Regulatory impact assessment of the current mandatory labelling requirements of pre-packaged processed food products /

Cerbolles, Maria Theresa C.

Regulatory impact assessment of the current mandatory labelling requirements of pre-packaged processed food products / Maria Theresa C. Carbolles. - 104 leaves : color illustrations



Public Management Development Program

The food industry in the country is presently required to comply with the 11 mandatory labeling requirements according to Administrative Order 2014-0030. Significant effort from the food industry for compliance ti the issuance is evident considering the following new development: (1) new TRAIN Law on sweetened beverages, which are regulated by the FDA as additional requirements; and (2) it is necessary at this point in tome to align with international standards like the ASEAN Common Food Control Requirements on Labelling of Prepared Foodstuff as part of the harmonization efforts in the ASEAN on standards and regulation, and the FAO-WHO Codex Standards on Food Labeling of Pre-packaged Food Products. This study aims to conduct Regulatory Impact Assessment (RIA) on the said Regulation in order to determine the impact to the Food Industry, at least, up to the Proportionality Analysis of the RIA process and to come up with a proposed draft revised regulation based on the outcome and analysis of this process. The study covered representative FDA-licensed food establishments from the local large-, medium-, and micro-scale enterprises with applications for product registration and for desk review. A survey was also conducted among establishments focusing on the issues that they encounter in complying with the mandatory food labelling requirements including the cost and benefits, qualitatively and quantitatively. Data gathered from FDA database desk review covering January to June 2018 applications for both imported and locally manufactured food products were analyzed to determine compliance at the registration application level. Non-FDA licensed processed food establishments were not covered by the study, as well as food prepared of standard menu items from establishments like restaurants. Regulatory Impact Assessment (RIA) was conducted from Problem Analysis to Proportionally Analysis with Stakeholder Mapping and Analysis based on the Modules on Public Policy Analysis (PPA) and Transformational Leadership of PMDP and the RIA Trainings from Modernizing Government Regulation Program (MGRP) of DAP. From the survey that was conducted among FDA-licensed food manufacturers and imported-distributors, it showed that compliance to the current mandatory labelling requirements has a direct or significant whether an establishment may be able to comply with the Mandatory Labelling requirements or not. Though the survey failed to show the implication of compliance cost, specifically, cost to have product tested for its nutritional content and shelf-life study to substantiate nutrition information and expiration date to be declared, respectively, due to lack of data at the time the survey was accomplished, the overall labelling compliance among the food industry surveyed was high at 70% of the 48 respondents. From the results of the Proportionality Analysis taking into consideration the findings from the survey, the Problem Analysis, at the First RIA Step, the total rating from the four criteria mentioned in the previous section of "14 - Moderate", meant that the Cause for Action for the proposed revised regulation as an intervention to the identified problem is equivalent to "Provide justification for a complete/detailed RIA."


Food labeling.
Packaging and Labeling Services.
Republic Act No. 10611.
Republic Act No. 9711.

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