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Frequently Asked Questions on the
Guidelines on Voluntary Labelling of Genetically Modified (GM) Food
(for Trade)

Q. 1 What is the purpose of developing these guidelines?
A. 1
In order to enhance consumers' knowledge and right to make an informed choice on GM food, the Centre for Food Safety (CFS) supports the local food trade's initiative in setting up a voluntary labelling system for GM food. The Guidelines serve as a reference to facilitate the trade to make truthful claims of GM foods.
   
Q. 2 Why does the Government propose to introduce the voluntary labelling guidelines on GM food, instead of a mandatory labelling scheme?
A. 2

When deciding the regulatory framework on GM food labelling, a number of factors, including trade impact and public concern, have to be taken into account.

In the past public consultation exercise, the majority of views collected are in support of mandatory labelling, and the presence of GM content in any ingredient of a food product above a threshold level should be labelled. However, as there was concern about the possible price rise after the introduction of a mandatory labelling system, a regulatory impact assessment (RIA) on the labelling of GM food in Hong Kong was conducted and revealed that there would be additional cost to the trade, in particular the small and medium sized companies, if a mandatory scheme was to be implemented. Moreover, there is at present no international consensus on the labelling of GM food. The Government will need to engage the trade and other stakeholders and consult them before coming to any conclusion on whether there should be mandatory labelling requirement for GM food. In response to consumers' increasing demand for more product information, the Government considers it a pragmatic move to introduce a voluntary labelling scheme for GM food at this stage.

   
Q. 3 What are the current international practices on labelling of GM food?
A. 3
The international community is working towards a consensual policy on GM food labelling. However, the Codex Alimentarius Commission of the United Nations is unlikely to be able to set internationally agreed standards in the near future. At present, the regulatory approach on GM food labelling varies in different countries and areas, and can be broadly classified as voluntary or mandatory. For the voluntary labelling approach, only GM food that is significantly different from its conventional counterpart, in terms of composition, nutritional value and allergenicity, needs to be labelled. The U.S and Canada are examples of countries adopting this approach. For the mandatory approach, it can be further classified as two categories, i.e. “pan-labelling” or “labelling for designated products only”. The “pan-labelling” category requires that any food products containing GM materials exceeding a threshold level or food with any significantly different characteristics as a result of genetic modification must be labelled. The EU, Australia and New Zealand are examples of countries adopting this approach. The “labelling for designated products only” category requires that only the designated products which are genetically modified need to be labelled. Countries and areas like Japan, Korea, Taiwan and Mainland China are adopting this approach.
   
Q. 4 How were the guidelines developed?
A. 4
A Working Group comprising representatives from the food trade, Consumer Council and relevant Government departments was set up by the Food and Environmental Hygiene Department to formulate the Guidelines. After the Centre for Food Safety was established, the Working Group met and finalised the draft Guidelines.
   
Q. 5 Are these guidelines legal binding?
A. 5
The Guidelines are advisory in nature and have no legal effect. Adoption is entirely voluntary and is not binding. Nevertheless, members of the trade are encouraged to adopt the Guidelines to standardise consumers' information.
   
Q. 6 Are these guidelines applicable to all types of food including loose food items sold in Hong Kong?
A. 6 These guidelines are only applicable to pre-packaged food sold in Hong Kong and are voluntary in nature.
   
Q. 7 What kind of food products should be labelled under the Guidelines?
A. 7
Any food items with 5% or more GM materials in their respective food ingredient(s) could be labelled as “genetically modified” in a prescribed manner. Additional declaration on the food label is recommended when significant modifications that have taken place under the following conditions: (a) the composition or nutritional value is significantly different from that of its conventional counterpart; (b) the level of anti-nutritional factors or natural toxicants is significantly different from that in its conventional counterpart; (c) the presence of an allergen that is not found in its conventional counterpart; (d) the intended use of the food is significantly different from that of its conventional counterpart; or (e) an animal gene has been introduced into food of plant origin.
   
Q. 8 Why is a threshold level of 5% adopted in the Guidelines?
A. 8
In the Guidelines, a threshold level of 5% is adopted in order to address the problem of unintentional adventitious mixing between GM and non-GM food materials during harvest, storage and transportation. This chosen level reflects what the trade can deliver at this stage. Furthermore, the analysis in the Regulatory Impact Assessment on Labelling of GM Food suggested that the cost to the trade could increase significantly if the threshold level becomes more stringent. This threshold level was also adopted by overseas countries or areas including Canada, Japan and Taiwan.
   
Q. 9 What are the pros and cons of adopting a threshold level of 5% or 1%?
A. 9

Adopting a threshold level of 5%:

Pros

  • At present, there is no international consensus on threshold level for GM food labelling and the adopted threshold levels vary from country to country with levels ranged from 0.9 to 5%. Hence, a threshold level of 5% would impose less technical difficulties on the trade.
  • This approach will incur less additional cost on the food production.
  • This approach will currently be more practical or achievable among the local food trade.

Cons

  • This approach will not fully address the need of consumers who would like to know the presence of a lower content of GM materials, so as to make informed choices.

Adopting a threshold level of 1%:

Pros

  • This approach will address better the need of consumers who would like to know whether food contains any GM materials at all, so as to make informed choices.

Cons

  • This approach will currently be less practical or achievable among the local food trade.
  • This approach will limit consumer choice to those foods that have been grown intentionally to meet the non-GM market due to the problem of unintentional adventitious mixing between GM and non-GM food materials in the production of field crops.
Q. 10
Do the Guidelines cover the aspect of negative labelling? What is the approach proposed in these guidelines?
A. 10
To be consistent with the international approach, negative labelling is not recommended for food of which no GM varieties have been produced as it would be misleading to consumers. The trade could browse the webpage of the “GM Food Database” in our website to know more about which foods have GM counterparts. Furthermore, absolute terms such as “GM free” and similar labels (e.g. GMO free, free from GM ingredients, etc.) are not recommended to be used, as such absolute terms may be misleading to consumers. Since there is the possibility of unintentional mixing of GM and non-GM crops, a truly “GM free” status is very difficult to attain.

If the trade would like to use labelling besides the aforesaid absolute terms to describe their products as being made from non-GM source, they need to have documentation to substantiate such declaration. Moreover, if a product contains multiple ingredients, such declaration can only be used when ALL of the ingredients in the product are derived from non-GM sources and documentation are available to substantiate the claim.
   
Q. 11 Will the Guidelines be reviewed in the future?
A. 11
Subject to further development, in areas like technological advancement, international consensus on the labelling approach, etc., these guidelines may be reviewed and updated.
   
Q. 12 Do the Guidelines require additional declaration if the GM food contains an allergen?
A. 12
Food allergy is common and a range of food products such as peanuts and eggs, no matter if they are GM or not, may contain allergenic proteins which can cause allergic reaction. Under the current legislation, if a food consists of or contains any of (i) cereals containing gluten; (ii)crustacea and its products; (iii) eggs and its products; (iv) fish and its products; (v) peanuts, soyabeans and their products; (vi) milk and its products and (vii) tree nuts and nut products, the name of the substance shall be specified in the list of ingredients. In addition, the voluntary Guidelines on GM food labelling also suggest those GM foods with the presence of an allergen, which is not found in its conventional counterpart to have additional declaration on the food label.
   
Q. 13 How should the trade label food with single ingredient which is genetically modified?
A. 13
Schedule 4 of the Food and Drugs (Composition and Labelling) Regulations exempts any food consisting of a single ingredient to comply with the labelling requirements imposed under paragraph 2 of Schedule 3 to the Regulations. However, paragraph 3 of Schedule 3 provides that if any prepackaged food which is exempted from paragraph 2 of Schedule 3 is marked or labelled with a list of ingredients on its own initiative (regardless whether the ingredients are GM or not), such list of ingredients shall comply with the labelling requirements imposed under Schedule 3.

Therefore, if traders adopt this voluntary guidelines on GM food labeling, food with single ingredient consisting of 5% or more GM materials is to be labelled as “genetically modified” in parenthesis following the name of the food in the list of ingredients or in a prominently displayed footnote to the list of ingredients. Such labelling should conform in all respects with the requirements of the marking and labelling of prepackaged foods in the said Schedule 3.
   
Q.14 What are the anti-nutritional factors mentioned in the Guidelines?
A.14
Anti-nutritional factors are those compounds that inhibit the normal uptake or utilization of nutrients. The trypsin inhibitor commonly found in soya bean is one of the examples of anti-nutritional factors. Trypsin inhibitor can inhibit the activities of some digestive enzymes and may affect the process of nutrient absorption from the overall diet.
   
Q. 15
How can the trade get information about those GM food products that have been approved so far?
A. 15
If the trade would like to obtain a list of GM food products which were approved to be sold in the market, they may visit the “GM Food Database” in our website. The database has included the list of GM food products that have been gone through the safety assessment processes and have been approved in some countries such as the United States, Canada, Australia and New Zealand.
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