Tackling Food Security Challenges In ASEAN Amid COVID-19: Removing Trade Barriers In Product Certification & Registration

Tuesday, June 9th, 2020

In a bid to address the challenges in getting food products across borders, Food Industry Asia (FIA) and the ASEAN Food and Beverage Alliance (AFBA) have put forward the recommendation for regulatory stakeholders to consider the adoption of a risk-based approach, where food assessment measures are carried out based on the risk that is involved, be it inherently in the product or from the process. The system-based approach can help improve products’ speed to market in ASEAN.

In ASEAN, the food value chain is one of the major drivers of GDP and employment in the region. On top of that, it is crucial to ensure the region’s food security. The COVID-19 pandemic that has grown into a global crisis in the past few months has accentuated the highly interconnected economies and societies, including the food and agriculture sector in ASEAN. With such close interdependence, any interruption along the food supply chain could threaten ASEAN’s food security. It is crucial to minimise such effects by keeping trade open as much as possible to secure the food supply chain during this period, and even more so after the pandemic.

As ASEAN Member States are faced with the impacts from the pandemic, unprecedented challenges present a strong call of urgency for Member States to redouble collective efforts to strengthen regional trade for ASEAN and emerge from this crisis with increased resilience. Prior to COVID-19, trade barriers were long-standing challenges that hindered the potential in ASEAN to be fully tapped. As ASEAN countries put forward various stimulus packages to revive businesses that have taken a toll from COVID-19, the removal of trade barriers remains integral in ASEAN’s economic recovery journey.

In ASEAN, one of the trade barriers faced by businesses relates to the certifications and registration processes for food products, both in domestic trade and regional trade. A comparison of the regulatory frameworks in the countries has shown the different certifications or registration processes which need to be fulfilled by businesses to gain market access. Fragmentation in the approach from each country has made it challenging for businesses as the lack of standardisation has inevitably increased the complexity of market access and cost to businesses, especially for import and export activities across countries.

To gather a deeper understanding of businesses’ experience in gaining market access in ASEAN countries, Food Industry Asia (FIA) and the ASEAN Food and Beverage Alliance (AFBA) launched a survey with businesses to gather input on the product registration requirements across ASEAN Member States, in particular the processes and documentations required. The survey allowed FIA and AFBA to identify the gaps and provide recommendations to relevant stakeholders to ease the challenges.

Product registration, also known as pre-market registration, is a measure that looks at the safety and compliance assessment of food products before the products are allowed to be sold in the country. In ASEAN, product registration is adopted by most countries (Brunei Darussalam, Cambodia, Indonesia, Laos, Myanmar, the Philippines and Thailand). To sell products in these markets, businesses are required to submit the relevant documents, based on the types of products. On the other hand, in countries such as Malaysia, Singapore and Vietnam, a system-based approach is adopted where control measures are distributed along the food supply chain and additional controls are applied when risk levels are higher. In Malaysia and Vietnam, product registration is required for products with higher risk.

With the spectrum of food safety approaches implemented across ASEAN countries, it is necessary for businesses to be aware of the requirements in each country and to comply accordingly. However, the process of doing so is often challenging, especially in the countries that require product registration.

Results from the survey carried out by FIA and AFBA showed that business sentiments on the process of product registration vary where the feedback on the ease of fulfilling the requirements ranges from easy to difficult. Upon closer examination, businesses in growing markets in ASEAN—such as Indonesia, Thailand and the Vietnam—had mostly indicated the ease of obtaining documents as ‘moderate’ and ‘difficult/complicated’. This sheds light on the complexity and uncertainties in the process of product registration (Figure 1).

Figure 1: Ease of obtaining documents experienced by industry members during product registration

Upon the synthesis of the input from businesses, there were two main challenges identified. Firstly, businesses have flagged out burdensome paperwork and procedures. The documents required can include certificate of analysis, food safety certification, dietary certification, product-related declaration or licence, business-related declaration or licence, label, and trade documents. The documents to be submitted vary according to the country as well as the product category—these specific documents can be found in Table 1.

Secondly, some of the challenges in fulfilling documentation requirements that were highlighted by businesses surveyed include difficulties in obtaining documents and the rejection of documents from importing countries due to format differences. Other issues such as the efficiency of online submission platforms, and inconsistent interpretation on requirements also surfaced through the survey. All in all, the multiple hurdles that come along during product registration add to the time required for businesses to gain approval. In some markets, this can take up to several months.

While a tight food safety and regulatory control framework is necessary to safeguard the food products that are traded domestically or between borders, this could come at the expense of trade potential if businesses are faced with burdensome registration requirements. This could be further exacerbated by the impact from COVID-19. Therefore, there is a greater need to remove trade barriers and minimise cost to business.

In a bid to address the challenges in getting food products across borders—and, in particular. those that were highlighted in the survey—FIA and AFBA have put forward the recommendation for regulatory stakeholders to consider the adoption of a risk-based approach where food assessment measures are carried out based on the risk that is involved, be it inherently in the product or from the process. The system-based approach that is adopted in Malaysia, Singapore and Vietnam has helped improved products’ speed to market and the examples in these markets can serve as references for other ASEAN countries.

Beyond looking at the long-term goal of a risk-based approach, FIA and AFBA have also put forward short-term recommendations targeted to address specific challenges. An example would be to achieve greater flexibility in the acceptance of alternate documents that provide the information needed, and the acceptance of certifications that are valid and recognised by the exporting country’s competent authorities. These alternatives serve to minimise the chances of documents being rejected and ease the process of passing the safety and compliance assessment.

As the food and agricultural sector is a key priority sector in ASEAN, it is clear that the food industry continues to play a critical part in ASEAN’s economies. For the food industry to continue supporting food security and ensuring that foods are accessible and available, the commitment from ASEAN to remove trade barriers will be critical to preserve the vitality of the food sector.

Access the full report which includes our survey findings and recommendations.



# Free Sale Certificate and Health Certificate are issued by the exporting country
1 Import Recommendation Letter (Importers of food additives that are included in the General Standards for Food Additives issued by Codex Alimentarius Commission, low risk food products (1008 items) and sample to be submitted to FDA are not required to provide both Import Recommendation Letter and Import Health Certificate)
2 Attested by recognised regulatory body or chamber of commerce/ Philippines Consulate in the country of origin
3 For assessment of compliance for medium and high risk products with standards of identity, as well as fortified food products
4 Notarised and authenticated by issuing organisation, embassy or governmental office



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