Advisory Council on Food and Environmental Hygiene



This paper seeks Members' views and advice on a number of legislative amendments to the existing statutory requirements on the labelling of pre-packaged food.


  1. Food labelling is an important channel of communication between manufacturers and consumers. It serves as a tool for the food industry to inform and attract potential buyers on the one hand and assist consumers to make informed choices on the other.
  2. In Hong Kong, pre-packaged food have to be labelled. The Food and Drugs (Composition and Labelling) Regulations require that the following information be provided and displayed on the labels -
     (a) name or designation of the food;
     (b) list of ingredients;
     (c) food additives;
     (d) indication of "best before" or "use by" date;
     (e) special condition for storage or instruction for use;
     (f) quantity; and
     (g) name and address of manufacturer/packer.
  1. As the food authority, the Food and Environmental Hygiene Department (FEHD) enforces the above requirements through random inspection of all pre-packaged food available in the market place. Verification on the truthfulness of label contents through laboratory testing will also be carried out as necessary. When non-compliance is detected, appropriate enforcement action will be taken.


  1. As part of Government's ongoing efforts to enhance food safety for the protection of public health, we conduct regular review of the legal provisions and requirements for food labelling. We also aim to keep the local food legislation up to date and, as far as possible, in line with the latest international development. In proposing any additional labelling requirements, we should balance the need to enhance consumer information on the one hand and to guard against imposing an unnecessary burden on the trade on the other. As a member of the World Trade Organization, HKSAR is obliged under the Agreement on Sanitary and Phytosanitary Measures to ensure that we do not enact food related legislation which would pose unnecessary barrier to international trade. For this reason, any review will have to make reference to the international standards on food labelling developed by Codex .
  2. Following the above principles, we have identified three areas in which the existing labelling legislation on pre-packaged food should be improved -
     (a) food labels should declare the presence of any allergic substances which are known to cause allergy in some individuals;
     (b) food labels should contain detailed information on any food additives used; and
     (c) the format required in marking the "best before" or "use by" date should be made more flexible.

The rationale and justification for each of the above proposals are discussed in the following paragraphs.

Labelling of Allergic Substances

  1. The existing legislation does not require labelling of ingredients or additives which may cause allergy to some individuals. To safeguard public health, we recommend that we should require the declaration of substances in food products which are known to cause allergy in some people on the labels. Similar requirement has been endorsed by Codex and incorporated into the Codex General Standard for Labelling of Prepackaged Foods.
  2. We propose that the following food ingredients and additives which are known to be capable of causing allergy should be labelled -
     (a) cereals containing gluten, i.e. wheat, rye, barley, oats, spelt or their hybridized strains and products of these;
     (b) crustacea and crustacean products;
     (c) eggs and egg products;
     (d) fish and fish products;
     (e) peanuts, soybeans and their products;
     (f) milk and milk products (lactose included);
     (g) tree nuts and nut products; and
     (h) sulphite in concentrations of 10 mg/kg or more.

Labelling of Details of Food Additives Used

  1. The existing legislation requires food labels to declare either the exact name of any additives used, or just the general categories to which the additives belong, such as preservative and colour. To provide consumers with more information, we recommend that both the category and the exact name of the additives should be declared on food labels. For example, instead of stating "preservative" (which already fulfils the requirement of the existing legislation), detailed information such as "preservative - sodium nitrate" should be declared. Such declaration of the exact additives used is in accordance with the Codex recommendation.
  2. To address the potential concern of the trade regarding the practicability of listing all additives within the limited label space, we propose that serial numbers of additives under the International Numbering System (INS) can be used as alternatives to full names; hence in the previous example, "preservative 251" will also be accepted. This approach in additive labelling is widely adopted internationally, including in countries of the European Union, Australia and New Zealand. To improve consumer understanding, we will publish booklets on INS directory and promulgate the scheme through public education programmes.

More Flexible Date Marking Format

  1. The existing legislation requires the "best before" or "use by" date of food products to be marked in both English and Chinese language, or in Arabic numerals in the strict order of the date followed by the month and then the year. While marking the date in English and Chinese words is straightforward, there are two problems associated with the existing Arabic numeral option -
     (a) the date marking sequence of the products normally follows the convention of the country of origin. For example, products of the United States are normally marked in the sequence of the month followed by the date and then the year. We have received complaints from importers about the unnecessary costs incurred due to the order requirement as they have to introduce additional food labels on products to replace the original ones in order to comply with our legislative requirement; and
     (b) confusions arising from the display of a sequence of numbers. For example, the date mark "10 05 2000" may denote 5 October 2000 or 10 May 2000.
  1. To address the concerns of the trade and consumers, we propose that when Arabic numerals are used to show the durability period of a food, the restriction on the order in which the year, the month and the date appear should be lifted but the exact sequence must be clearly declared in both Chinese and English words. Hence using the previous example, any one of the following date marks are acceptable -
2000 10 05
�~ �� ��
yy mm dd
2000 05 10
�~ �� ��
yy dd mm
10 05 2000
�� �� �~
mm dd yy
05 10 2000
�� �� �~
dd mm yy
10 2000 05
�� �~ ��
mm yy dd
05 2000 10
�� �~ ��
dd yy mm


  1. The implementation of the above proposed amendments will require the full co-operation of the trade. To give sufficient time for the trade to prepare for the changes, we would allow a grace period which from past experience may take two years. We will consult the trade on the length of the grace period required when we sound them out on the proposed amendments.


  1. Members are invited to advise on the proposal set out in para 6 to para 13 above. Subject to Members' endorsement, we will consult the trade and the relevant panels of the Legislative Council later in the year. Our aim is to introduce the legislative amendments in early 2001.

Food and Environmental Hygiene Department
June 200