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Thailand flavouring regulations: Notification No. 223, three flavour types, labels and EU 1334/2008 compared
Thailand flavouring regulations: what counts as a flavouring
Thailand flavouring regulations start from one core rule: Notification of the Ministry of Public Health (No. 223) B.E. 2544 (2001) on flavouring agents. Clause 3 defines a flavouring agent as a substance used to give odour or taste to food. The notification was published in the Royal Gazette, volume 118, special part 70 Ngor, on 26 July 2001, took effect on 24 July 2001, and repealed the earlier Notification No. 120 (1989) on the labelling of flavouring agents.
The legal base is section 4 of the Food Act B.E. 2522 (1979). Its definition of food includes substances intended for use as ingredients in food production, expressly including food additives, colours and flavouring agents. A drum of flavour sold to a snack factory is therefore food in law, just like the snack it ends up in.
Clause 2 of Notification No. 223 makes flavouring agents a food that must carry a label, so each flavour needs a food serial number and a label in the prescribed form. Clause 4 requires anyone who manufactures or imports flavouring agents for sale to follow the notification on production methods, equipment and storage of food, commonly called GMP.
This guide covers the three flavour types, the label for the flavour itself, the label of a food that uses a flavour, the difference from flavour enhancers such as MSG, and a comparison of selected substances that Thailand bans or limits with Annex III of the EU flavouring regulation.
Natural flavouring in Thailand, nature-identical and artificial: the three types
Clause 3 of Notification No. 223 sorts flavouring agents into three types. The type matters because it decides the words on the label of the flavour and the words on the label of every food made with it.
1. Natural flavouring agent
Obtained from plants or animals that people normally eat, by physical methods. Both conditions apply together: the raw material must be a plant or animal normally consumed, and the flavour must be obtained physically. If either condition is not met, the flavour should not be called natural under Thai rules.
2. Nature-identical flavouring agent
Obtained by separating flavouring substances by chemical methods, or from synthesised substances, where those substances are chemically the same as substances found in natural products that people normally eat. The type also covers nature-identical flavourings that contain natural flavourings.
3. Artificial (synthetic) flavouring agent
Obtained from substances not yet found in natural products that people normally eat. The type also covers artificial flavourings that contain natural or nature-identical flavourings.
How blends are classified
The definitions answer this directly: a blend takes the type furthest from natural. If any nature-identical part is present, the whole flavour is nature-identical, even if most of it is natural. If any artificial part is present, the whole flavour is artificial. Buyers should ask the flavour house for a statement of type under the Thai definitions, not rely on a trade name or catalogue wording.
Source: MOPH Notification No. 223 B.E. 2544 (2001), clauses 3 and 5
Flavourings versus flavour enhancers such as MSG
Thai searchers often use the phrase for flavour seasoning agents when they mean flavouring agents under Notification No. 223. The Food Act uses a slightly different Thai term in its definition of food, but the formal name of the group in the notification is flavouring agent.
A flavour enhancer is a different thing. Monosodium glutamate (MSG) and similar substances enhance taste and, on a food label, belong with food additives rather than with flavourings.
Our food label checker, based on Notification No. 450 B.E. 2567 (2024) on labelling of prepackaged food, keeps the two in separate items:
- Clause 5(7), food additives: colours, preservatives, flavour enhancers and sweeteners must show the function class followed by the specific name (colours and preservatives may use the specific name or the INS number).
- Clause 5(8), flavouring statement: if a flavouring agent is used, the label must carry the statement for its type, for example the Thai words for natural flavour, nature-identical flavour or artificial flavour, or natural or nature-identical taste, as applicable.
So a snack bag with both MSG and a barbecue flavour needs both: MSG in the additive list, and a flavouring statement that matches the flavour type. One combined phrase does not cover both items.
Thai flavouring label requirements for consumer packs
Clause 5(2) of Notification No. 223 covers flavouring agents sold to consumers, such as small bottles of vanilla or pandan flavour sold for home baking. The label must be in Thai (other languages may be added) and must show:
- The name of the food, with the Thai words for natural, nature-identical or artificial flavouring agent, as applicable.
- The food serial number.
- The purpose or benefit of use, with directions.
- Net quantity in metric units: weight for solids, volume for liquids, either for semi-solids.
- Name and address of the manufacturer or repacker for local products, or name and address of the importer and the country of manufacture for imports (local products may show the head office address).
- Type and amount of any added colour (if any).
- Storage instructions (if any).
- Month and year of manufacture, or the expiry date, or the best-before date, with the Thai word for manufactured, expiry or best before.
- Any statement the Thai FDA prescribes (if any).
Clause 5(1) also says the general food labelling notification applies, except for certain clauses that No. 223 covers itself. The general notification for prepackaged food today is No. 450 of 2024, as amended by No. 474 of 2026 (in force from 31 October 2026). When preparing a real label, check both together, and ask the Thai Food and Drug Administration (Thai FDA) if it is unclear which clauses of No. 450 apply to the flavour itself.
A common mistake is a label that says only vanilla flavour without the type, or a type that does not match the flavour house's documents, for example natural when the blend contains a nature-identical part.
- Food name with the type: natural / nature-identical / artificial flavouring agent
- Food serial number
- Purpose or benefit of use, with directions
- Net quantity in metric units (solids by weight, liquids by volume)
- Name and address of the manufacturer or repacker, or importer and country of manufacture
- Type and amount of added colour (if any)
- Storage instructions (if any)
- Manufacture, expiry or best-before date with its label word
- Statements prescribed by the Thai FDA (if any)
The label must be in Thai; other languages may be added. Flavours not sold to consumers follow clause 6 (at least six items).
Source: MOPH Notification No. 223 B.E. 2544 (2001), clause 5(2)
Labels for flavours sold to factories, and imported flavours
Most flavours are not sold to consumers but in drums or jerrycans to food, beverage or supplement factories. Clause 6 of Notification No. 223 sets a separate label for flavouring agents not sold to consumers.
These labels must be in Thai, except that imported flavouring agents may be labelled in English. At minimum they must show six items:
- The name of the food, with the Thai words for natural, nature-identical or artificial flavouring agent, as applicable.
- The food serial number.
- Net quantity in metric units.
- Name and address of the manufacturer or repacker (local), or name and address of the importer and the country of manufacture (imported).
- Month and year of manufacture, or the expiry or best-before date, with the matching Thai word.
- Any statement the Thai FDA prescribes (if any).
Compared with consumer packs, directions, colour details and storage instructions are not required, because business buyers receive technical documents separately. The type statement is still required.
Points for flavour importers
- English labels from overseas suppliers usually say natural flavour or flavouring under the rules of the country of origin, which may not match the three Thai types. Confirm the type under the Thai definitions before labelling.
- If you repack bulk flavour into small bottles for consumers, the small bottle needs a Thai label with every item in clause 5, not clause 6.
- Importers of food for sale must hold evidence that the foreign manufacturer meets standards equivalent to, or not lower than, Thai GMP, under clause 5 of Notification No. 420 B.E. 2563 (2020).
Duties of flavour manufacturers and importers
Beyond the label, the notification ties manufacturers and importers to two further duties.
1. Food serial number
Because flavouring agents are foods that must carry a label, and both label types must show a food serial number, the manufacturer or importer must obtain a serial number for the flavour before selling it. For classification and the filing steps, see getting a Thai FDA food serial number.
2. GMP at the premises
Clause 4 of Notification No. 223 requires manufacturers and importers of flavouring agents for sale to follow the notification on production methods, equipment and storage. The current one is Notification No. 420 of 2020, which requires every food produced for sale to follow GMP, with limited exceptions such as places that cook food for immediate eating. For the five basic requirement areas, see GMP 420 requirements.
Transitional clauses
Clauses 7 and 8 were transitional provisions for businesses licensed under the old Notification No. 120, such as two more years for old label approvals and one year to apply for food serial numbers. Those periods ended long ago, so a new business today must meet the main body of the notification in full.
Artificial flavouring in Thailand: food labels and beverages
Once a factory puts a flavour into food, the label of the food has its own rules, separate from the label of the flavour.
The flavouring statement under Notification No. 450
Clause 5 of Notification No. 450 lists the minimum items on a prepackaged food label, including a flavouring statement. If a flavouring agent is used, the label must say which type, for example natural flavour, nature-identical flavour or artificial flavour, in Thai. No. 450 also applies to foods with their own labelling notification, such as dietary supplements, so a fruit-flavoured capsule or drink powder needs the statement too.
From real labels we have checked: a product name or ingredient line that says strawberry flavour signals that a flavouring is used, and our checker flags whether the type statement is present. The type stated must match the type of the flavour bought, under the definitions above.
Beverages in hermetically sealed containers
The notification on beverages in hermetically sealed containers, No. 356 of 2013, most recently amended by No. 473 of 2026, has two rules tied directly to flavourings:
- Name of an artificially flavoured fruit drink: it must be called the Thai equivalent of fruit-flavoured sweet water, for example orange-flavoured sweet water, rather than a juice name, which is kept for drinks with real fruit at the set percentages.
- Caffeine from flavourings: a drink made from ingredients other than fruit, plants or vegetables that uses flavouring agents naturally containing caffeine may hold no more than 15 mg of caffeine per 100 ml, and must show the Thai words for contains caffeine in letters at least 2 mm high, near the food name or trademark.
For the full amendment, see sealed beverages amendment No. 473.
EU flavouring regulation 1334/2008 compared with Thai rules
Some flavouring source materials, such as cinnamon, star anise, basil or bitter almond, carry certain substances naturally, and many markets set limits on them. Producers who sell in Thailand and export to Europe need to read both sets of rules together.
Thailand: what our database shows
- Coumarin and dihydrocoumarin: foods containing them may not be produced, imported or sold under Ministry of Public Health Notification No. 391 B.E. 2561 (2018), items (6) and (7). No. 391 replaced the older Notification No. 151 B.E. 2536 (1993), which was repealed by Notification No. 390 B.E. 2561. Some Thai FDA summaries still cite No. 151; cite No. 391 in formal documents.
- Safrole: listed as a type 4 agricultural hazardous substance in Notification No. 460 B.E. 2568 (2025) on pesticide residues, under which food must not contain substances on that list. That notification was written for residues, and it is unclear how it applies to safrole occurring naturally in spices; ask the Thai FDA case by case.
- Hydrocyanic acid: Notification No. 414 B.E. 2563 (2020) on contaminants sets maximum levels of 2 mg/kg in gari made from cassava and 10 mg/kg in cassava flour.
- Methyleugenol and estragole: our database has not found a specific rule in Thai food law. This does not mean Thailand has no rule; it may sit in a notification we have not yet extracted.
EU: Regulation (EC) No 1334/2008, Annex III
We read the consolidated text of 16 February 2026 on 3 November 2026. Annex III has two parts:
- Part A: 15 substances that must not be added to food as such, including coumarin, safrole, methyleugenol, estragole, hydrocyanic acid, pulegone, thujone and capsaicin.
- Part B: maximum levels of certain substances naturally present in flavourings and food ingredients with flavouring properties, in compound foods to which flavourings are added, by food category, in mg/kg.
For estragole, methyleugenol and safrole, the Part B limits do not apply where no flavouring has been added and the only food ingredients with flavouring properties are fresh, dried or frozen herbs and spices. The table below shows selected food categories only, not every row in the annex.
Source: Thai FDA prohibited-substance summary · MOPH Notifications No. 460 and No. 414 · Regulation (EC) No 1334/2008 Annex III, read 3 November 2026
Checklist before you make, import or use a flavour
- Get a type statement from the flavour house: natural, nature-identical or artificial under clause 3 of Notification No. 223, including whether other types are blended in.
- Check the flavour's food serial number: flavours sold in Thailand must show one on the label. For imports, the importer applies.
- Pick the right label for the buyer: consumer packs follow clause 5 (Thai, nine items); factory packs follow clause 6 (at least six items, English allowed for imports).
- Label the finished food with the flavouring statement for the type used, and keep flavour enhancers such as MSG in the food additive list.
- Artificially flavoured fruit drinks use the fruit-flavoured sweet water name; drinks using flavours that naturally contain caffeine must respect the caffeine cap and the contains caffeine statement.
- Check substances carried in from natural sources: ask suppliers for analysis or documents on substances Thailand bans or limits, and for European exports compare against Annex III of EU 1334/2008 for the destination food category.
- GMP at the premises under Notification No. 420, and evidence of the foreign maker's standards for imports.
Free tools on this site help with several steps: search substances Thailand bans or limits, which now shows an EU flavouring box next to the Thai food rules for the same substance; check a food label for the flavouring statement; and ask the RA advisor for case-specific questions. For a team review of your label or documents, contact our consultants.
Frequently asked questions
Do flavouring agents need a Thai FDA number?
Yes. Clause 2 of Notification No. 223 of 2001 makes flavouring agents a food that must carry a label, and both consumer and factory labels must show a food serial number.
What is the difference between natural and nature-identical flavouring in Thailand?
Natural flavouring comes from plants or animals people normally eat, by physical methods. Nature-identical flavouring is separated chemically or synthesised but is chemically the same as substances found in nature. If a blend contains any nature-identical part, the whole blend counts as nature-identical.
Is MSG a flavouring agent?
No. MSG is a flavour enhancer and belongs with food additives. On a food label it is shown by function class and specific name, separately from the flavouring statement.
Can an imported flavour have an English-only label?
Only if it is not sold to consumers, under clause 6 of Notification No. 223. If you repack it for consumers, the label must be in Thai and include every item in clause 5.
Can coumarin from cinnamon flavour be used in Thailand?
Thailand prohibits producing, importing or selling food containing coumarin under Notification No. 391 B.E. 2561 (2018), which replaced the repealed No. 151. The EU bars adding coumarin as such and sets limits in some food categories.
Can an artificially orange-flavoured drink be called orange juice?
No. The sealed beverages notification, as amended by No. 473 of 2026, requires artificially flavoured fruit drinks to use the Thai name for fruit-flavoured sweet water, for example orange-flavoured sweet water.
Sources
- MOPH Notification No. 223 B.E. 2544 (2001) on flavouring agents · Open source · Search our archive
- Food Act B.E. 2522 (1979) · Open source · Search our archive
- MOPH Notification No. 450 B.E. 2567 (2024) on labelling of prepackaged food · Open source · Search our archive
- MOPH Notification No. 420 B.E. 2563 (2020) on production methods, equipment and storage of food · Open source · Search our archive
- MOPH Notification No. 473 B.E. 2569 (2026) on beverages in hermetically sealed containers (No. 4) · Open source · Search our archive
- Notification of the Ministry of Public Health (No. 391) B.E. 2561 (2018) on foods prohibited from production, import or sale · Open source · Search our archive
- MOPH Notification No. 460 B.E. 2568 (2025) on food containing pesticide residues · Open source · Search our archive
- MOPH Notification No. 414 B.E. 2563 (2020) on standards for food containing contaminants · Open source · Search our archive
- MOPH Notification No. 474 B.E. 2569 (2026) on labelling of prepackaged food (No. 2) · 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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