Advisory Council on Food and Environmental Hygiene



This paper presents the main features of the food safety control system in Hong Kong.


2. The overall objective of food safety control is to ensure that food products are hygienic, safe and fit for human consumption.


3. The food safety control framework in Hong Kong consists of the following main components -

  1. food safety legislation;
  2. safety control of imported food;
  3. food surveillance;
  4. risk assessment;
  5. safety control of live food animals;
  6. management of food incidents; and
  7. risk communication.

4. In the past the emphasis of food safety control was on enforcement of food safety legislation and the carrying out of food surveillance and import control. The traditional food safety control model recommended by the World Health Organization (WHO) in the 1960s focused on end-product inspection through food surveillance at points of import and in the market.

5. With the increasing sophistication of the food production/ manufacturing industry and the advancement of food science and medical knowledge, limitations of the traditional model have become more and more apparent. With its emphasis on end-product inspection, the model was reactive as in most cases, the food in question would have already been consumed by the time test results are available. As a result, the WHO started to promote a more process-oriented and risk-based control model from the 1990s. The new model excels the old one in at least two areas -

  1. it seeks to prevent the occurrence of food incidents at source and is therefore more proactive; and
  2. it encourages partnership, responsibility sharing and documentation among all stakeholders, i.e. the Government, the food trade and the consumers.

6. The Administration has since the 1990s taken steps to improve Hong Kong's food control framework in line with the new model promulgated by WHO by putting more emphasis on safety control at source. Taking the opportunity of the reorganization of the provision of municipal services, we further strengthened efforts on this front through the introduction of some infrastructural changes to the food safety regulatory framework. The following paragraphs describe how we organize our work and how each component mentioned in paragraph 2 contributes to food safety assurance.

Food Safety Legislation

7. Most food safety related rules and regulations are contained in Part V (Food and Drugs) of the Public Health and Municipal Services Ordinance (Cap. 132). This main Ordinance provides for, inter alia, general protection of consumers against food not of the nature, substance or quality demanded by the purchaser. It stipulates the offences against sale of food which is unfit for human consumption, and empowers authorized public officers to seize, remove and destroy food which is unfit for human consumption. Its subsidiary regulations prescribe detailed rules on food standards, import food control measures and related matters. A list of these subsidiary regulations is at Annex A.

Safety Control of Imported Food

8. As a member of the World Trade Organization (WTO) and in accordance with its Agreement on the Application of Sanitary and Phytosanitary Measures, we have adopted the policy and practice for imposing all control measures on imported food solely on public health grounds and on the basis of scientific evidence. The extent of control varies depending on the health impact of individual food categories.

9. Import of perishable products, which include milk, milk beverages, frozen confections, game, meat and poultry, has to be accompanied by official health certificates issued by recognized overseas authorities. Importers are also required to notify or/and seek the authority's (i.e. the Director of FEHD) prior approval before the actual importation takes place. Inspection and random sampling are carried out at points of import and products which do not comply with local safety standards are rejected.

10. Vegetables imported from the Mainland must be accompanied by official pesticide declaration forms. Random samples are taken from vegetable vehicles going through the Man Kam To Control Point. The sampled vegetables are subject to laboratory tests on pesticide residues with positive results initiating immediate recall.

11. Seafood, being more liable to bacteriological and chemical contamination, is also considered as a high-risk food. It is hence one of our priority items of random inspection and sample testing at import control points. In particular, under the agreement between the Administration and the seafood trade, importers of coral reef fish from "high-risk" harvest zones (i.e. where ciguatoxin has been found previously) need to submit prior fish samples to FEHD for testing. Importation only takes place after the samples are tested as ciguatoxin free. For coral reef fish from other harvest zones, the trade notifies FEHD upon the importation and the latter takes random samples after their arrival in Hong Kong.

12. To ensure the imported food is safe, we undertake and maintain close liaison with health and food authorities of our major trading partners to make sure that their food production is governed by sound safety standards.

Food Surveillance

13. Food surveillance involves ongoing and systematic collection, analysis and interpretation of data on food hazards through the process of random food sampling. We have two specific objectives in conducting the food surveillance programme -

  1. To ensure food on sale is safe for human consumption -

    The programme covers all food items available in the market, with priorities given to high-risk food, products which are subjects of complaints, and items suspected to be related to food poisoning cases. Food samples collected are subject to chemical tests (mainly on additives and contaminants), microbiological tests (mainly on bacteria and virus), or radioactive tests (mainly to monitor the prevalent level of radioactivity in our food supply) depending on their nature and associated risks. While the international reference for surveillance intensity is 3 samples per 1 000 population per annum, we have consistently achieved an intensity of 8 samples per 1 000 population per annum over the years.

  2. To ensure prepackaged food is properly labelled -

    The purpose of food labelling is to provide a means for the food industry to communicate to the consumers and for the latter to make an informed choice. Random inspections are carried out to ensure all prepackaged food on sale is labelled in accordance with the legal requirements. Random samples are also collected for verification of the contents of the labels.

14. Based on the results of the inspection or laboratory testing, enforcement actions are taken against any person who imports or sells food not complying with the legislation. Depending on the possible health impact, these actions may include giving health advice, warning and prosecution.

Risk Assessment

15. Risk assessment provides the scientific basis for effective management of food safety issues and accurate communication of real and perceived risks. Since 1 January 2000, a dedicated team of medical professionals and food scientists has been set up in FEHD to take up the following duties -

  1. (a) providing scientific basis for the food surveillance programme by carrying out regular reviews on the surveillance results;
  2. (b) conducting risk assessment and research on specific food items with priority given to high-risk foods, subjects of food incidents reported or food items of public concern;
  3. (c) recommending testing standards for food surveillance and enforcement purposes;
  4. (d) conducting daily surveillance for food incidents and carrying out follow up case assessment as necessary; and
  5. (e) conducting food consumption survey and related data analysis.

Safety Control of Live Food Animals

16. To ensure live food animals are safe for human consumption, we now have a dedicated team of veterinary professionals and field officers undertaking the following duties -

  1. verification of health documents and identification tags/tattoos, and inspection of general health conditions of all imported food animals at points of entry;
  2. ante-mortem inspection for each and every animal for slaughtering in slaughterhouses; and
  3. random urine sampling of pigs for testing of beta agonists, a prohibited veterinary drug residue in meat, at slaughterhouses.

Management of Food Incidents

17. Food incident is a general term we use to describe any situation where food safety is compromised. A food incident may involve specific human victims as in the case of food poisoning, but in others, no human victims may be involved. Before the re-organization when DH was responsible for food safety control, different types of food incidents were handled by different units in DH. The designation of a dedicated and multi-disciplinary team of professionals to handle all food-related incidents in FEHD will enhance efficiency and coordination for swift action to be taken. The team, led by a medical doctor and comprising health inspectors and nurses, cooperates closely with DH (which is responsible for treating the human victims, their food collaterals and contacts, and controlling the spread of infection in the community) to perform the following duties on reports of food incident -

  1. inspecting the food premises and investigating the causes of the food incidents in food premises;
  2. coordinating efforts amongst concerned government departments, local consulates, the trade and the public in case of food recall;
  3. coordinating necessary follow up actions to public complaints and media reports on local or overseas food incidents; and
  4. collecting and analysing the food incident data for the formulation of specific food hygiene education programmes for the trade and the community.

Risk Communication

18. Food safety control is a shared responsibility among three key parties, the Government, the trade and the consumers. The concept of tripartite responsibility is illustrated in Annex B. In brief, the Government is responsible for ensuring compliance of all food safety related rules and regulations by the trade on the one hand, and providing adequate information to consumers on the other. The trade has to take responsibility and exercise due diligence to ensure their products are safe for consumption. Consumers have to watch out for and be aware of the risk when choosing their food and to observe safe food practices at home.

19. Since close tripartite cooperation is essential for achieving the ultimate goal of "safe food for all", communication amongst all stakeholders is of utmost importance. Effective and efficient exchange of information reduces the chance of food incidents during ordinary times and minimizes damage during crises. We therefore have another team of medical professionals and health inspectors dedicated to carry out communication with the public and the trade -

    Communication with Public
   a. organizing programmes to promote food safety and provide information on prevention of food-borne diseases to the community;
   b. organizing programmes to publicize the latest food surveillance and risk assessment results;
   c. organizing programmes to collect public opinions on specific food safety issues, e.g. public forums on labelling of genetically modified food;
   d. preparing/providing resource materials to facilitate the above risk communication programmes;
   e. handling public enquiries on food safety issues.

    Communication with Trade
   f. introducing and promoting the Hazard Analysis Critical Control Point (HACCP) concept to the food trade. HACCP is a preventive and proactive approach to food safety assurance recommended by WHO. With the HACCP system, food safety control is integrated into the design of food production and manufacturing process;
   g. assisting selected sectors of the trade to identify hazards and critical control points, set critical limits and develop monitoring/control procedures; and
   h. assisting selected sectors of the trade to implement HACCP-based food safety programmes.


20. While food safety control is facing more challenges as technology develops and consumers become more health conscious, we are confident that with the collaborated efforts of the Government, the trade and the consumers, the people of Hong Kong will be able to enjoy food of the highest possible level of hygienic and safety standard; and all food related risks will be properly assessed, managed and communicated.

Food and Environmental Hygiene Department

2 May 2000

Annex A

Food Safety Related Subsidiary Legislation under
the Public Health and Municipal Services Ordinance (Cap. 132)

  1. Colouring Matter in Food Regulations
  2. Dried Milk Regulations
  3. Food Adulteration (Artificial Sweeteners) Regulations
  4. Food Adulteration (Metallic Contamination) Regulations
  5. Food and Drugs (Composition and Labelling) Regulations
  6. Frozen Confections Regulation
  7. Harmful Substances in Food Regulations
  8. Imported Game, Meat and Poultry Regulations
  9. Milk Regulation
  10. Mineral Oil in Food Regulations
  11. Preservatives in Food Regulations
  12. Smokeless Tobacco Products (Prohibition) Regulations

Annex B

Shared Responsibility: Safe Food For All
Source: Guidelines for Strengthening a National Food Safety Programme, by Food Safety Unit, Division of Food and Nutrition, WHO, 1996.