Cambodia’s Law on Food Safety came into force on June 8, 2022. This law has been widely regarded as a major legal development of the food safety framework in Cambodia, providing new rules, clarifying existing rules, and setting a clear framework for its implementation and enforcement. In addressing some of the key features of this new law shortly after it was passed in 2022, we remarked that we eagerly await implementing regulations. Since then, various regulations have been adopted, such as two regulations (Sub-Decree No. 13 and Prakas No. 80) on food surveillance, recalls, and seizure. These implementing rules are essential in ensuring that enforcement officers can remove noncompliant and unsafe foods from the market. Another key aspect of the Law on Food Safety is that it requires Khmer-language labeling on prepackaged food products. There has been a notable increase in the inclusion of Khmer labeling on food products in the market since June 2022, but noncompliance is still considerable, especially for imported foods. Further interesting labeling rules set by the Law on Food Safety include a requirement to provide nutrition information. This requirement has not yet been widely adopted, with many in the industry highlighting that the details of this labeling requirement are not clear. Indeed, the relevant article of the Law on Food Safety itself only sets the requirement for food products to bear nutrition labeling and does not spell out what detailed information should be provided or in what manner. However, a prakas (ministerial regulation) adopted months prior to the Law on Food Safety does set out clear guidance on nutrition labeling. As long as this earlier regulation is not replaced or abrogated, and as far as it does not conflict with later laws or regulations, it can be relied upon for guidance. What are the

Cambodia has issued a set of regulations that aim to encourage greater energy efficiency from appliances marketed in the country. The regulations follow Cambodia’s adoption of its National Energy Efficiency Policy, which sets out the government’s energy efficiency targets and policies to reach them by 2030, including the ambitious national target of reducing the country’s total energy consumption by at least 19%. This set of regulations for appliances marketed in Cambodia is contained in Sub-Decree No. 254 on the Management and Improvement of Energy Efficiency of Electrical Appliances, dated August 11, 2023. This sub-decree sets out product registration and energy efficiency labeling requirements for electrical appliances marketed in Cambodia. It further provides that appliances should meet energy efficiency standards and all other mandatory standards that apply to electrical appliances. During the product registration process, the appliances are checked against such standards, and registration is only granted if the standards are met. The sub-decree identifies the Ministry of Mines and Energy as the main ministry responsible for the implementation of the sub-decree. To assist with the wide scope of regulations as set by the sub-decree, it further appoints assisting ministries that may implement and enforce only certain aspects. These effective implementation and enforcement mechanisms suggest that once the sub-decree’s 12-month implementation period has passed, there is likely to be a rather strict enforcement approach to the requirements. Key Features of the Sub-Decree Several mandatory standards have already been applied to most electrical appliances over the past years, but the required product registration process to check for compliance with those standards has not always been completed by those importing, distributing, or manufacturing electrical appliances in Cambodia. The new sub-decree clearly mandates a product registration requirement as a check to verify the applicable standards are met, and sets penalties for non-compliance. Penalties

Myanmar’s Ministry of Commerce has announced its E-commerce Guidelines to regulate stakeholders engaging in e-commerce. The guidelines—which were issued on September 5, 2023, and took immediate effect—are mandatory for e-commerce business operators (both entities and individuals), and failure to comply with the guidelines’ requirements may result in penalties under relevant laws. The E-commerce Guidelines come as Myanmar seeks to increase its regulation of e-commerce activities. The guidelines were preceded by a July 2023 notification requiring e-commerce business operators to register their activities with the Ministry of Commerce by January 21, 2024. Definitions “E-commerce” is defined as the sale of goods or services on the internet or other digital platforms. The term also covers sales promotions, marketing, logistics, ordering, and delivery. An “e-commerce platform entrepreneur” is a person who manages an e-commerce platform where two or more entrepreneurs can conduct e-commerce. An “e-commerce business operator” is a person operating or authorized to operate e-commerce activities. This includes e-commerce platform entrepreneurs, entrepreneurs selling on e-commerce platforms, and sellers through social media platforms. Electronic Contracts Acceptable forms of electronic contracts, which must comply with the Electronic Transactions Law, Contract Act, and other relevant laws, include: Click-wrap, click-through, and web-wrap contracts; Browse-wrap contracts; and Agreements between seller and buyer on social media platforms, such as by accepting or rejecting an offer via direct message. Samples of contract forms are appended to the guidelines. Consumer Protection Disclosure notices for consumers must be comprehensible, correct, consistent, simple, accessible, and visible. They can be written in Myanmar language, English, or Myanmar language and another language. They must also comply with the relevant provisions of the Consumer Protection Law. The guidelines provide that if the agreed delivery date is eclipsed by more than 15 days, the consumer may terminate the contract and request a full refund of

Thailand is preparing to open its first renewal period for drug marketing authorizations (MAs) since the passage of the Drug Act (No. 6) B.E. 2562 (2019). Before 2019, MAs for pharmaceuticals and vaccines in Thailand had lifelong validity. The 2019 Drug Act stipulated that all new MAs would be valid for seven years and could be renewed. The 2019 law also set out expiration dates for existing pharmaceutical products registered and approved prior to the implementation of the law (i.e., before October 13, 2019): Drug MAs issued before January 1, 1997, expire on October 13, 2024. Drug MAs approved between January 1, 1997, and December 31, 2007, expire on October 13, 2026. Drug MAs approved between January 1, 2008, and October 13, 2019, expire on October 13, 2028. Based on these dates, the first renewal period for drug MAs will commence in the fourth quarter of 2023. To facilitate the renewal process, the Thai Food and Drug Administration (FDA) has publicized draft regulations and notifications on the required application form and documents, the rules and conditions, and the process for renewing an MA. In May 2023, the Thai FDA issued Ministerial Regulation Re: Renewal of Drug MA Licenses B.E. 2566 (2023) to prescribe the essential requirements for filing a renewal application: To renew a drug MA, holders must submit their renewal application to the Thai FDA within the one-year period before the MA’s expiration date. Renewal applications can only be submitted online via the Thai FDA’s electronic system. The Thai FDA will grant approval for an MA renewal if the following conditions are satisfied: The documents in relation to efficacy and safety are up-to-date, accurate, and in accordance with academic principles. The specification and analytical method comply with the official pharmacopeias as prescribed in the Drug Act, as amended.