionally meet general imported-food labelling requirements (such as a Malay product name and importer details).

Self-check list

• [ ] All sweeteners used are on the current permitted list in the Food Regulations 1985
• [ ] Usage does not exceed the maximum limit for the corresponding food
• [ ] The ingredient list declares by "functional class + name or INS number"
• [ ] Products containing aspartame show "Contains a source of phenylalanine"
• [ ] Products containing polyols / polydextrose carry a laxative warning
• [ ] If a sugar-free / low-sugar claim is made, sugar content meets the threshold

Summary: The core of sweetener compliance is three things — "positive list + limits + warnings". First confirm the sweetener is on the permitted list, then control the dose, and finally add the two high-frequency warnings for aspartame (phenylalanine) and polyols (laxative); doing so avoids most findings. Further reading: Food additive labelling overview, Preservative labelling and permitted limits, 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.