What Claims Can You Put on a Thai Food Label? (Notification 447)

Two different rules, two different claims

1. Nutrition claims: the numbers game

A nutrition claim is any statement, image, or symbol about a nutrient's level in your food: energy, protein, fat, carbohydrates, vitamins, or minerals. There are two kinds: a nutrient content claim ("high in fiber," "low in fat") states an absolute level; a nutrient comparative claim ("30% less sodium," "light") compares your product to a reference food, either your own original recipe or similar products on the market.

You can only use words like "free from" or "low" if your product doesn't naturally and automatically qualify. If vegetable oil is naturally cholesterol-free without any special processing, you can state that as a fact ("naturally contains no cholesterol"), but you can't market it as though your brand achieved something special by removing it, since that would mislead customers into thinking it's exclusive to you.

2. The thresholds: Table 1 and Table 2

Notification 445 sets two separate threshold tables, and which one applies depends on whether your product has a government-prescribed reference serving size (listed in the notification's Annex 2, which covers most common food categories).

If your product has a prescribed reference serving size, use Table 1: thresholds are calculated per that reference serving size and per your actual labeled serving. If it doesn't, use Table 2: thresholds are calculated per 100g (solid food) or per 100ml (liquid food) instead.

The thresholds at a glance

Look closely at the last row. Protein and fiber claims are measured differently depending on which table applies: by percentage of Thai Reference Daily Intake under Table 1, or by grams under Table 2. The flat "10 grams = high protein" rule repeated online isn't quite right, because it depends on which table your product falls under. If you're not sure which table applies, confirm that before you commit to a claim.

When a nutrient you're not claiming still has to be disclosed

Even if you qualify for a claim like "low sodium," you must disclose a nutrient's amount right next to your claim if your product's total fat, saturated fat, cholesterol, sodium, or total sugar exceeds one of these levels. The disclosure must be in a font at least half the size of the claim itself.

For example, a product making a "low sodium" claim that happens to be high in fat would need to print something like: "Low Sodium, Total Fat 14 grams per 200 milliliters" directly alongside the claim. You can't headline one good number while hiding a less flattering one nearby.

Health claims: three types, three different bars to clear

A health claim connects your food to a health benefit or bodily function, anything from "calcium supports bone health" to "helps reduce cholesterol." Notification 447 splits these into three types.

The critical difference: nutrient function claims using the FDA's own pre-approved wording don't need individual sign-off. Anything else (any other function claim, any disease-risk-reduction claim, or any custom wording not on the approved list) must be assessed by an FDA-recognized nutrition and health claim center and formally approved before you publish it anywhere, including social media.

5. What you must print alongside any health claim

Beyond getting the claim itself approved (or using pre-approved wording), Notification 447 requires several things to appear on the label whenever a health claim is made:

• •The quantity of the claimed nutrient or constituent
• •How much of the food, and how often, is needed to get the claimed benefit
• •The target group, if the claim is aimed at a specific group
• •Guidance for vulnerable groups or anyone who should avoid the product, if applicable
• •The standard statement: "Should eat varieties of five categories of food in appropriate proportion"
• •For "other function claims" and "disease risk reduction claims" specifically: "Not intended to treat, relieve, cure or prevent any disease"

Skipping these required statements is one of the more common, and easily avoidable, mistakes producers make even when the underlying claim is legitimate.

6. The bright line: food claims vs. drug claims

Whatever category your claim falls into, one line can't be crossed: a food product cannot claim to treat, relieve, cure, or prevent any disease. That is a drug claim, and making it on a food product is illegal regardless of scientific backing or approval status.

This is also where the legal exposure sits. Making false, misleading, or unapproved claims under Thailand's Food Act can carry penalties of up to 3 years' imprisonment and/or a fine of up to ฿30,000, with additional fines for advertising without required prior approval. Get this right before printing, not after.

A simple starting checklist

If you're considering putting a claim on your label for the first time, work through it in this order:

1. 1Decide which type of claim you're making, nutrition claim (a number) or health claim (a benefit statement), since they're governed by different rules.
2. 2For a nutrition claim: confirm whether your product has a prescribed reference serving size (Annex 2) to know whether Table 1 or Table 2 applies, then check your actual nutrient values against that table.
3. 3For a health claim: check whether your intended wording is already on the FDA's pre-approved list. If it is, you're clear to use it (provided your nutrient content qualifies). If not, budget time and cost for third-party assessment and FDA approval before your launch date.
4. 4Check whether your product's fat, saturated fat, cholesterol, sodium, or sugar levels trigger a mandatory disclosure alongside your claim.
5. 5Never use language suggesting your product treats, cures, relieves, or prevents a disease, for either claim type.
6. 6Have your nutrient values confirmed by your own calculation or, ideally, lab analysis before committing to a specific number on packaging that's already been printed.