Decree of the Minister of Health Number HK.01.07/MENKES/301/2026 Requires the Inclusion of “Nutri Level” Labels on Ready-to-Drink Beverages

Introduction

On April 14, 2026, the Ministry of Health (“MOH”) issued Decree of the Minister of Health Number HK.01.07/MENKES/301/2026 on the Inclusion of Nutritional Labels and Health Messages on ready-to-drink beverages (“MOH Decree 301/2026”). MOH Decree 301/2026 considers that excessive consumption of sugar, salt, and fat can increase the risk of non-communicable diseases, including obesity, hypertension, cardiovascular disease, stroke, and type 2 diabetes; therefore, MOH Decree 301/2026 governs the inclusion of the visual “Nutri Level” label on ready-to-drink beverages to convey information on sugar, salt, and fat content, allowing the public to easily understand and compare products according to their needs.

Key Provisions

Legal Subjects and Implementation Objects

The FIRST Dictum and SECOND Dictum provide that businesses producing and/or distributing ready-to-drink beverages must include nutritional labels and health messages, with initial implementation for large-scale businesses in accordance with statutory provisions. In its implementation, the SEVENTH Dictum governs that the Central Government and Regional Governments conduct advocacy for businesses to encourage compliance. Furthermore, the NINTH Dictum governs that the Central Government and Regional Governments conduct guidance and supervision over the implementation of these provisions in accordance with their respective duties, functions, and authorities.

Information Media for Nutri Level Inclusion

The THIRD Dictum and FOURTH Dictum govern that nutritional labels in the form of “Nutri Level” indicators are included on information media. Businesses may include the label on menu lists, retail packaging, brochures, banners, flyers, menu lists on commercial electronic applications, leaflets, and/or other information media.

Self-Declaration Mechanism and Nutri Level Classification

The inclusion of Nutri Level is based on the businesses’ self-declaration regarding the sugar, salt, and fat content based on test results from government laboratories or other accredited laboratories, as governed in the FIFTH Dictum. Nutri Level is divided into four tiers, namely Level A to Level D, as governed in the SIXTH Dictum and Annex Letter A. Level A reflects lower nutritional content compared to the levels above it up to Level D. In its calculation, the salt value is based on sodium content, while the fat value is based on saturated fat. The nutritional content limits per 100 mL of beverage are as follows:

Restrictions on the Use of Sweeteners

Annex Letter A number 2, number 3, and number 4 govern the use of sweetener food additives at each level. Products at Level A do not use sweetener food additives, either natural or artificial, including through direct addition and/or carry over. Products at Level B only use natural sweetener food additives. Products at Level C and Level D may use natural and/or artificial sweetener food additives.

Calculation Methods and Conversion of Nutritional Values

Sugar calculation includes all monosaccharides and disaccharides, excluding lactose. These provisions are as set out in Annex Letter A number 5, where businesses calculate the sugar value based on the Nutritional Value Information and convert it from per serving to per 100 ml as the basis for the Nutri Level inclusion. An example of the calculation is as follows:

Rounding Provisions for Nutritional Content Percentages

The inclusion of Nutri Level values is expressed as a percentage (%) calculated based on the nutritional content in grams or milligrams per 100 milliliters (g/100 ml or mg/100 ml). These provisions are governed in Annex Letter A number 8 and number 9, stipulating that the percentages of sugar, salt, and fat content included on the packaging are rounded values. For example, the rounding for sugar content percentages is as follows:

1. Level A Category: Content values of 0.0 to 0.4 g/100 ml are rounded to 0%. Values of 0.5 to 1.0 g/100 ml are rounded to 1%.

2. Level B Category: Values of 1.1 to 1.4 g/100 ml are rounded to 1%. Values of 1.5 to 2.4 g/100 ml are rounded to 2%, and values of 2.5 to 3.4 g/100 ml are rounded to 3%. Values of 3.5 to 4.4 g/100 ml are rounded to 4%, and values of 4.5 to 5.0 g/100 ml are rounded to 5%.

3. Level C Category: Values of 5.1 to 5.4 g/100 ml are rounded to 5%. Values of 5.5 to 6.4 g/100 ml are rounded to 6%, and values of 6.5 to 7.4 g/100 ml are rounded to 7%. Values of 7.5 to 8.4 g/100 ml are rounded to 8%, and values of 8.5 to 9.4 g/100 ml are rounded to 9%. Values of 9.5 to 10.0 g/100 ml are rounded to 10%.

4. Level D Category: Values of 10.1 to 10.4 g/100 ml are rounded to 10%. Values of 10.5 to 11.4 g/100 ml are rounded to 11%.

Label Inclusion Exemptions

Ready-to-drink beverages that naturally do not contain sugar, salt, and fat do not include a Nutri Level. This provision is governed in Annex Letter A number 10.

Inclusion Procedures

The procedures for Nutri Level inclusion are governed in the EIGHTH Dictum and Annex Letter B, stipulating that the Nutri Level is included in the form of letters A, B, C, and D written in full, with emphasis on the letter indicating the highest percentage of nutritional content. The inclusion must meet the following provisions:

1. clearly legible;

2. does not touch the trade name;

3. does not obscure important information on the label; and

4. accompanied by information on the percentage of the nutrient with the highest value.

Design Standards

The visual form of the Nutri Level is governed in Annex Letter B number 2 and number 3, which includes:

1. horizontal format;

2. vertical format; or

3. infographic logo simplification.

The use of fonts and colors is governed as follows:

1. the text “NUTRI LEVEL” uses Arial Black;

2. percentages use Arial Bold;

3. dark green color (100C 25M 100Y 0K) for Level A;

4. light green color (55C 0M 100Y 0) for Level B;

5. yellow color (0C 30M 90Y 0K) for Level C; and

6. red color (20C 100M 100Y 10K) for Level D.
   

Transitional Provisions

The obligation to include nutritional labels and health messages applies after two years from the determination of the maximum limits for sugar, salt, and fat content, in accordance with statutory provisions, as governed in the TENTH Dictum.

Closing

MOH Decree 301/2026 governs the inclusion of nutritional labels and health messages in the form of a “Nutri Level” on ready-to-drink beverages, initially applied to large-scale businesses. The Nutri Level is included across various information media, with classification based on businesses’ self-declaration supported by accredited laboratory test results and calculated per 100 ml nutritional content, subject to established rounding standards. The framework also regulates restrictions on sweetener food additives by level, exemptions for products that naturally contain no sugar, salt, or fat, as well as inclusion procedures and design standards covering visual formats, fonts, and colors. The obligation becomes effective two years after the determination of maximum limits for sugar, salt, and fat content. Accordingly, businesses must adjust their labeling practices, nutritional calculations, and design implementation to comply with the applicable requirements.