KEY TAKEAWAY

The Food and Drug Administration (“FDA”) has formally prohibited the use of the Ministry of Health (“MOH”) and FDA logos on prepackaged food labels.

From May 2026, products displaying these logos may be subject to enforcement action under Section 31 of the National Food Law (“NFL”), as amended in 2024, making it essential for food businesses to review existing packaging before products enter the market.

WHY THIS MATTER

Many businesses have historically included government-related logos (i.e., FDA logo and MOH logo) on food packaging to indicate product registration or regulatory approval.

The new public notice makes it clear that this practice is no longer permitted.

Businesses should therefore review both existing packaging and future label designs to ensure that government logos are removed before products are placed on the market.

THE LEGAL FRAMEWORK BEHIND THE CHANGE

The public notice does not introduce an entirely new labelling principle. Rather, it reinforces existing restrictions under the Directive for Labelling of Prepackaged Foods (Directive No. 8/2022).

Existing Labelling Requirements

Paragraph 21 of Directive No. 8/2022 already prohibits labels from displaying references to government departments or institutions, including licenses or endorsements.

The April 2026 public notice confirms that the use of MOH and FDA logos falls within this prohibition and will now be actively enforced.

Certifications Require Permission

Paragraph 22 of Directive No. 8/2022 also provides that certifications such as:

• Good Hygienic Practice (GHP);
• Good Manufacturing Practice (GMP);
• Hazard Analysis and Critical Control Point (HACCP);
• International Organization for Standardization (ISO);

must not appear on food packaging unless the relevant authority has expressly authorized their use.
The public notice serves as a reminder that businesses should carefully assess all regulatory logos and certification marks appearing on product labels.

COMPLIANCE CHECKLIST

ENFORCEMENT RISK

The FDA’s April 2026 public notice signals a shift from merely having labelling requirements in place to actively enforcing them. While the prohibition on references to government departments and endorsements has existed since the issuance of Directive No. 8/2022, businesses can no longer rely on past market practices that permitted the display of MOH, FDA, or other government-related logos on food packaging. Companies involved in the importation, manufacture, distribution, and sale of prepackaged foods should promptly review their product labels, packaging materials, and approval processes to ensure compliance before products enter the market. Taking proactive steps now will help mitigate enforcement risks, avoid potential penalties under Section 31 of the National Food Law, and ensure continued market access in Myanmar.

Disclaimer: The information provided in this newsletter is for general informational and educational purposes only and is not intended to be, nor should it be interpreted as, legal advice or a formal legal opinion. No reader should act, or refrain from acting, based on the contents of this update without first seeking professional legal counsel tailored to their specific circumstances and jurisdiction. For comprehensive legal support or specific inquiries regarding your company’s compliance, please contact our team directly at firm@iicole.com.