Annex B



Summary of Views Collected from the Consultation Exercise on
Proposed Amendments to
Food and Drugs (Composition and Labelling) Regulations



Number of written opinions received: 29

Number of enquires (without giving comments) received: 49

Summary of views received

(A) Labelling of Allergic Substances

  1. Opinions received in general supported the proposal.

  2. There are 13 supporting submissions. Supporting reasons sited include -

    • It helps to protect health of individuals who are allergic to certain food ingredients.

    • It is in line with the recommendation made by Codex.

    • It helps consumers to make an informed choice.

  3. There are 3 submissions objecting the proposal. Objecting reasons sited include -

    • Most of HK's major trading partners have not implemented similar requirement.

    • It is costly in compliance.

  4. We have also received comments related to the proposal, which include-

    • Other known allergic substances such as honey, certain herbal products, phenylalanine should also be labelled.

(B) Labelling of Details of Food Additives Used

  1. Opinions received in general supported the proposal.

  2. There are 17 supporting submissions. Supporting reasons sited include -

    • Adoption of international code for labelling of food additives will help harmonization of world trade.

    • Adoption of INS number will simplify identification of food additives used.

    • It helps consumers to make an informed choice.

    • It helps medical professionals to give advice to their patients/clients.

  3. There is 1 submission objecting the proposal for the following reason -

    • Compliance cost to the trade outweighs potential benefits to consumers.

  4. We have also received comments related to the proposal, which include -

    • EU's code (i.e. INS with prefix "E") should also be accepted means for declaration of food additives.

    • Accepted Chinese translations for additive names should be flexible.

    • Chinese names of additives should be standardized.

(C) More Flexible Date Marking Format

  1. Opinions received in general supported the proposal.

  2. There are 15 supporting submissions. Supporting reasons sited include -

    • It increases flexibility of the trade.

    • It provides clearer information to the consumers.

  3. There are 4 submissions objecting the proposal. Objecting reasons sited include -

    • Compliance cost to the trade outweighs potential benefits to consumers.

    • There is difficulty to comply with in cases of printing all the required words in small areas such as caps of bottled products.

    • Should not require dates marked in numerical format in the sequence of "day-month-year" to declare the exact order adopted. Such declaration is only required for numerical dates marked in other sequence.

  4. We have also received comments related to the proposal, which include -

    • Supplementation of "best before date" with "production date".

    • Size, colour, location and method of date marking should be standardized.

    • "d/m/y" for declaration of order of date marking sequence adopted should be accepted.

(D) Strengthening of Labelling Requirement for Alcoholic Drinks

  1. Opinions received in general supported the proposal.

  2. There are 16 supporting submissions. Reasons sited include -

    • Beverage alcohol with low alcoholic content would deteriorate over time and should therefore be required to label durability periods.

    • Liquor with high alcoholic content should continue to be exempted from ingredient labelling as fermentation and distillation process transform the original ingredients used in the production of spirits products.

  3. We have received 1 submission objecting the proposal, for the following reason -

    • It is costly in compliance.

  4. We have also received some comments related to the proposal. They include -

    • Alcoholic drinks should label their alcoholic strength.

    • Alcoholic drinks should display health warnings on their labels.

    • Name and address of importer and country of origin should be labelled.

(E) Grace Period

We have received 3 submissions requesting for extension of grace period. Suggested grace periods include 24 and 36 months.

Food and Environmental Hygiene Department
January 2001

 

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