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Food additives (INS numbers) in Thailand: limits and labelling

10 min read · Updated 9 Nov 2026

What food additives are under Thai law

Thailand food additives (INS numbers, limits and labels) are governed by one core rule: MOPH Notification No. 281 of 2004. It defines a food additive as a substance that is not normally eaten as food or used as a main ingredient, but is added on purpose for a technological reason, such as keeping texture stable, stopping fats from going rancid, extending shelf life or adding colour.

Two details in that definition often surprise brand owners. First, items packed separately with the food, such as desiccant sachets or oxygen absorbers, also count as food additives. Second, nutrients added for nutritional value, such as protein, vitamins and minerals, are not food additives. The same substance can play both roles: L-ascorbic acid can be an antioxidant additive in a food and vitamin C in a supplement. If you sell vitamin products, see vitamin C supplement labels.

Notification No. 281 does not apply to flavouring agents, which have their own notification, so this article does not repeat that topic; see flavourings under Notification No. 223. Here we cover which notifications are current, what INS numbers mean, how to read the maximum-level list, how to combine additives, and how additives must appear on a Thai label.

Which Thai food additive notifications apply now

Thai additive law is not one document. It is one core notification amended several times, and each amendment changed a specific part.

• No. 281 (2004) is the core text: definitions, additive quality, and the principle that use must follow the permitted substance, food and maximum level.
• No. 381 (2016) rewrote clause 6 of No. 281 so that use follows Lists No. 1 and 2, introduced the sum-of-ratios rule for additives with the same function, and added clause 6/1 on uses that differ from the lists.
• No. 418 (2020) replaced Lists No. 1 and 2 of Notification No. 389 with its own annex.
• No. 444 (2023) replaced the lists of No. 418.
• No. 468 (2025) replaced the lists of No. 444 with a new List No. 1 and No. 2, which the Thai FDA explanatory notice says follow the Codex General Standard for Food Additives (GSFA 2024). It has applied since 12 December 2025.

In short, the legal text is still No. 281 as amended by No. 381, while the list of substances and maximum levels in use today is the annex to No. 468. The explanatory notice confirms that clauses 1 to 4 of No. 381 remain in force. If a supplier document quotes the lists of No. 418 or No. 444, treat those values as outdated and check them against No. 468.

For products licensed before 12 December 2025 that used additives in line with the No. 444 lists, the explanatory notice requires them to be brought into line with No. 468 by 12 December 2027. This grace period covers only products licensed before the effective date that complied with the old lists; new products must follow No. 468 from the start.

What an INS number is

INS stands for International Numbering System. The annex to Notification No. 468 defines it as a set of numbers or English letters used to identify a food additive. In practice it is a shared code that lets everyone point to the same substance, whatever trade or local name is used.

List No. 1 is sorted alphabetically by English name. Each entry header gives four facts: the English and Thai name, the INS number, other names, and the technological function. Examples taken from the list itself:

• ACESULFAME POTASSIUM, INS 950, also called Acesulfame K, functions: flavour enhancer and sweetener.
• ASCORBIC ACID, L-, INS 300, other names include Vitamin C, functions: acidity regulator, antioxidant, flour improver and sequestrant.
• BENZOATES, a group entry covering benzoic acid (INS 210), sodium benzoate (INS 211), potassium benzoate (INS 212) and calcium benzoate (INS 213), all with the preservative function.

Some INS numbers carry a suffix in brackets, such as curcumin INS 100(i) or carotenoids INS 160a(i). The suffix separates sub-forms within the same family, so when you compare a supplier specification, match both the number and the suffix.

An INS number only tells you which substance it is. It does not tell you whether you may use it in your food or how much. Those answers sit in the table under each entry, explained in the next section. You can search a name or INS number in our ingredient search, which already holds the No. 468 additive list.

Food additive limits: reading List No. 1 column by column

Under each entry, List No. 1 has a table with five columns. The notes to the No. 468 annex define them as follows.

• Food category code: a numeric code for the food category, explained in List No. 2, Part 1, which splits food into 16 main categories, such as 01.0 dairy products and analogues.
• Maximum permitted level: milligrams of additive per kilogram of food (mg/kg).
• Quantum satis (Thai: appropriate amount): used instead of a number in some categories. It means the lowest amount that achieves the intended technological effect under good manufacturing practice (GMP).
• Conditions: numbers or codes explained in List No. 2, Part 2. For example, condition 13 for benzoates means the level is calculated as benzoic acid. Codes starting with XS refer to Codex commodity standards, and TH codes are Thai conditions, such as TH4, which excludes products covered by the Thai ice cream notification.
• Year adopted: the Buddhist-era year in which that provision was accepted.

The Thai FDA explanatory notice is clear about main and sub-categories. If an additive is allowed in a main category, it is also allowed in all its sub-categories. If it is allowed only in a sub-category, it may be used only there. So the first step in checking a formula is to place your product in the correct food category, and then look for a line for that category or its parent.

Quantum satis needs care. The explanatory notice says it does not mean unlimited use. The producer must study its own product to find the lowest effective amount, for example by testing several levels to see which one gives enough shelf life, and should keep that study with its GMP records.

A real line from the No. 468 list: acesulfame potassium (INS 950) in category 01.1.4, flavoured dairy-based drinks, has a maximum of 350 mg/kg, conditions 127, 188 and TH1, adopted in 2559 (2016). That figure applies to that category only; other categories have their own lines, and every condition must be opened too.

Using several additives: the sum-of-ratios rule

Real formulas often use more than one additive with the same function, such as two preservatives together. Clause 6 of Notification No. 281, as rewritten by No. 381, says that when two or more additives with numeric maximum levels are used in the same functional class, the sum of each one's used amount divided by its own maximum must not exceed one.

A worked example with made-up figures: if additive A is used at half of its maximum (ratio 0.5) and additive B at half of its maximum (ratio 0.5), the sum is 1 and the formula complies. If B is raised to 60 percent of its maximum, the sum becomes 1.1 and the formula does not comply, even though each one is below its own limit.

The No. 468 explanatory notice adds two points. The rule applies unless a specific condition in List No. 2 says otherwise. For colours, the sum is calculated only within the same shade group: yellow, orange, red, blue, green, brown, black, purple and white. Two yellows are added together; a yellow and a red are not.

Also consider carry-over, meaning additives that come in with an ingredient, such as a preserved jam used as a pastry filling. The explanatory notice gives guidance on carry-over in its annex No. 5 and states that food categories 13.1 (infant and young child products) and 13.2 (complementary foods for infants and young children) may not contain additives carried over from ingredients. If you make products in those categories, check every ingredient.

The explanatory notice also includes worked methods for ratio calculations, condition-based calculations and calculation in the ready-to-eat state for foods that are mixed or diluted before eating. For complex formulas, start with our formula check and then confirm against the full list.

Preservatives in food: reading values from the list

Preservatives are the additives people search for most. In the No. 468 list, several preservatives are grouped into one entry. Examples:

• Benzoates, INS 210 to 213, preservative function, levels calculated as benzoic acid (condition 13). For category 02.3, oil-in-water fat emulsions, the list sets 1000 mg/kg.
• Sorbates: sorbic acid (INS 200), potassium sorbate (INS 202) and calcium sorbate (INS 203), preservative function, levels calculated as sorbic acid (condition 42).

What these examples show is that if you use sodium benzoate, you must convert the amount to benzoic acid before comparing it with the limit, rather than comparing the salt weight directly. If you use both a benzoate and a sorbate, both belong to the preservative class, so the sum-of-ratios rule applies as well.

We quote only a few lines here to show the method. Values for other categories can differ widely, and some categories do not allow a given preservative at all. The safest routine is:

1. Assign your product's food category code from List No. 2, Part 1.
2. Find the substance name or INS number in List No. 1 of No. 468.
3. Look for a line for your category or its parent; if there is none, the use is not yet permitted.
4. Open every condition code in List No. 2, Part 2.
5. Convert units as the conditions require, then apply the sum-of-ratios rule if you use more than one.

The whole No. 468 list is searchable in our ingredient search, and the source files are in our regulation archive.

Uses outside the list: what the Thai FDA requires

Sometimes the additive you want has no line for your food category, or you need more than the maximum. Clause 6/1 of Notification No. 281, added by No. 381, and the No. 468 explanatory notice require consent from the Thai FDA after a safety assessment, and four conditions must all be met:

1. The additive has complete quality specifications and safety values in the latest Codex Advisory Specifications for the Identity and Purity of Food Additives, or in a Thai FDA notification on additive quality.
2. An exposure assessment has been passed.
3. Reliable technical documents or research support the technological need and effectiveness in the product concerned.
4. The latest laws of at least two countries with credible safety assessment systems accept that use; the explanatory notice gives the EU, Australia-New Zealand, the United States and Japan as examples.

The explanatory notice points applicants to the public guide on requesting a safety assessment for food additives where no use condition exists yet, or where an extra condition is sought. This matters most for imported products, because a formula sold legally at home may use a substance or level that Thailand's list does not yet include.

Keep in mind the difference between a food that contains additives and an additive sold as a product itself, such as retail baking powder or food colouring. Notification No. 281 makes food additives a specifically controlled food, with quality set by Codex or Thai FDA notifications. Labels for additive products follow specific rules in Notification No. 372, such as listing the additive components with percentages and INS numbers, plus directions for use. If you plan to sell an additive product, plan its licensing separately from ordinary food; our registration service can help.

Food additives on Thai labels: Notifications No. 450 and 474

Labels on prepackaged food follow Notification No. 450 of 2024, amended by No. 474 of 2026 (in force 31 October 2026). No. 474 rewrote clause 5 in full, but the additive rule in clause 5(7) keeps the same core and adds a new paragraph. In summary:

If additives are used, or are carried over from ingredients at a level that has a technological effect, the label must state the functional class. Four classes need more detail:

• Colours: the class name followed by the specific name or INS number; the label may also say whether the colour is natural or synthetic.
• Preservatives: the class name followed by the specific name or INS number.
• Flavour enhancers and sweeteners used instead of sugar: the class name followed by the specific name (an INS number alone is not enough for these two).

For other classes, the label may use the words “food additive” in place of the class name, together with the specific name or INS number. No. 474 adds two points. If a substance in one of the four classes has more than one function and is used mainly for another one, the label shows the class of that main function instead of “food additive”, and the amount used must fit that main function. Carriers and packaging gases may also be declared under clause 5(7), but this is optional.

No. 474 also rewrote the labelling exemptions. Producers selling directly to consumers, including through their own online channels, are exempt from labels in some cases, but food that contains additives is one of the groups that is not exempt. If your product contains an additive, it needs a full label even if you sell every unit yourself.

Clause 12 of No. 450 also bars label claims about an additive that has no use condition in the additive notifications. Flavour statements such as “natural flavour” fall under clause 5(8) and are covered in our flavourings article. Run a first check of your label text with the label check tool.

Checklist before you use additives in a formula and on a label

Before you file a formula or send a label to print, go through these questions one by one.

• Which food category code in List No. 2, Part 1 of No. 468 fits the product?
• Does every additive in the formula, including carry-over from ingredients, have a line for that category or its parent?
• Have amounts been converted as the conditions require, for example as benzoic acid or sorbic acid?
• Where several additives share a function, or colours share a shade group, is the sum of ratios one or less?
• For quantum satis uses, do you have a study showing the lowest effective amount?
• Do raw material documents show Codex or Thai FDA quality specifications and an INS number that matches what you actually use?
• Does the label state the functional class and the specific name or INS number as clause 5(7), as amended by No. 474, requires?
• If the product was licensed before 12 December 2025, have you planned the changes needed for the No. 468 lists?

If any answer is unclear, or the formula comes from an overseas plant that uses a different numbering habit, our consultants can check your formula and label against the current list. Send the details through contact.

Sources

1. MOPH Notification No. 281 B.E. 2547 (2004) on food additives · Open source · Search our archive
2. MOPH Notification No. 381 B.E. 2559 (2016) on food additives (No. 4) · Open source · Search our archive
3. MOPH Notification No. 418 B.E. 2563 (2020) on criteria, conditions, methods of use and ratios of food additives (No. 2) · Open source · Search our archive
4. MOPH Notification No. 444 B.E. 2566 (2023) on criteria, conditions, methods of use and ratios of food additives (No. 3) · Open source · Search our archive
5. MOPH Notification No. 468 B.E. 2568 (2025) on criteria, conditions, methods of use and ratios of food additives (No. 4), in force 12 Dec 2025 · Open source · Search our archive
6. Thai FDA explanatory notice on MOPH Notification No. 468 B.E. 2568 (2025) · Open source · Search our archive
7. MOPH Notification No. 450 B.E. 2567 (2024) on labelling of prepackaged food · Open source · Search our archive
8. MOPH Notification No. 474 B.E. 2569 (2026) on labelling of prepackaged food (No. 2) · Open source · Search our archive
9. MOPH Notification No. 372 B.E. 2558 (2015) on food additives (No. 3), labels of additive products · Open source · Search our archive

This article is for general information. It is not a Thai FDA ruling or legal advice, and rules change — check the latest notification or ask an expert before filing or producing.

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