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Andi Refandi
Andi serves as a Senior Account Executive on Emerhub’s global team.
Milk products, such as raw cow milk, sterilized milk, and milk powder, are subject to specific quality standards set by the Thai FDA. Companies involved in importing, manufacturing, distributing, or advertising these products must comply with strict FDA regulations and obtain necessary licenses to market milk products in Thailand.
In this article, we will cover key regulatory frameworks on how to register milk products in Thailand, the requirements needed, and registration process.
Understanding Milk Products Registration in Thailand
What is considered a ‘Milk Product’ by the Thai FDA?
Under Thai FDA regulations, “milk products” covers every food made from the milk of milking animals, excluding infant formula. Milk products are classified as standardized food in Thailand. This means they must comply with specific quality and labeling standards.
There are several subcategories of dairy products as defined by the Thai FDA:
- Fluid milk and milk products
- Fermented and renneted milk products (plain)
- Condensed milk (plain) and analogues
- Cream (plain) and similar products
- Milk powder, cream powder (plain), and powder analogues
- Cheese and analogues
- Dairy-based desserts
- Whey and whey products, excluding whey cheese.
Specifically, cow’s milk products include fresh plain fluid cow’s milk, plain fluid cow’s milk (which can be made from raw whole, partly skimmed, or skimmed milk), milk powder (whole, partly skimmed, or skimmed), condensed milk (unsweetened or sweetened), and recombined milk.
It is important to note that Flavoured milks and any other milk‑based innovations also fall under the same “milk products” umbrella and must observe the corresponding Thai FDA standards.
Why do you Need to Register Milk Products in Thailand?
Milk spoils quickly and ranks among the world’s most common allergens. Product registration helps enforce quality standards for milk products, ensuring they meet specific criteria for safety and quality.
Overall, this process protects consumer health by maintaining the safety and integrity of dairy products available in Thailand.
Compliance and registration with FDA regulations enhance consumer confidence in the safety and quality of your dairy products which can give you a competitive edge in the market. Failure to register can result in legal penalties, including fines and product seizures.
How to Register Milk Products in Thailand
Labeling Requirements for Milk Products
Under the MOPH Notification No. 367 B.E. 2557 (2014) and MOPH Notification No. 401 B.E. 2562 (2019), milk products must have the correct labeling information for dairy products such as ingredients and expiry dates. The following information must be displayed on the product in Thai:
- Product Name: Must comply with specific naming conventions including flavor and heat treatment details for flavored milk.
- Food Serial Number: Obtained during the registration process.
- Manufacturer/Importer Details: Name and address of the manufacturer, packer, or importer.
- Ingredients: Listed in descending order by weight, including allergens.
- Nutritional Information: Required if nutritional claims are made.
- Shelf Life: Displayed as “should consume by” or “expiration date.”
- Storage Conditions: If applicable.
- Warning Statements: For certain types of milk products, such as “Do not feed infants” for specific products.
Registration Process for Milk Products in Thailand
Milk is considered a ‘standardized food’ in Thailand which means they need to meet quality standards but do not need to be registered as specially controlled foods. Other examples of food types in this category are condiments (fish, tomato, chili sauces, etc.), beverages, and honey.
Each step is crucial for ensuring compliance with Thai regulations, especially for milk product manufacturers and importers. Here’s an overview of the registration process for milk products in Thailand:
- Establishing a Legal Entity – you need to establish a legal entity in Thailand before you register your milk products with the FDA. This involves reserving a company name, drafting a Memorandum of Association and Articles of Association, and registering with the Department of Business Development (DBD).
- VAT Registration – If your business is projected to have a turnover exceeding THB 1.8 million, you must register for Value-Added Tax (VAT). VAT registration is typically completed within a week and involves filing monthly returns by the 15th of the following month.
- Product Registration with the Thai FDA – Each product must be tested and registered individually with the Thai FDA once the Import & Export License is issued. The documents required are:
- Company Documents (Company Affidavit, Business License)
- Labeling & Packaging Design (must comply with Thai regulations)
- Certificate of Free Sale (CFS) from the country of origin
- GMP Certificate (Good Manufacturing Practice)
- Analysis Reports (Heavy Metals, Microbiological Tests)
- Submission of application – registration is submitted through the Food e-Submission System, requiring a commercial registration certificate and a place of business in Thailand. The Thai FDA has introduced a fast-track procedure for milk products, which can expedite the approval process to as little as seven business days.
- Obtaining Additional Certificates – to fully access the Thai market, you would need additional certifications such as Halal or ISO 22000 for food safety These certifications are not mandatory but can enhance the marketability of your milk products in Thailand.
How to Import Milk Products to Thailand
Requirements for an Import License
To legally import food-related products, you need an import license and approval from the FDA. You need to register a warehouse facility, preferably in the same province as your registered address. The FDA will inspect the warehouse to verify compliance with regulatory standards. Aside from that, a Thai director is also needed to represent your company.
Here are documents you need to apply for an import license in Thailand:
- Commercial Registration Certificate: Proof that your company is a registered legal entity in Thailand.
- Orr 6 Form: application form for a food import license, which requires detailed information about the products to be imported.
- Product Specifications: Detailed descriptions of the milk products, including ingredients, nutritional content, and labeling information.
- Certificate of Origin: verifies the country of origin of the milk products. It must accompany the shipment at the time of entry.
- Sanitary Certificate: required to ensure that the products meet health and safety standards.
- Commercial Invoice: provides details about the transaction, including the quantity and value of the goods.
- Bill of Lading: document issued by the carrier that details the type, quantity, and destination of the goods.
- Medical Certificate: In some cases, a medical certificate may be required to certify the importer’s details and compliance with health regulations.
How to Import Milk Products without an Import License
If you need to import your food products without an import license or a legal entity, you can always use Emerhub’s Importer of Record (IOR) in Thailand. We will act as your consignee in the country and handle customs clearance and logistics on your behalf. Here’s how we can help you import milk products in Thailand:
- Compliance with Regulations: we will ensure that all imported milk products comply with Thai regulations, including quality standards and labeling requirements set by the Thai FDA.
- Customs Clearance: handle all customs clearance procedures, which involve preparing and submitting necessary documents, such as commercial invoices and certificates of origin.
- Documentation Management: we will manage and verify all shipping documents, including packing lists, HS codes, and commercial invoices, to ensure accurate customs declarations.
Emerhub can help you navigate the country’s complex FDA registration and customs processes. Fill in the form below and our local experts will get in touch!
FAQs About How to Register Milk Products in Thailand
Each milk product must be registered individually under the Thai FDA. The fast-track procedure can expedite this process by simplifying registration. Each product must comply with the labeling and documentation requirements set by the Thai FDA.
Standardized foods have a medium risk level and do not require registration but must meet specific quality and labeling standards as outlined by the Ministry of Public Health. On the other hand, specially controlled foods are high-risk foods that require strict control and registration before production or importation. These include foods for specific consumer risk groups, such as infants, and have detailed quality standards, labeling, and production processes.
If there are changes to a registered milk product in Thailand, you should follow these steps:
- The Thai FDA will review your submission and may request additional information before approving the changes.
- Classify the change as either “major” or “minor.” Major changes require review by the Thai FDA or external specialists, while minor changes may have a faster approval process.
- Use the Thai FDA’s Skynet system to submit a request for amendment. Attach required documents such as a declaration of conformity, label updates, and any other relevant documentation.
- Include an explanation letter outlining the reasons for the change and ensure that the changes do not affect the product’s safety or intended use.
