| 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.
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| 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.
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| 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.
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| 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.
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| 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.
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| 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. |
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| 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.
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| 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.
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| 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
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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
Cons
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| Q. 10 |
Do the Guidelines cover the aspect of negative
labelling? What is the approach proposed in these guidelines?
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| 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. |
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| 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.
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| 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 labeling 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.
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| 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 labelling 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.
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| 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.
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| Q. 15 |
How can the trade get information about those
GM food products that have been approved so far?
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| 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. |
