Thailand has notified the WTO of a draft Ministry of Public Health Notification updating the national rules for enzymes used in food production. The measure is issued under the Food Act B.E. 2522 and would amend the existing framework under Ministry of Public Health Notification No. 443 B.E. 2566 on enzymes used in food production.

The notified product scope is enzymes used in food production, including food enzyme preparations under HS 3507. The responsible agency is the Thai Food and Drug Administration.

What the Draft Notification Would Introduce

The draft would repeal and replace Schedule 1 of the existing enzyme notification with an updated list of enzymes permitted for use in food production. The Thai draft states that the revised Schedule 1 will replace the existing list attached to Notification No. 443 B.E. 2566.

The WTO notifications explain that the objective is to update the list of enzymes that have passed safety assessment by the Thai FDA and JECFA.

The revised enzyme list covers a broad range of food-processing enzymes, including:

• glucose oxidase and catalase;
• hexose oxidase, laccase and L-ascorbate oxidase;
• transglutaminase;
• inulosucrase and glucan-transfer enzymes;
• lipase and phospholipases;
• pectinase, tannase and phytase;
• alpha-amylase, beta-amylase, glucoamylase and other carbohydrases;
• cellulase, beta-glucanase, xylanase and related hemicellulases;
• lactase, invertase, pullulanase and isoamylase;
• proteases, including subtilisin, papain, bromelain, pepsin, chymosin and collagenase;
• asparaginase, glutaminase, AMP deaminase, acetolactate decarboxylase, D-allulose epimerase and xylose isomerase.

Most entries are linked to the enzyme’s EC number, accepted name, source organism, condition of use and permitted use level, which is generally stated as an appropriate amount.

Silicon Dioxide Added for Enzyme Preparations

The draft also adds Silicon dioxide, amorphous / Silica (INS 551) to the list of permitted food additives for enzyme preparations under Schedule 4. The Thai draft specifies a maximum level of 50,000 mg/kg for dry powder enzyme preparations, with residues in beverages and other foods allowed at appropriate levels.

This is relevant for enzyme preparation formulators because silicon dioxide is commonly used as an anticaking agent or processing aid in powder preparations.

Adoption, Entry into Force and Comments

The proposed date of adoption and publication is still to be determined. The TBT notification states that the regulation would enter into force on the day following publication in the Government Gazette.

The SPS notification also refers to entry into force timing linked to publication and indicates a possible six-month timing from publication, so companies should monitor the final gazetted version for the confirmed implementation date.

The comment deadline is listed as 25 August 2026 under the TBT notification and 28 August 2026 under the SPS notification.

Industry Impact

The measure is relevant for enzyme manufacturers, food ingredient suppliers, food manufacturers, importers, distributors and companies using enzymes in bakery, dairy, beverage, starch processing, oil and fat processing, meat, seafood, plant-based foods, brewing, protein hydrolysates and specialty food production.

Businesses should review whether their enzyme preparations are covered by the revised list and confirm:

• enzyme name and EC number;
• source organism and any genetically modified production strain;
• permitted condition of use;
• applicable food categories;
• intended technical function;
• safety assessment documentation;
• compliance with JECFA/Thai FDA expectations;
• carrier/additive composition, especially where silicon dioxide is used;
• import classification under HS 3507.

Outlook for Industry

If adopted, the draft would modernize Thailand’s permitted enzyme list and provide clearer regulatory coverage for a wider range of enzyme preparations used in food production. The addition of silicon dioxide also gives manufacturers clearer flexibility for dry powder enzyme formulations.

Companies placing enzyme preparations on the Thai market should begin mapping products against the revised enzyme list, checking source-organism details and preparing safety, specification and formulation records before the final regulation is published.