Can You Really Claim “Sugar-Free” or “Trans Fat-Free”? Understanding Food Packaging Claims in Malaysia
“Sugar-Free.” “Low Fat.” “High in Calcium.” “Trans Fat-Free.”
These claims are commonly displayed on food packaging and can strongly influence consumers’ purchasing decisions. But before putting these words on a product label, there is an important question manufacturers should ask:
Does your product actually meet the regulatory criteria for the claim?
Under Malaysia’s Food Regulations 1985, nutrition claims are subject to specific requirements. Terms such as “free”, “low”, “source of”, “high in” and “reduced” are more than marketing statements – they can carry specific regulatory meanings.
What Does “Free” Actually Mean?
Under Regulation 18C, a nutrient content claim describes the level of a nutrient contained in a food. When a prescribed nutrient content claim is made, the product must fulfil the applicable conditions under the Fifth A Schedule.
For example, criteria are established for claims such as:
Sugar-Free | Fat-Free | Cholesterol-Free | Sodium-Free | Trans Fat-Free
Interestingly, “free” does not always mean absolute zero.
A “sugar-free” product, for example, is subject to a specified maximum sugar content. A product formulated without adding table sugar may still contain naturally occurring sugars contributed by other ingredients.
Therefore, “No Added Sugar” and “Sugar-Free” are not necessarily the same claim.
The composition of the finished product matters.
Latest Update: New Trans Fat-Free Claim Criteria
Malaysia has recently updated its criteria for trans fatty acid-free claims through the Food (Amendment) (No. 2) Regulations 2026 [P.U.(A) 221/2026], which comes into operation on 16 December 2026.
Under the amended requirements, a “Trans Fatty Acids Free” claim may be made when the trans fatty acid content does not exceed:
| Product Category | Maximum Trans Fatty Acids |
| Edible fat/ oil – solid | 0.5 g/100 g |
| Edible fat/ oil – liquid | 0.5 g/100 ml |
| Other food – solid | 0.1 g/100 g |
| Other food – liquid | 0.1 g/100 ml |
This update is particularly relevant to manufacturers of edible oils, margarine, shortening, bakery products and other foods carrying or intending to carry trans-fat-related claims.
It’s Not Just About “Free”
The same principle applies to other nutrition claims.
Claims such as “Low Sugar”, “High in Calcium”, “Source of Protein” or “Reduced Sodium” may each have their own applicable conditions.
Changing your packaging from “Low Sugar” to “Sugar-Free”, for example, is not simply a marketing decision. The finished product must meet the criteria applicable to the new claim.
Test Before You Claim
Before finalising a product label, manufacturers should consider:
Intended Claim → Check Regulatory Criteria → Laboratory Testing → Verify Results → Review Nutrition Information & Label → Finalise Packaging
Depending on the intended claim, laboratory testing may include total sugars, fat, saturated fat, trans fatty acids, cholesterol, sodium, protein, dietary fibre, vitamins and minerals.
Analytical testing can provide objective evidence to support the nutrient composition of the finished product and help manufacturers evaluate whether their intended claims meet the applicable requirements.
Verify Before You Print
Words such as “free”, “low”, “high” and “source of” may look simple on packaging, but they can carry specific regulatory meaning.
With Malaysia’s updated trans fatty acid-free criteria taking effect on 16 December 2026, now is a good time for food manufacturers to review existing product claims and packaging.
Planning to make a nutrition claim on your food product?
MY CO2 provides food and nutrition testing services to support product claim verification, nutrition labelling and regulatory compliance.
Test before you claim. Verify before you print.