Food and Agricultural Import Regulations and Standards Country Report - Riyadh - Saudi Arabia - SA2022-0011 PDF
Food and Agricultural Import Regulations and Standards Country Report - Riyadh - Saudi Arabia - SA2022-0011 PDF
Post: Riyadh
Report Highlights:
Over the past several years, Saudi Arabia published quite a few new regulations and standards,
some of which were notified to the World Trade Organization (WTO). Unfortunately, many of
these standards were notified and immediately implemented, missing the opportunity to engage
with international stakeholders and making it difficult for U.S. exporters to adjust. The new
regulations include a registration requirement for export facilities and competent authorities that
could be problematic for various U.S. food products. However, in June 2022, the Saudi Food and
Drug Authority (SFDA) finally postponed their Front of Package Nutritional Labeling regulation
indefinitely, which is great news for numerous U.S. agricultural products.
THIS REPORT CONTAINS ASSESSMENTS OF COMMODITY AND TRADE ISSUES MADE BY USDA STAFF AND NOT NECESSARILY
STATEMENTS OF OFFICIAL U.S. GOVERNMENT POLICY
TABLE OF CONTENTS
The United States annually exports more than $1.5 billion (USD) of agricultural and related
products directly and indirectly to the Kingdom of Saudi Arabia. Saudi Arabia is reliant on
imports to meet up to 75 percent of its food consumption needs, and U.S. retail food exports to
Saudi Arabia have grown rapidly over the past several years. U.S. exports of consumer-oriented
food products to Saudi Arabia decreased four percent in 2021, compared to 2020, to
approximately $535 million mainly due to shipping issues (e.g., fewer cargo ships, higher costs,
etc.) throughout the year. Unfortunately, this trend is expected to continue throughout 2022.
The Saudi Food and Drug Authority (SFDA) is the Saudi government entity that sets and
enforces regulations and standards related to processed food, seafood, fresh produce, and
processed animal feed. In recent years, SFDA has been issuing new announcements, regulations,
and standards at an extremely rapid pace. Since the last GAIN report in 2021, SFDA issued
several draft regulations to the World Trade Organization (WTO) for public comments including
Guidelines for Marketing Requirements of Food Directed to Children as well as registration and
recognition requirements for competent authorities of food exporting countries. On the other
hand, SFDA recently postponed their Front of Package Nutritional Labeling (FOPNL)
regulation, which would have been problematic for numerous agricultural products.
Some recent regulations have dealt with food additives (Additives Permitted For Use In
Foodstuffs - SFDA.FD 2500/2021), a comprehensive 373-page technical regulation that lists all
allowed food additives, including food coloring agents. This regulation is a good reference for
U.S. exporters of processed food products as it lists allowed food coloring. One of the artificial
food colorings eliminated from the allowed list is Tartrazine, or E102, which has caused
rejections of some U.S. food products at Saudi ports of entry. Another recently updated and
broad technical regulation implemented in Saudi Arabia, and other Gulf Cooperation Countries
(GCC) as well as Yemen, is the Gulf Standardization Organization (GSO) regulation number
193:2021. This regulation deals with contaminants and toxins in food and feed.
Over the past few years, issues with implementation of existing regulations have closed or
threatened to close the market for several U.S. products. At the end of 2018, SFDA abruptly
introduced new facility registration and certification requirements for eggs, egg products, and
seafood, which immediately stopped shipments of those products from several countries,
including the United States. Requirements were loosened for a few months in early 2020 due to
the COVID-19 outbreak to help the country’s food supply but were reapplied once domestic
supplies increased. Since May 2018, U.S. poultry meat has been absent from the Saudi market
after SFDA implemented a ban on poultry stunning by electrical or controlled atmosphere
methods.
One positive development has been the return of U.S. seafood to the Saudi market in 2022 due to
the resolution of a facility registration requirement between the United States and SFDA. FDA is
the U.S. competent authority for food safety of seafood, honey, and bee products. To facilitate
U.S. exports of these products, FDA has updated the Export Listing Module (ELM) allowing
U.S. establishments to request FDA certification for inclusion on SFDA’s lists of approved
establishments. U.S. establishments are eligible for listing if they are in substantial compliance
with applicable FDA requirements for the products intended for export. For ease of reference,
FDA refers to the Saudi Arabia lists, Saudi Arabia honey and bee products export list and the
Saudi Arabia seafood export list, for these products. More information on the FDA listing
process and requirements may be found at this link. As of April 2022, 56 U.S. seafood
establishments have been approved and registered with SFDA through FDA to export wild
caught fish to the Kingdom of Saudi Arabia (list available here)
SFDA was formed in 2009 and is the Saudi government agency responsible for establishing
regulations and standards concerning food and animal feed. It is also responsible for the
inspection of both domestically produced and imported food products. The Saudi Food Act states
that “Imported food shall not be released prior to SFDA’s approval as laid down by the
regulations, policies, and procedure. SFDA shall be responsible for developing regulatory bylaws
for controlling the clearance process of foodstuff intended for importation into the Kingdom of
Saudi Arabia. Countries exporting their products to the Kingdom of Saudi Arabia shall comply
with the import conditions and requirements issued by SFDA.” SFDA determines if imported
products meet all the standards and regulations established by Saudi Arabia and the Gulf
Standardization Organization (GSO), which is the standards setting agency of the Gulf
Cooperation Council (GCC) and Yemen. SFDA is an autonomous entity controlled by a Board
of Directors, and its chairman is appointed by Royal Decree. The current Chairman of the Board
is the Minister of Health. The Board of Directors reports directly to the King of Saudi Arabia,
and SFDA board of directors consists of:
SFDA’s primary regulations (the Saudi Food and Animal Feed Acts) were issued and
implemented in 2016. The Saudi Food Act covers all stages of the food chain to ensure food
safety, quality improvement, and the protection of consumer health by minimizing food-related
risks. The Saudi Feed Act applies to all stages of the feed chain to guarantee animal feed safety.
Its purpose is to safeguard human health from harmful substances resulting from feeding
animals’ unsafe feed. Both imported and domestically produced food and feed products are
subject to the same food safety regulations and labeling requirements.
The SFDA’s Operations Sector inspects imported foods and processed feed products at the ports
of entry, and mostly conducts tests on imported as well as domestically produced foods,
processed feed and animal products at its own laboratories. However, it uses other government
agencies’ laboratories or accredited domestic private laboratories when needed.
All food, drinks, and edible agricultural products are required to comply with regulations and
standards set by the SFDA, or the GSO, and includes food ingredients and processed animal
feed. Two SFDA “sectors” (Food and Operations) affect trade in food. The Food Sector is
primarily responsible for issuing food and animal feed regulations and standards while the
Operations Sector is responsible for inspecting both imported and domestically produced food
and animal feed products for compliance with existing SFDA, or GSO, regulations and
standards. The SFDA’s Food Sector has several departments including risk assessment and food
and feed standards. The main duties of the Operations Sector are:
1. Evaluate and register imported food and feed on SFDA’s E-Service portal,
2. Inspect imported food and feed products at Saudi ports of entry,
3. Register and inspect foreign facilities that export seafood, livestock, and poultry meat to
Saudi Arabia,
4. Issue health certificates for food product exports, and
5. Inspect local food and feed factories
The GSO is made up of the national standards bodies of Yemen and the six GCC countries (the
United Arab Emirates, Saudi Arabia, Kuwait, Bahrain, Oman, and Qatar). As a group, the GSO’s
main role is to create a common set of regulations and standards. The GSO’s Food Standards
Committee (FSC) is responsible for drafting new food regulations and standards and updating
existing ones. The Chairman of the FSC rotates among the member states. All GSO draft
standards are submitted for review and approval to the GSO Board of Directors (BOD), which is
composed of the ministers responsible for standardization in each member state. They meet twice
a year to deliberate on standards and other related issues.
GSO draft regulations and standards are generally notified to the WTO by the seven member
countries and are open for public comments for sixty days. Once a new standard is approved by
the BOD, it is implemented in each member state, and in most cases after a phase-in period of six
months from the date of approval. In practice, GCC countries differ concerning the timing of
implementation and the enforcement of new GSO technical regulations. GSO issues two types of
official documents that govern food and agricultural products:
2. GSO Standards: GSO standards are adopted by a majority vote of member states and
implementation is voluntary in all member countries.
GSO standards are often based on Codex Alimentarius regulations and to some extent on
European and U.S. standards, but are modified to reflect local religious, cultural, and climatic
conditions. The GSO often adopts existing member countries’ standards after updating them and
making sure that they conform to Codex Alimentarius guidelines and/or International
Organization for Standardization (ISO) standards. The GSO Ministerial Board has authorized the
GSO to adopt international standards in their original language as a fast-track measure to develop
and increase the total number of Gulf standards. As such, the GSO has adopted several ISO and
Codex technical regulations and standards.
GSO issued standards are implemented in the seven member countries. Saudi Arabia implements
GSO regulations and standards if they are more recently updated compared to existing SFDA
regulations. However, while originating from the GSO, there are some of SFDA regulations that
are not compatible with international standards and/or U.S. regulations or are costly to enforce or
implement. Examples of this include the ban on animal protein in animal feed the ban on poultry
stunning/immobilization for religious purposes, and nutrition labeling requirements.
English copies of GSO standards mentioned in this report and other food/agricultural are
available and can be purchased from the GSO headquarters in Riyadh by clicking on this link:
GSO Standards Store. For a list of SFDA’s technical regulations and standards for food, seafood
and agricultural products, please use this link. The SFDA technical regulations and standards can
be purchased from SFDA online store.
SFDA regulations for livestock and poultry meat products require that health certificates
accompany shipments of livestock and poultry meat, and the certificates must clearly indicate
that animals slaughtered have not been fed animal protein. In order for the U.S. Food Safety and
Inspection Service (FSIS) to issue the required animal protein free certification, U.S. exporters of
beef, poultry and related products to the Kingdom must come from slaughter facilities that
participate in the Agricultural Marketing Service’s (AMS) Export Verification (EV) Programs:
the USDA Bovine Export Verification Program for beef or the Animal Protein Free Verification
Program for poultry (APFV).
At the end of May 2018, SFDA implemented part of GSO 993, which was based on more than a
two-decades-old Islamic religious edict that bans poultry stunning/immobilization in the poultry
slaughtering process. This prohibition on stunning is based on the concern that the stunning
process kills the birds ahead of slaughter, preventing the bird from being certified as halal. This
requirement has stopped exports of U.S. poultry meat and products to Saudi Arabia. Through
bilateral and multilateral fora, the United States has provided technical information and
assurances to SFDA that electrical stunning as practiced in the United States does not kill the
birds and that U.S. government regulations require that they are alive and verified after stunning
by FSIS inspectors.
In September 2017, SFDA began work on a healthy food program aimed at (1) the
implementation of a healthy food strategy, (2) developing health food regulations and policy, (3)
innovative initiatives to promote healthier lifestyles, and (4) improving the quality of food
products.
On January 1, 2020, SFDA banned the use of added sugar or its sources (honey, glucose syrup)
artificial flavors, color additives and energy drinks in “fresh and mixed juices. The regulation
was enforced July 1, 2021on food service outlets operating in the Kingdom.
All imported and locally produced prepackaged food products must meet the labeling
requirements indicated in GSO 9:2013 (SFDA.FD/GSO 9:2013). Prepackaged food product
labels should be in Arabic or include an Arabic language translation on the label. Labels must
contain the product name, packer’s name, country of origin (COO) of manufacture or production,
list of ingredients in descending order of predominance, instructions for the end use of the
product (where applicable), and the shelf-life of the product. COO labeling is mandatory for
imported and locally produced products in Saudi Arabia.
If a food product undergoes processing in a second country, changing its nature, the country in
which the processing is performed is the COO of the product. It is prohibited to mention on a
product that has been packaged or processed without changing its nature that it is produced in the
packing country. However, a phrase can be declared stating that the packaging and processing
has been done by the packaging company in the exporting country mentioning the COO of the
products. For example, rice imported from the United States, but packed in Saudi Arabia may be
labeled as: a “rice” product of the United States packed in Saudi Arabia by ABC company.
SFDA.FD/GSO 2487, which was issued in 2015, discusses general requirements for foodstuff
labeling including “stickering.” As a member of the GCC countries, Saudi Arabia began
implementing Gulf standard GSO 2015 in 2015. Section 7.2.2.1 of the regulation states that if the
Arabic labeling information is stated in a supplementary sticker, a single sticker must be
provided by the manufacture (designed and printed).
GSO member countries, including Saudi Arabia, require that labels of pre-packaged food
products include both production and expiration dates printed on the label prior to export. The
following are GSO regulations that govern shelf life for food products:
• SFDA.FD 150-1:2021 “Expiration Dates for Food Products - Part 1: Mandatory
Expiration Dates” requires mandatory expiration periods for perishable foods, such as
fresh or chilled meat and poultry; fresh milk and fresh milk-based products; margarine;
fresh fruit juice; table eggs, and baby food.
• SFDA.FD/GSO 150-2:2013 “Expiration Dates for Food Products - Part 2: Voluntary
Expiration Dates” lists suggested expiry periods for non-perishable food products but
allows manufacturers to determine science-based use-by dates.
Shelf life can only be shown by clear and unambiguous production and expiration dates. The use
of any of the following statements for expressing expiration date is permissible.
• Expiration Date
• Use by (date)
• Fit for (from the day of production)
• Use Before (date)
• Sell by date (for food products having an expiration period exceeding 3 months).
The production and expiration dates should be declared on the label of the package as follows:
• Day-Month-Year: for foodstuffs with an expiration period less than three months.
• Month-Year: for foodstuffs with expiration exceeding three months.
Dates must be engraved or in relief and printed by stamp with permanent ink directly on all
packages, or on their original label by the producer. Adding stickers for production and
expiration dates is not permissible. There may not be more than one date of production or
expiration on the same package. The dates may not be deleted, changed or be deceitful. Only the
date of production or processing needs to be shown (mm/yy) for products with no specific
expiration date. Examples of these products include salt, spices, and milled rice. U.S. exporters
should cross check information on the food label, including Production and Expiration dates,
with the Saudi buyer before putting together an order.
On February 2, 2021, the Saudi Food and Drug Authority (SFDA) increased the shelf-life
requirement for U.S. chilled beef from 70 to 120 days (SFDA.FD 150-1:2021). This measure is
expected to help U.S. exporters save at least $4 per kg while providing Saudi importers with the
flexibility to purchase larger quantities of U.S. beef. Since 2016, Post has been seeking a longer
shelf life for U.S. beef, and this announcement was a welcome sign for many beef importers in
Saudi Arabia. In 2021, the United States exported approximately $12 million in U.S. beef to
Saudi Arabia, and that amount is expected to significantly increase over the next several years
due to the extended shelf life.
SFDA.FD/GSO 150-2 sets expiration period for frozen livestock and poultry meat at 12 months.
However, producers could set a higher expiration period if they provide scientific justifications
to SFDA for setting a longer expiration period.
2) Additional Labeling Requirements
In addition to requirements per SFDA.FD/GSO 9:2013, the following labeling information must
be declared for food additives and antioxidants used in food:
For colorings used in foodstuffs, their mixtures, preparations and diluents, the following
additional information must be declared:
1. Common name
2. Color index number
3. Name of solvent or diluent
4. Production and expiration dates in a non-coded manner (day-month-year)
5. Dye purity
6. The statement “Free from alcohol”
7. The statement “Color matter for use in foodstuffs.”
For flavors permitted for use in food, the common name and code number (if found) must
be declared on food product containers containing flavors.
For preservatives permitted for use in food products, the label must identify the common
name or European Economic Community (EEC) number and a statement “Preservative
for Use in Food Products” on preservative containers.
For emulsifiers, stabilizers, and thickeners permitted for use in food, the following
additional information must be declared:
1. Common name or EEC number.
2. In case of gelatin, lecithin, and mono- and diglycerides, the source shall be
mentioned.
For Sweeteners Permitted for Use in Food Products
1. The name of sweeteners or International Numbering System (INS)
numbers as determined by the Codex Alimentarius committee.
2. Food products formulated specifically for use by diabetics or for other
special nutritional uses shall contain the statement “Food for special
dietary use or food for diabetic” along with the amount of sweetener in
mg/liter or in kgs.
3. For combinations of sweeteners, the amount of each in combination shall
be declared.
The following additional labeling information must be declared for antioxidants permitted for
use in food:
Common name or EEC number.
A statement “Antioxidants permitted for use in foodstuffs” in case of antioxidant
containers.
3) Other Specific Labeling Requirements
Nutrition Facts
8 servings per container
Serving size 2/3 cup (55g)
Amount per serving or 100 ml or 100g
Calories 230
Daily Need Percentage %
[illegible text]
Cholesterol 0mg 0%
Sodium 160mg 7%
Total Carbohydrate 37g 13%
Dietary Fiber 4g 14%
Total Sugars 4g 5%
Includes 10g Added Sugars 20%
Protein 3g
* Is lower than the daily need
percentage for nutrients of one
serving based on a nutritional
diet including 2000 calories
SFDA requires that food product importers and domestic producers strictly follow pertinent
regulations such as SFDA.FD/GSO 9:2013 “Labeling of Prepackaged Food Products” and
SFDA.FD 2233:2018 “Requirements of Nutritional Labeling” when disclosing the required
nutrition information.
Definition of Dietary Foods: SFDA standard SFDA.FD 654:2017 defines dietary foods as food
products specially prepared or formulated to satisfy dietary requirements and are intended for
consumers with physical or physiological conditions and/or specific diseases or disorders. These
foods differ significantly in composition from the ordinary products of comparable nature if such
ordinary foods exist. The following requirements need to be met by prepackaged foods for
special dietary uses:
The product must be completely free from pork products or their derivatives.
It must be registered by the Saudi Ministry of Health (MOH).
o Note that infant formulas and baby foods such as infant formula, ready-made soft
and wet foods, breakfast cereals, dry finger foods (including biscuits and snacks)
are not considered foods for special dietary uses and there are specific registration
requirements for them. All imported baby foods and formulas are inspected by
SFDA at Saudi ports of entry and must comply with pertinent GSO or Saudi
quality regulations and standards.
It should not be pharmaceutically packaged in a way suggesting that it is a drug.
It must be offered for sale in places separated from the ordinary foods in supermarkets.
Foods for special dietary uses for infants and children shall be dispensed only by
pharmacies, hospitals, and childcare centers.
Artificial sweeteners are not permitted to be used in any baby and infant foods.
SFDA.FD 2233:2018: This regulation states the procedures for the nutrition labelling of foods. It
applies to the nutrition labelling of all prepackaged food products except for raw products such
as fresh fruits, vegetables, meat, and fish.
SFDA.FD 2333:2018: This 55-page technical regulation contains guidelines on prohibited and
permitted health and nutrition claims in food labelling. Below are the lists of claims that are
prohibited and those that are allowed on labels of food products sold in Saudi Arabia:
a. The following health and nutrition claims are prohibited on food product labels:
Claims that refer to the rate or amount of weight loss.
Claims that refer to recommendations of individual doctors or health
professionals cannot be made on food.
Claims that suggest that health could be affected by not consuming the food.
Claims that a food can be used in the prevention, alleviation, treatment or cure
of a disease, disorder, or physiological condition.
Claims stating that any given food will provide an adequate source of all
essential nutrients.
Claims implying that a balanced diet or ordinary foods cannot supply adequate
amounts of all nutrients.
Claims that cannot be substantiated.
Claims that could give rise to doubt about the safety of similar food or which
could arouse or exploit fear in the consumer.
Meaningless claims including incomplete comparatives and superlatives.
Claims as to good hygienic practice, such as “wholesome”, “healthful”,
“sound”.
b. List of permitted health and nutrition claims used on labels of food products:
Health Claims listed in Table No. (1) of SFDA.FD 2333:2018 are permitted to
be used on the food label and for advertising purposes. The list is currently 49
pages long. These claims should be accompanied with all necessary conditions
(including restrictions & warnings) for their use.
Wording and presentation of claims to be made on food products should be
truthful, clear, reliable, and useful to the consumer. Flexibility with the
wording of claims (including graphics and symbols) is allowed if it provides
the same meaning for consumers as the listed in the tables (1 and 2) and they
are not misleading.
Any health and nutrition claim made on food products label is prohibited
unless it fulfills conditions mentioned in SFDA.FD 2333:2018
In July 2019, SFDA announced new labeling and facility registration requirements for fresh
imported fruit and vegetables. SFDA did not notify the new produce labeling and exporting
facilities registration requirements to the WTO and claimed that they were not TBT changes. An
SFDA letter dated August 14, 2019, gave importers of fresh horticultural products a six-month
grace period to adopt the new labeling requirements and commence registering their suppliers.
The grace period ended on Feb 25, 2020.
SFDA recently approved a label signaling that it fulfills the fresh horticulture products labeling
requirements. The sample label below is believed to provide most of the information needed for
SFDA facility registration. The label is to be affixed on individual product package.
Fruit Name : الصنف
Quality Grade :الدرجة
As part of the Healthy Food Program, SFDA issued several new technical regulations
and standards since 2018. Measures one through six below have been identified as the
most relevant to U.S. agricultural exports to Saudi Arabia:
1. In September 2018, SFDA issued SFDA.FD 42/2018 “Front of Pack Nutritional
Labeling (FOPNL)”, which laid out a traffic light style labeling system (blue,
yellow, and red) based on sugar, fat and salt levels found in processed food
products, with a format and thresholds unique to Saudi Arabia. Following
feedback from local industry and trading partners in 2018, SFDA decided to make
this FOPNL scheme voluntary. However, on September 20, 2021, SFDA re-
notified to the WTO a revised draft regulation (G/TBT/N/SAU/1212) making the
FOPNL requirements mandatory. The comment period ended on November 19,
2021, but date of adoption of the regulation has not been determined. The
notification indicated that the regulation will be enforced 18 months from the date
of adoption. However, it was announced at the end of June 2022, the
implementation was postponed indefinitely.
2. On September 20, 2021, SFDA notified to the WTO TBT Committee a draft
measure titled, “Requirements of Food Products with High Nutritional Value,”
(G/TBT/N/SAU/1211) with a November 19, 2021, closing comment date. The
draft technical regulation deals with the requirements are based on Nutrient
Profiling Model for the Kingdom of Saudi Arabia (Arabic language document).
The reported main goal of the regulation is to increase consumer’s awareness and
empower consumers in selecting healthier food choices.
3. On June 28, 2021, SFDA notified to the WTO TBT Committee a draft regulation
number G/TBT/N/SAU/1202 “Guidelines for Marketing Requirements of Food
Directed to Children”, The guidelines are concerned with controlling the
marketing of food directed to children (prepackaged and food meals provided in
food establishments) which falls under criteria of low nutritional value based on
the Kingdom’s nutrients profile adopted from the UK nutrient profile model. The
draft regulation bans advertising of such products to children less than 12 years
old of foods high in sugar, fat, and sodium contents. The deadline for providing
comments was August 27, 2021. A U.S. concerned about this notification
because it is not clear what calculation methods are used to classify food products
as low nutritional value.
4. SFDA.FD 59/2018 “Salt Limits Guidelines in Food Products” sets the maximum
limit for salt in 22 processed food products such as meat, cereals, snack foods and
cheese. The voluntary standard urged local food producers and food products
exporters to implement its recommendation by January 1, 2020. Though this
standard was announced as voluntary, sometimes, SFDA inspectors at ports of
entry enforce voluntary standards as mandatory by mistake. If that occurs, U.S.
suppliers should immediately contact FAS Riyadh for assistance.
5. On January 1, 2020, SFDA implemented its regulation number SFDA.FD 2483
issued in 2018 banning the use of partially hydrogenated oils in all food products
imported or locally produced due to health concerns.
6. On October 1, 2020, SFDA implemented its Technical Regulations number
SFDA.FD 2233/2018 or GSO 2233/2018 "Nutritional Data Requirements for
Food Products' Card” or the Nutritional Fact Label, also known as the “Back of
Pack” nutritional facts panel.
7. In force since October 1, 2019, SFDA.FD 56/2018 “Declaration of Allergens on
Food Establishments Menu’s Selling Away-From-Home Foods” requires food
establishments to provide allergy warnings on menus of foods they serve to
customers.
8. On January 1, 2019, SFDA implemented SFDA.FD 20:2018, which mandates the
food service sector to display caloric information on menus of prepared foods.
SFDA says the requirement is needed to increase consumers’ awareness of
nutritional information of the food they consume so they can make healthier
consumption decisions.
9. SFDA.FD 2362/2018 “Technical Requirements of Bread Production” sets the
maximum level of salt in domestically produced bread at 1 gram per 100 grams of
produced bread. The regulation was implemented on June 12, 2019. SFDA stated
that the new sodium limit in bread aims at harmonizing its legislations with the
requirements of the World Health Organization (WHO), which aims to reduce the
consumption of salt used in food products.
SFDA collaborates with other Saudi government ministries and agencies to achieve its food
safety and healthy food goals. On December 1, 2019, the Saudi General Authority of Zakat and
Tax (GAZT) started collecting a 50 percent selective tax on sugary drinks in the local market.
GAZT defined sugary drinks as any product in which any source of sugar or other sweeteners is
added, to be taken as a drink, whether ready for drinking, or in the form of a liquid concentrate,
powder, gel, extract, or any form that can be converted into a drink.
In June 2017, the Kingdom started to levy a 100 percent tax on energy drinks and cigarettes and
50 percent tax on carbonated drinks. GAZT is a government agency in Saudi Arabia responsible
for the assessment and collection of Zakat and taxes including VAT. Zakat is one of the five
pillars of Islam and an obligatory charitable contribution. It is collected from all Muslims who
meet certain criteria of wealth to help the needy.
SFDA officials are hopeful that the above measures will help address Saudi Arabia’s problems
with obesity and diabetes.
SFDA.FD/GSO 2471 was issued in 2015 and provides requirements for the labeling of body
building food products. The standard deals with food supplements used for body building that
contains nutrients such as amino acids, vitamins, minerals, etc.
SFDA.FD/GSO CODEX STAN 107:2007: Labeling of food additives when sold as such. This
standard is concerned with the labeling of any food additives sold as food additives to consumers
or food manufacturers for use as ingredients in preparing or manufacturing food products.
On April 12, 2011, GSO issued two mandatory agricultural biotechnology regulations, GSO
2141:2011 - SFDA.FD/GSO 2141:2011 (General Requirements for Genetically Modified
Unprocessed Agricultural Products) and GSO 2142:2011- SFDA.FD/GSO 2142:2011 (General
Requirements for Genetically Modified Processed Agricultural Products). GSO 2141:2011 deals
with general requirements for genetically modified unprocessed agricultural products, while
GSO 2412:2011 specifies the general requirements for genetically modified processed food and
feed products. The two technical regulations require positive biotech labeling if unprocessed
agricultural products, processed food products, feed products or seed contains more than one
percent of genetically engineered (GE) ingredients.
Saudi Arabia, which was the lead GCC country in preparing the draft standards for the two GSO
biotech regulations, became the first GSO member country to implement these regulations
domestically in October 2011. With more than a decade of experience implementing similar
regulations for dealing with both processed food and feed products, it was relatively easy for
Saudi Arabia to implement the GSO technical GE regulations.
These technical regulations replaced the old Saudi agricultural biotech labeling decrees by
increasing the biotech threshold level from 0.9 percent to one percent and rescinded the ban on
imports of biotech planting seeds according to specifications outlined in GSO 2141:2011.
However, no biotech planting seeds have been imported thus far into Saudi Arabia.
Specifically, the Saudi biotech regulation, GSO 2141:2011, prohibits the importation of any
genetically modified animals, birds, fish, and their products. Meanwhile, the SFDA.FD/GSO
2502:2015 and compilation of Codex texts relevant to the labeling of foods derived from modern
biotechnology recalls and compiles in a single document some important elements of guidance
from Codex texts, which are relevant to labelling of foods derived from modern biotechnology.”
a. Positive Labeling
If a product contains one or more GE plant ingredients with more than one percent GE
content, the words (genetically modified) or (produced from genetically modified, name
of the ingredients) shall appear clearly and easy to read in parentheses immediately
following the ingredient(s) concerned, with same font size and different color. The GSO
biotech regulations do not allow imports of foodstuffs that contain GE animal products.
According to the SFDA, local food producers must also abide by the biotech labeling
requirements.
b. Bilingual Labeling
Labeling and adjoining explanatory statements shall be in Arabic and, where another
language is used, it shall be alongside the Arabic. All information that is provided in
another language shall be identical with those written in Arabic. The biotech statement
must be clearly written in an easy-to-read font in both Arabic and English (upper case),
with a different color from the main product label.
If the GE food product is different from its conventional counterpart, the labeling shall
mention any characteristic or property concerning the following:
Composition
Mode of storage and packing
Nutritional value or nutritional effects.
Intended use of product.
Any implication on certain group of people, certain animals, or the
environment.
Physical characteristic (color, taste, odor, and the touch).
Methods for the safe handling, storage, transport, and use.
If the food product does not have a conventional counterpart, the label shall contain
appropriate information about the nature and characteristics of the food product
concerned. If the mode of storage, preparation or cooking of the product is no longer
equivalent to or differs significantly from the corresponding conventional food, clear
instructions on use must be given on the label of the product.
c. Health Certificate
Biotech agricultural products exported to Saudi Arabia and GCC countries must have
been approved in the country of origin for human or animal consumption, or for use as
planting seeds, and meet all relevant Saudi and GSO-approved regulations and standards.
Each shipment must be accompanied by an official health certificate issued by a
competent government agency stating that the GE ingredient(s) used in the foodstuff,
grains or seed exported is approved in the country of origin for human or animal
consumption or for planting seeds. The SFDA accepts health certificates issued by the
FDA and federal or state departments of agriculture for high value and processed feed
products. Health certificates issued by exporting companies or other private
organizations, including notary public statements are not recognized.
For U.S. biotech feed grains, the Ministry of Environment, Water, and Agriculture
(MEWA) accepts the biotech grains certification statement that was provided in 2003 by
the USDA’s Grain Inspection, Packers and Stockyards Administration (GIPSA). The
statement certifies that the exported transgenic feed grains and oilseeds (corn and
soybean, and soybean meal) are the same as those consumed in the United States. The
approved statement eliminates the need for a shipment-by-shipment positive biotech
certification for unprocessed agricultural products that is required by section 4.1.5. of the
GSO 2141:2011.
Saudi Arabia implements PCR Real Time Method for GE testing. Samples for laboratory
analysis are taken according to GSO ISO standards numbers 21098, 21569, 21570,
21571, 21572 and 24276.
The Saudi Arabian Standards Organization (SASO) is responsible for issuing standards for
nonfood products including those that come in contact with food products. On February 3, 2020,
the organization announced (Arabic text) the suspension of implementation of Phase 2 and Phase
3 of a regulation requiring biodegradable plastic products (M.A-156-16-03-03). Originally issued
at the end of 2016, the regulation applies to all disposable products produced from polypropylene
and polyethylene plastics. It mandated that all plastic packaging, packing, and wrapping
materials be OXO degradable (excluding food contact packaging), and requires the
preregistration of plastic products with SASO, the application of SASO’s logo, and the use of
plastic additives licensed by SASO. For more information SASO’s technical regulation for
biodegradable plastic products visit www.saso.gov.sa or write [email protected]
Saudi Arabia has also implemented the following regulations and standards regarding food
packaging and container requirements:
GSO 839:1997 (Food Packages Part 1-General Requirements) is concerned with the general
requirements of food packaging. The main requirements are listed below:
All packaging materials used in fabricating, forming, or treating packages shall be of
food grade for contact with foods and in compliance with relevant Saudi standards.
They shall be clean and in a condition that does not allow any contamination of the
contained material.
They shall maintain the properties of the packaged material and protect it from gaining
undesirable odors, flavors, and tastes.
They shall offer protection to the product against contamination with microorganisms,
insect, rodents, and dirt in the case the products require it.
They shall be impermeable to moisture in the case of food products.
They shall offer necessary protection against environmental conditions and mechanical
hazards such as impacts, vibration, static stresses, and they shall remain intact during
handling.
They shall not affect the container because of migration of some of their constituents that
may react or be mixed with the food materials.
It shall not be in a pharmaceutical shape.
GSO 1863:2013 (Food Packages Part 2 - Plastic Package) deals with the requirements and
specifications for plastic packages used for packaging food materials. Per the standard, the
following labeling information should be written on labels of plastic packages used to package
foods:
Type of plastic material
Weight, capacity, number, or dimensions based on the type of packages
Statement of food grade
Purpose and type of application
Directions for usage
Warnings if applicable
Saudi Standard number SASO 2173/2003 (Food Packages Made of Aluminum Foil) deals with
the general requirements for food packages made of aluminum foil. Below are the main
requirements specified in SASO 2173:
Purity of aluminum metal shall not be less than 99% aluminum.
Each package shall be made of one piece of aluminum foil without any connection and
free from holes and scratches.
Shall be made from foil with regular thickness not exceeding 200 micrometers according
to the agreement between the user and manufacturer of these packages regarding the
strength with relation to the nature of application.
In case of aluminum foil coated with protection layer, the coating material shall not
transfer any health hazard material to the food product or impart the odor or flavor of the
food material.
Shall be impermeable to the water, odors, and gases.
Shall be impermeable to the light to protect fatty foods from light.
Shall provide enough protection to the food product from losing or gaining heat.
SECTION IV. FOOD ADDITIVE REGULATIONS
On February 28, 2021, SFDA issued an updated version of SFDA.FD 2500 “Additives Permitted
for Use in Food Stuffs.” SFDA.FD 2500/2021 a 373 - page comprehensive technical regulation
has a list of allowed additives, including allowed food coloring matters (SFDA regulations
store). This regulation which delisted some artificial food coloring such as Tartrazine or E102
replaces and supersedes SFDA.FD/GSO 2500/2019. The delisting of E102 has caused rejections
of some U.S. food products at the Saudi ports of entry. U.S. exporters may purchase the
regulation from the SFDA online store to refer to allowed artificial colors and in which products
they are allowed. SFDA is open to adding other food additives to this regulation under one of the
following conditions:
1. Food additives that have been allotted an Acceptable Daily Intake (ADI) or calculated on
the basis of other criteria, to be safe for human consumption by the Joint FAO/WHO
Expert Committee on Food Additives (JECFA)
2. The additives should have a Codex designated International Numbering System (INS)
number.
If a food product contains additives that are not listed on SFDA.FD 2500/2021 but meet one of
the above-mentioned conditions, the food product supplier should contact SFDA through his/her
prospective Saudi importer. The supplier will need to provide information on the new food
additives and ask if it is included in the allowable additives list. If an additive does not meet
JECFA or INS conditions, the food product will not be cleared by Customs, and it will need to be
re-exported to the country of origin or destroyed locally at the importer’s expense.
Saudi Arabia and other members of the GSO have developed positive pesticide and other
contaminants lists. Per SFDA, the lists were mainly adapted from Codex standards. The
following are the major GSO standards enforced in the Kingdom:
• Gulf Standard No. GSO 2481:2015 regulates the MRLs of veterinary drugs in food.
• Gulf Standard No. GSO 2532:2016 regulates the maximum limits of pesticides residues
and contaminants in organic food.
• Gulf Standard No. GSO 1016:2015 regulates microbiological criteria for foodstuffs.
• Gulf Standard No. GSO 1995:2015 regulates sweeteners permitted in food.
• Gulf Standard No. GSO 988:1998 is concerned with limits of radioactivity levels (gamma
rays, cesium 134, 137) permitted in foodstuffs, drinking water and animal feeding stuffs.
• Gulf Standard No. GSO 2512:2016 is concerned with dairy products with added
probiotics.
SFDA regularly updates its MRLs generally referencing levels set by the Codex Alimentarius.
Any interested stakeholders can suggest or provide comments on existing or new MRLs limits.
To request an additional MRL which has not been established by Codex, the application must be
supported by international or national regulations or based on risk assessments. All these
document can be submitted for evaluation at SFDA to [email protected] if it is coming from
governmental sector, or to [email protected] if it is coming from the companies and private
sector.
GSO 193:2021 is a 75-page Gulf Technical Regulation dealing with contaminants and toxins in
food and feed.
This regulation which is implemented in the six GCC countries and Yemen contains maximum
levels of contaminants and toxicants in food (including tree nuts) and feed. The regulation
contains only maximum levels of contaminants and natural toxicants in feed in cases where the
contaminant in feed can be transferred to food of animal origin and can be relevant for public
health.
GSO 193:2021 is a comprehensive regulation that supersedes the following GSO technical
regulations:
GSO 1807:2007 “Maximum level for cadmium in food”.
GSO 988:1998 “Limits of radioactivity levels permitted in foodstuffs - Part 1”.
GSO 2042:2010 “Maximum levels of Melamine in Foods and Feeds”.
GSO 841:1997 “Maximum limits of mycotoxins permitted in foods and animal feeds
- Aflatoxins”.
Registration of imported food products is the responsibility of local importers or agents. Each
importer or agent is required to open an E-Account and set up an individual user name and
password at SFDA’s Operations Sector E-Services at E-Account. Once the E-Account is created,
importers can upload information about their products, including the harmonized code (HS
Code), bar code, item code, listed ingredients in English and Arabic, a picture of each product,
and a copy of the product label. The label must contain all information required by the Gulf
Standard Organization regulation number GSO 9:2013 “Labeling of Prepackaged Food Stuffs”.
The importer is also required to register the address of their warehouses, the names of their staff
members authorized to deal with SFDA, including customs brokers contracted in each Saudi port
of entry. Individual importers are required to register all food products they intend to import,
even if some or all the products they intend to import have been already registered by another
importer. The electronic registration is free of charge and there is no expiration date for
registration. However, importers are required to re-register their products when there are changes
in the product formulations or labels. The registration process seems simple and can quickly be
completed if the necessary information is readily available and required documents are uploaded.
It is important to note that SFDA does not allow the importation of food products that are not
registered in its E-Account database.
SFDA maintains a mandatory electronic customs clearance system (E-Clearance) for all food and
processed feed products imported into the Kingdom. The mandatory E-Clearance covers all food
imports, including packaged products and raw materials for the food processing industry and
processed animal feed. SFDA does not process any requests for customs clearance of imported
food and processed feed products unless it is submitted through the E-Clearance system. To
qualify for E-Clearance, all food and feed product importers, as well as their custom brokers,
should create individual E-Accounts with SFDA and complete the online registration process for
all imported food and feed products.
SFDA’s Operations Sector uses an electronic Animal Feed National Registry (AFNR) system for
registering and licensing domestic feed importers and producers. Each domestic feed importer
and producer must open individual E-Account with AFNR and register all imported feed
materials including raw feed, compound feeds and non-medicated feed additives in order to
obtain an import license and customs clearance of the products electronically upon arrival at
Saudi ports of entry. SFDA allows foreign feed producers to voluntarily register the facilities and
feed products they intend to export to Saudi Arabia in AFNR.
Herbal preparations, health and supplementary foods must be registered with the General
Directorate of Medical and Pharmaceutical Licenses of the Ministry of Health (MOH) in order to
be marketed in the Kingdom. Registration is done through a local agent by submitting sample
products and product brochures, which are studied and tested by the ministry’s central
laboratory. It takes approximately six months for the ministry to approve and license a product.
The ministry charges a onetime fee of approximately $300 (USD) as a registration fee.
Exporters need to submit the following documents through their local agent to the MOH in order
to initiate the product registration and licensing process:
1. Table of contents
2. An authenticated copy of the agency registration certificate at the Saudi Ministry
of Commerce and Investment.
3. When registering for herbal products, a copy of a pharmaceutical wholesale
license should be submitted by the local agent.
4. Certificate(s) issued by the health authorities in the country of origin clearly
stating that:
The company is licensed to manufacture the products in the country of origin
(state license number and date).
The company is permitted to sell the product in the country of origin
(certificate of free sale).
The company follows good manufacturing practice.
Coloring agents, diluents and other substances in the product formula are
permitted in the country of origin (if the free sale certificate states such
information, it will be sufficient).
Package inserts and applicable information stated on the package must be the
same as that approved and currently marketed in the country of origin. The
package insert must be in Arabic and English languages. The company is
obliged to add and/or delete any information required for handling the product
in the Kingdom as determined by the registration committee.
5. A certificate issued by the company and authenticated by the relevant authorities
in the country of origin must clearly state the following information:
Registration number and date of marketing in the country of origin.
Trade and/or generic name.
Full composition (the scientific name of active and inactive ingredients and
their quantities) therapeutic category (if any). The composition of the product
to be exported to the kingdom is the same as that marketed in the country of
origin.
Names of countries where the product is currently marketed.
A certificate of analysis indicating the results of completed analyses for the
submitted samples.
If the product contains ingredients of animal source, the kind of animal must
be specified.
Percentage of alcohol in the finished product, if present, should be indicated
with justification of that percentage.
Full specifications and methods of analyses of the finished product, as well as
stability study and data including storage conditions.
Six samples of the product as well as samples of the outer package and
product’s label.
Abstracts of scientific references, brochures, and international scientific
periodicals testifying to the efficacy and safety of the product.
SFDA has recently issued three important documents that governs the importation of food
products to Saudi Arabia including requirements for prior approval of foreign food control
agencies of countries that wish to export food products to the Kingdom in addition to the
requirements for official registration of foreign establishments that intend to export food
products to Saudi Arabia. The documents are discussed below:
Interested in Exporting Food Products of Animal Origin to the Kingdom of Saudi Arabia (KSA).
SFDA defines competent authority/authorities as body/bodies responsible for the official food
control in the exporting countries. The document that was notified to WTO on October 1, 2014,
as G/SPS/N/SAU/93/Add.3, specifies the procedures that should be followed by competent
control authorities responsible for food safety in supplying countries of food products of animal
origin to KSA need to be recognized by SFDA and it assigns the responsibilities of approving
establishments interested in exporting the following nine product categories to the Kingdom:
Establishments for the export of beef and beef products.
Establishments for the export of sheep and sheep products.
Establishments for the export of poultry and poultry products.
Establishments exporting fishery products and other seafood products of animal
origin.
Establishments for the export of honey and its products.
Establishments for the export of milk and its products.
Establishments for the export of breast milk substitutes.
Establishments for the export of table eggs and its products
Establishments exporting any other products of animal origin
The process of approving the foreign competent authority starts when a foreign competent
authority sends an official request to SFDA through a diplomatic channel. If SFDA accepts the
request, it sends a Country Food Safety Evaluation Form (Annex 1) of the Process of Approving
Foreign Competent Authority. SFDA evaluates the responses to the questionnaire and provides
feedback if needed as well as may request from the competent authority to coordinate SFDA
technical visit if required to evaluate the country’s Food Safety system. The team will visit the
control body and some establishments of food products of animal origin to ascertain that the
competent authority in visited country indeed conducts supervision of the facilities per pertinent
SFDA/GSO technical regulations and according to health requirements approved in Saudi
Arabia. The technical visit will include targeted products facilities such reference labs,
quarantine facilities, animal farms and other control bodies.
SFDA implemented the above requirements on livestock and poultry meat and products
exporting countries in 2015 while the requirements were enforced on seafood and egg/egg
products at the end of 2018 following the enforcement of the Conditions and Requirements for
Importing Food to the Kingdom of Saudi Arabia discussed below.
2. Conditions and Requirements for Importing Food to the Kingdom of Saudi Arabia
In addition to complementing the requirements discussed in document number one above, this
document lists in the Appendix a new model of SFDA Health Certificates for the following nine
product categories and specifies the required certifications by competent authorities of the
exporting countries:
1. Health Certificate for Export of Red Meat and Meat Products to KSA
2. Health Certificate for Export of Poultry Meat and Poultry Meat Products
to KSA
3. Health Certificate for Export of Products of Aquatic Animal Origin to the
Kingdom of Saudi Arabia
4. Health Certificate for Export of Honey & Bee Products to Kingdom of
Saudi Arabia
5. Health Certificate for Export of Processed Fruit and Vegetables Products
to KSA
6. Health Certificate for Export of Table Eggs and Egg Products to KSA
7. Health Certificate for Export of Milk, and Milk Products to KSA
8. Phytosanitary Certificate for Export to KSA
9. Health Certificate for Export of Assorted Food Products to KSA
SFDA implemented a draft of this measure to verify the procedures carried out by the competent
authorities responsible for the whole food chain within the exporting countries that are interested
in exporting their products to the Kingdom of Saudi Araba. These procedures are conducted to
assign the authorities the responsibility of approving the establishments interested in exporting
the following products:
Establishments exporting beef and beef products.
Establishments exporting sheep and sheep products.
Establishments exporting poultry and poultry products.
Establishments exporting fishery/other seafood products of animal origin.
Establishments exporting honey and its products.
Establishments exporting milk and its products.
Establishments exporting breast milk substitutes.
Establishments exporting table eggs and its products
Establishments exporting processed vegetables and fruit
Establishments exporting grain and agricultural crops
This document reiterated the need for the competent authority to get approved by SFDA by
fulfilling the conditions discussed above in Process for Approving Foreign Competent Control
Authorities and the role that the approved competent plays in facilitating trade between the
exporting country and Saudi Arabia. A few new things included in the document are the addition
of processed vegetables & fruits, grain and agricultural crops and the fee that SFDA charges as
the cost of its technical team’s visit to exporting countries (if the visit is required) to audit an
exporting country’s food safety system and inspection of exporting facilities. Inspection fees
range between $4,667 for Arab countries and $8,800 for North American countries.
As discussed earlier the overall contents and requirements of G/SPS/N/SAU/451 are not new and
have been implemented on poultry/livestock meat products as well as on fish/seafoods over the
past few years and enforced on honey and bee products at the end of October 2021. SFDA has
not indicated when it will implement the requirements on dairy and other products.
The Food and Drug Administration (FDA) is the competent authority that regulates all foods
and food ingredients produced and sold in the United States with the exception of meat, poultry,
grains, fresh fruit and vegetables, and fresh eggs that are regulated by the USDA while live fish
and other aquatic animals are regulated by The National Oceanic and Atmospheric
Administration (NOAA) of the United States Department of Commerce. To address the recent
SFDA requirements for seafood and honey and bee products registration requirements, FDA has
launched an Update to its Export Listing Module (ELM) to Facilitate U.S. Exports of the
aforementioned products to Saudi Arabia. Below is the announcement:
The Saudi Food and Drug Authority (SFDA) has implemented new import requirements
for certain food products of animal origin exported to Saudi Arabia. Effective
immediately, establishments that export seafood and bee and honey products must appear
on SFDA’s lists of approved establishments eligible to export such products. SFDA will
include foreign establishments on these lists that have been certified to comply with
applicable food safety requirements by the competent authority of the exporting country.
FDA is the U.S. competent authority for food safety for seafood and honey and bee
products. To facilitate U.S. exports of these products, FDA has updated the Export
Listing Module (ELM) to allow U.S. establishments to request FDA certification for
inclusion on SFDA’s lists of approved establishments. U.S. establishments are eligible for
the lists if they are in substantial compliance with applicable FDA requirements for the
products intended for export. For ease of reference, FDA refers to the Saudi Arabia lists
for these products as the Saudi Arabia honey and bee products export list and the Saudi
Arabia seafood export list.
U.S establishments that wish to export seafood or honey and bee products to Saudi
Arabia may apply for the initial updates to these lists now through December 10, 2021.
FDA expects to send the first version of these lists to SFDA in mid-December 2021.
Going forward, FDA will send updates to these lists on a quarterly basis as described on
the Food Export Lists webpage.
For more details including step-by-step instructions on how to apply in the ELM, visit
Online Applications for Export Lists. Please contact the Export Certification Team at
[email protected] for any additional questions about the ELM.
SECTION VII. OTHER SPECIFIC STANDARDS
1) Vitamin-Enrichment Requirements
SFDA implements GSO 2539:2017 which has the following general requirements.
o Vitamins and minerals may be added to food products in a form that is bio-
available to the human body.
o Vitamins and minerals may not be added to foodstuffs unless these vitamins
and minerals are added to the product specification
o Vitamins and minerals may not be added to unprocessed foodstuffs, including
fruit, vegetables, meat, poultry, and fish
SFDA.FD/GSO 2392:2014: Food for special dietary uses - Low sodium iodized. This standard
applies to refined iodized soft edible salt prepared for human consumption.
3) Advisory Lists of Nutrient Compounds for Use in Foods for Special Dietary Uses
4) General Requirements for Prepackaged Foods for Special Dietary Use (GSO
654:2021)
This technical regulation applies to all prepackaged foods used for special dietary uses, which
includes but not limited to foods for special medical purposes, foods for use in weight control
diets, gluten-free foods, food supplements, infants and young children’s foods, infant formula,
follow on formula and formulas for special medical purposes.
GSO 2055-1/2015 defines Halal food as food and drinks, which are allowed to be consumed
according to Islamic rules by eating, drinking, injection, or inhaling, and that should comply with
requirements mentioned in the regulation.
Halal Slaughter Certificates: Poultry and livestock slaughtering must take place in an
officially licensed slaughterhouse and in accordance with Islamic slaughtering
procedures prescribed in GSO number 993:2015 “Animal Slaughtering Requirements
According to Islamic Law”. Exports of whole meat and parts must be accompanied by
halal slaughter certificates attesting that the livestock/poultry slaughtered for export to
Saudi Arabia are slaughtered according to the requirements of GSO 993:2015.
Halal Certificates: Food products containing meat ingredients exported to Saudi Arabia
must be accompanied by halal certificates issued by halal certification bodies accredited
by SFDA.
At the end of 2020, SFDA began requiring that halal certificates accompanying poultry and
livestock meat as well as their products/ingredients exported to Saudi Arabia must be issued
exclusively by Halal Certification Bodies (HCB) accredited by the SFDA Halal Center (HC).
Thus far, the HC has accredited and registered three U.S. HCBs: (1) ISWA Halal Certification
Department, (2) Halal Transactions, Inc. and (3) Islamic Food and Nutrition Council of America.
A new U.S. company interested in getting approved as HCB should contact the SFDA Halal
Center at this link to obtain information about registration requirements.
SFDA has issued a 44 page Food Hygiene and Requirements and SFDA summarizes the main
objective of the guidelines as achieving a high level of protection for human health and lay down
general and specific rules and responsibilities of food business operators on the hygiene of
foodstuffs and requirements for food premises and establishments. The guidelines make food
business operators responsible primarily for food safety, emphasizes the need to ensure food
safety throughout the food chain starting with primary production, requests general
implementation of procedures based on the HACCP principles. The guidelines equally apply to
all Saudi based food premises and foreign facilities wishing to export food products to the
Kingdom.
SFDA implements GSO CODEX STAN 174:2021 Vegetable Protein Products. The requirement
applies to vegetable protein products (VPP) intended for use in foods prepared proteins by
various separation and extraction processes from vegetable sources other than single cell protein.
The VPP are aimed for use in foods requiring further preparation and used by the food
processing industry.
The regulation deals with soy protein products (SPP) prepared from seeds of soybeans (Glycine
Max. L.) by various separation and extraction processes which are intended for use in foods
requiring further preparation and in food processing industry.
The following conditions and requirements apply to all consignments of food where the
descriptive information on the label, or in the accompanying advertisement materials and
commercial documents, indicate the use of organic production methods. The term " organic",
"biological", "biodynamic", "ecology" or any other words with similar meanings, including
phrases which suggest to the consumer that the product, or any ingredients thereof, has been
produced by means of organic production methods. These conditions and requirements cover the
following products:
SFDA.FD/GSO 2374:2014 provides guidelines for the production, processing, labeling, and
marketing of organically produced foods. Saudi Arabia requires that food products labeled as
organic and exported to the Kingdom must be produced according to the requirements and
standards of competent authority of the exporting country and the imported products must be
accompanied by official certificate issued by the competent authority that ascertain the organic
production claim. SFDA accepts the USDA organic logo if the claim is substantiated by an
official certificate issued by a USDA’s competent authority. Other pertinent regulations for
organic foods are SFDA.FD/GSO 2532:2016 " Maximum Limits of Pesticides Residues and
contaminants in Organic Food". The regulation provides maximum residue limits of pesticides
and contaminants allowed in organic food. SFDA.FD/GSO 2511 deals with prepackaged organic
dates.
In addition to the above regulations, importers of organic products must comply with MEWA
Organic Agricultural Law and SFDA’s requirements for Releasing Organic Food Products
discussed below:
a) MEWA is the competent authority in the Kingdom to legislate organic agriculture law
and its executive regulations.
b) MEWA’s Executive Regulations for Organic Agriculture (in Arabic) states that any party
or individual wishing to engage in any activity (farming, manufacturing, importing, and
exporting, etc.) with organic food, must obtain a certificate of authentication from
licensing organic certification bodies (OCB) . That certificate confirms and documents
the organic activity.
c) MEWA is the responsible authority for licensing OCBs to conduct inspection and
documentation services in the Kingdom. Any party or individual interested in engaging in
organic food production or trade must obtain a license from an accredited OCB. MEWA
has licensed five OCBs: 1) BCS, Germany, 2) CERES, Germany, 3) TAWTHIQ, Saudi,
4), OneCert, USA, and CCPB, Italy. Currently, SFDA accepts organic certificates issued
by USDA’s National Organic Program (NOP).
d) The organic authentication certificate and the transaction certificate issued by the OCBs
are required to release organic food products imported to Saudi Arabia. In addition, all
organic products imported to the Kingdom are subject to inspection, documentation and
tracking by one of the OCBs.
e) The release of imported organic food products is linked to local importer's commitment
to the SFDA conditions of importing and releasing organic food products (in Arabic).
SFDA notified the requirements to the WTO TBT Committee on January 7, 2020, as
G/TBT/N/SAU/1118, “Clearance Conditions for Organic Food Products.” The comment
period ended on March 6, 2020, and the regulation was enforced early in 2021.
f) The authentication authorities in the country of origin that grant transaction certificates
are either the official supervisory authority in the country of origin or could be companies
licensed by that official authority. The role of MEWA licensed OCBs is to verify the
credibility of the issuing authorities and the food production and certification process.
g) MEWA is a member of the International Federation of Organic Agriculture Movements
(IFOAM - Organics International), and the certificates issued by MEWA and the national
certification bodies for exports of Saudi produced organic products are internationally
recognized.
Prior to the importation of novel food items to Saudi Arabia, the following documents must be
presented:
Reliable scientific evidence authenticated by recognized official bodies to confirm
the safety of the food for human consumption including Acceptable Daily Intake
(ADI), possible warnings in case of intake by a high-risk population and warnings if a
food ingredient has exceeded its Recommended Daily Allowance (RDA).
Ingredient analysis results from accredited labs confirming that the product is fit
for human consumption and free from any health hazards.
A Certificate of Free Sale attesting that the product with its components and
ingredients is freely sold in one of the countries which apply Codex standards or EU
legislations.
A pledge of full responsibility towards the product after its entry to the market
and commitment to follow any relevant circulars, standards, or regulations that SFDA
officially publishes in the future.
The GSO standards that establish quality specification for baby foods are GSO 355:2011 and
GSO 354:1994.
GSO 355:2011 (Canned Baby Foods) provides specifications for baby foods that are
intended primarily for use during an infant's normal weaning period (from 6 months)
and for the progressive adaptation of infants and children to ordinary food. They may
be either in ready-to-eat form or in dry form requiring reconstitution with water only.
GSO 354:1994 (Infant Foods Based on Milk) is concerned with infant foods based on
milk in liquid or powdered form intended for use as substitutes for human milk.
In addition to the general requirements specified in established GSO standards, Breast Milk
Substitutes (BMS) or infant formulas must meet the following specifications:
• Age group: from birth until three years of age
• The percentage of milk protein: (11%)
• Percentage of milk fat: (8%)
• No flavor, only plain
Saudi Arabia has periodically banned cattle, meat, and meat products imports for health reasons.
Cattle imports from countries affected by Mad Cow disease, or Bovine Spongiform
Encephalopathy (BSE), Foot and Mouth (FMD), and Cattle Plague diseases are banned until the
affected countries are declared free of the diseases by OIE. Cattle imports from countries not
affected by these diseases are subject to strict quarantine regulations on arrival at Saudi ports of
entry. Saudi Arabia also bans meat and meat derivatives from countries affected by BSE and
other cattle diseases. It also bans transshipment of livestock meat through countries banned from
exporting meat and meat products because of BSE, FMD and other animal diseases.
In addition, Saudi Arabia requests additional statements on the health certificate accompanying
livestock and poultry meat shipments indicate that the animals slaughtered for export to the
Kingdom were not fed animal protein. Imports of live poultry, poultry meat and hatching eggs
are banned from countries affected by avian influenza. Imports of live poultry are also banned
from countries with the West Nile Virus epidemic.
For all requirements related to U.S. meat and poultry exports to Saudi Arabia, the FSIS Export
Library is regularly updated (link here).
Royal Decree No. M/5 and Resolution of Council of Ministers No. 75 dated 1984 regulate
trademark registration laws in the Kingdom. According to the decree, trademarks are registered
with the Trademark Registration Department of the Saudi Ministry of Commerce and Investment
(MOCI) through a local agent or lawyer. Once the registration application is received, the
Trademark Registration Department will require one month to study the presented documents to
decide on the request.
If an application is approved, the department will publish the trademark in the official
government Arabic language newspaper (Uma Al-Qura) with the cost of publication paid by the
agent or owner of the trademark. The total registration cost is estimated at approximately $2,000.
Registered trademarks are protected for 10 years and can be renewed for another similar period
or periods without any new inspection after republishing it in the official paper.
SECTION IX. IMPORT PROCEDURES
Commercial Registration
Rejected Released
Rejected
Released
Below are the SFDA’s procedures for importing food products into Saudi Arabia:
• Importers must have a Commercial Register, which includes imports and
distribution of food products.
• Importers should have already created an E-Account with the SFDA and registered
all their imported food products.
• The following required documents must be submitted to the SFDA to commence
the required product inspections process:
Original invoice certified by a chamber of commerce where the
exporting company is located.
Some of the following certificates (depending on the food item) shall
be made available:
• Certificate of origin (Copy)
• Halal Certificate (original)
• Certificate of slaughtering for meat and poultry (original)
• Any other documents or certificates required by the SFDA
• In addition to the general requirements listed above, there may be
special requirements specified by SFDA according to the nature
of imported food products.
Except for herbal preparations, health, and supplementary foods (inspected by the Ministry of
Health) and live animals, plants, seeds, and grains (inspected by MEWA), all imported
foodstuffs, including processed seafood, fruits, and vegetables as well as processed animal feed
are inspected by the SFDA’s Operations Sector inspectors at Saudi ports of entry or Border
Inspection Posts (BIPs).
Imported foods are inspected independently by SFDA Operation Sector inspectors at one of
Saudi Arabia’s BIPs without any interference from the SFDA headquarters in Riyadh.
Laboratory officials pull random samples from full consignments and testing is typically very
quick. If an imported consignment is in compliance with pertinent GSO or Saudi regulations and
standards, it is cleared. Otherwise, it is rejected.
The domestic importer has no access to SFDA’s internal reports during the process. The SFDA
informs the importer of its final decision whether to clear the product for sale in Saudi Arabia or
reject it due to lack of compliance with established regulations and standards. Rejected products
have to be re-exported or destroyed domestically under SFDA’s supervision. Importers may
appeal the decision to reject a shipment in certain circumstances (see below).
Operations Sector inspectors (Operations inspectors) perform the following mandatory four-
stage verification process when food consignments arrive at BIPs:
Documentation Check: All certificates and documents accompanying a
consignment are checked and presence of all required documentation is
verified.
Identity Check: The identities of all food items imported in the consignment
are verified against information in accompanying documents.
Physical Examination: All food items contained in the consignment are
physically verified to ascertain conformity with the technical regulations and
standards, and that the labeling requirements are met as specified by the
pertinent technical regulations and standards. The inner temperature level of
the container is checked to ensure it meets the established pertinent
regulations and standards.
Laboratory Test: If the food inspector has reasons to believe that a
laboratory test is needed to take a final decision about the food consignment,
he may take random sample and send it for analysis at an authorized
laboratory. SFDA does not always include all test details in the test results.
FAS/Riyadh has seen several instances where the compound found and/or
level was not included.
If the imported food product meets the regulations and standards, it is released by operations
inspectors on the same day and referred to Customs for final clearance. Failure to comply with
regulations at any of the above stages may result in a rejection of the imported food product and
prevent its entry to the Kingdom. Containers can be cleared in less than five working days
provided all required documents are in order and imported products meet Saudi Arabian/Gulf
specifications.
If a product is rejected by one of BIPs inspectors for alleged lack of adherence to established
specifications at any of the above four stages, the local importer has the right to appeal the
decision in writing to operations inspectors at the SFDA headquarters and ask for reconsideration
of the inspection results. In such cases, operations will forward the appeal to a special committee
that studies shipment documentation and the BIP’s test results to verify compliance with
established rules and regulations. If the BIP action was found to be compliant with the rules and
regulations pertaining to the rejected product, then the BIP findings and decision is final. If, for
any reason, there was a misjudgment by the BIP inspectors, the operations sector must repeal the
decision and inform the importer to clear the consignment from Customs.
B. Customs Clearance
The SFDA allows imports of food products purchased via the internet for personal or
commercial purposes without going through the required online pre-registration and import
authorization requirements. However, the imported food products will be subject to inspection at
the port of entry to ensure that they comply with SFDA’s regulations and requirements to
ascertain they are fit for human consumption.
Samples destined to potential Saudi buyers or for display in Food Shows are exempt from Saudi
labeling and shelf-life regulations but are subject to inspection at ports of entry. A commercial
invoice specifying that the product is not for sale and has no commercial value must accompany
samples, which are usually sent to Saudi Arabia by D.H.L. and similar carriers.
E. Foodstuff Monitoring
The Environmental Protection Department at the Ministry of Municipality and Rural Affairs is
responsible for establishing nationwide food sanitation laws and guidelines. Inspectors at the
municipal levels monitor products already in the market. The authorities inspect retailers,
wholesalers, restaurants, bakeries, fast food chains, vegetable and meat markets for expiration
dates, sanitary and storage conditions as well as product handling. Outlets found selling
unhygienic or expired products are exposed to stiff financial fines, temporary closure, or both.
Most Saudi food imports enter the country via the Jeddah port on the Red Sea or Dammam port
on the Arabian Gulf. Approximately 70 percent of all food enters through the Jeddah port.
Imports from Jordan, Syria, and other nearby countries generally enter the Kingdom by truck.
King Khalid International Airport in Riyadh and King Abdulaziz International Airport in Jeddah
also receives significant quantities of food items, particularly fresh fruits, vegetables, and chilled
meat. Fresh and chilled products are usually cleared within 24 hours of arrival.
Saudi Arabia does not have a pre-clearance import program. Instead, SFDA randomly samples
imported products from trusted supplying countries, such as the United States. As such, most
imported U.S. food products clear Saudi customs after arriving at ports of entry, without lab
testing, in approximately four days. However, if a consignment requires a lab test, results may
take up to 15 days, and the importer is responsible for the fee (approximately $1,333 per tested
product). The importer is also responsible for demurrage fees, depending on the location of the
customs site. Daily demurrage, or storage, fees for dried and frozen products are $220 and $265,
respectively.
If a product is rejected entry by SFDA for violating import regulations, the importer must re-
export the product to the country-of-origin or destroy it locally under SFDA’s supervision. If a
product is destroyed locally, the importer must also pay the demurrage fee (a fine of $4,000 for
violating import regulations) and at least $4,533 (charged by a private company) to destroy the
product.
The SFDA sets food and feed products standards. Contact information for the SFDA, and other
ministries involved in food and agricultural products safety and inspection, is as follows.
Dr. Sami Al-Sager
Vice President for Operations
Saudi Food & Drug Authority (Inspects imported food and processed feed products)
Tel: 966-11-203-8222 Ext: 5800 Fax: 966-11-275-7238
www.sfda.gov.sa
Saudi Arabia does not have any relevant import specialists that are not affiliated with the
government.
Attachments:
No Attachments