1. How can I know whether a particular food additive can be used in a food product in Hong Kong?

Reference can be taken from the following regulations:

  1. Colouring Matter in Food Regulations (Cap. 132H)
  2. Sweeteners in Food Regulations (Cap. 132U)
  3. Food and Drugs (Composition and Labelling) Regulations (Cap. 132W)
  4. Preservatives in Food Regulation (Cap. 132BD)

Details of the above food law are available at the website www.elegislation.gov.hk.

If, after checking with the aforesaid Regulations, you are still not sure whether a particular food additive can be used in food, you may send us an enquiry through the electronic mail (e-mail address: enquiries@fehd.gov.hk) with the following information for processing:

  1. name of the food additive;
  2. INS No. of the food additive;
  3. nature of the substance e.g. extract or whole plant;
  4. technological function of the food additive in the food;
  5. nature/type of food in which the food additive is being added;
  6. amount of the food additive used in the food;
  7. other useful information or special concern.

We will reply the enquirer within 10 days of receipt of the enquiry. If a substantive reply is not possible within this period, an interim reply will be given.

2. Can Tertiary butylhydroquinone(TBHQ) be used as antioxidants in edible oils and fats ?

According to the Preservatives in Food Regulation (Cap. 132 BD), TBHQ not exceeding a permitted level is allowed to be used as an additive in fats and oils in Hong Kong.

3. Can brominated vegetable oil (BVO) be used in food in Hong Kong?

BVO may be used in flavouring for beverages. JECFA (Joint FAO/WHO Expert Committee on Food Additives) has evaluated the safety of BVO and concluded that it should not be used as food additive.

As stipulated in section 54 of the Public Health and Municipal Services Ordinance (Cap. 132), it is an offence to sell food that is unfit for human consumption.

Members of the trade should not use BVO in food in Hong Kong.

4. Is sulphur dioxide a permitted additive in peeled almond ( 南北杏 ) ?

According to the Preservatives in Food Regulation (Cap. 132 BD), peeled almond may contain sulphur dioxide as food additive.

5. Can calcium carbonate be used as a food additive including colouring matter in food? New

The Joint FAO/WHO Expert Committee on Food Additives (JECFA) has evaluated the safety of calcium carbonate. According to the Codex General Standard for Food Additives (GSFA), calcium carbonate is a permitted food additive with multiple technological functions such as acidity regulator, anticaking agent, firming agent, flour treatment agent, stabilizer and colour.  In places like the European Union, the United States and Canada, calcium carbonate is also a permitted food colouring matter. 
In Hong Kong, calcium carbonate can be used in food in general.  Besides, the First Schedule to the Colouring Matter in Food Regulations (Cap. 132H) specifies colouring matter permitted for food use.  Calcium carbonate, being natural to some leafy green vegetables, is also considered a permitted colouring matter under Cap. 132H.

The Food and Drugs (Composition and Labelling) Regulations (Cap. 132W) also specifies the maximum levels of calcium carbonate in certain milk products.  As a stabilizer in cream, the maximum level of calcium carbonate is “limited by good manufacturing practice#” while as an acidity regulator in condensed milk, the maximum level of calcium carbonate is as follows:

Maximum level of calcium carbonate in sweetened condensed or evaporated milk; sweetened condensed skimmed or separated milk; and unsweetened condensed or evaporated milk

Acidity Regulators
Additive Maximum Level
Calcium carbonates 2 grams per kilogram singly or 3 grams per kilogram in combination, expressed as anhydrous substances
Sodium phosphates
Potassium phosphates
Calcium phosphates
Sodium carbonates
Potassium carbonates
#Good manufacturing practice includes a manufacturing practice which complies with the following requirements—
(a) the quantity of the additive added to food is limited to the lowest possible level necessary to accomplish its desired effect;
(b) the quantity of the additive that becomes a component of food as a result of its use in the manufacturing, processing or packaging of a food and which is not intended to accomplish any physical, or other technical effect in the food itself, is reduced to the extent reasonably possible; and
(c) the additive is prepared and handled in the same way as a food ingredient.

6. How is the use of flavouring agent regulated in Hong Kong?

There is currently no specific legislation in Hong Kong governing the use of flavouring agent. The food law in Hong Kong under the Public Health and Municipal Services Ordinance (Cap. 132) covers general protection for food purchasers, offences in connection with sale of unfit food and adulterated food, composition and labelling of food, food hygiene, seizure and destruction of unfit food.

When considering whether any particular flavouring agent is allowed to be added to foods, we will take reference from safety evaluation done by international food safety authorities such as JECFA.

7. Is sorbitol a permitted sweetener in food?

According to the Sweeteners in Food Regulations (Cap. 132U), sweetener means any chemical compound which is sweet to the taste, but does not include any sugars or other carbohydrates or polyhydric alcohols. As sorbitol is one of the polyhydric alcohols, the aforesaid Regulations are not applicable to sorbitol. Nevertheless, sorbitol can be used in food in accordance with good manufacturing practice.

8. What are the permitted sweeteners in Hong Kong?

According to the Schedule to the Sweeteners in Food Regulations (Cap. 132U), permitted sweeteners include the followings:

  1. Acesulfame Potassium
  2. Alitame
  3. Aspartame
  4. Aspartame - acesulfame Salt
  5. Cyclamic Acid (and Sodium, Potassium, Calcium salts)
  6. Saccharin (and Sodium, Potassium, Calcium Salts)
  7. Sucralose
  8. Thaumatin
  9. Neotame
  10. Steviol Glycosides

9. What are the maximum permissible levels for the permitted sweeteners in foods?

There are no maximum permissible levels set for those permitted sweeteners as prescribed in the Schedule to the Sweeteners in Food Regulations (Cap. 132U). The quantity of the permitted sweeteners to be used in foods shall be in accordance with the good manufacturing practice.

10. In the supermarket, the soya milk of local brands often expire within a few days, but some foreign brands expire in half a year's time. Both types are found in the refrigeration section. Does that mean that the longer lasting ones have a higher dose of preservatives and that we should avoid them?

The difference in shelf-life among different brands of soya milk may be due to the use of different types of heat treatment process in their production. For example, in products that have been Ultra Heat Treated, virtually all microbial population has been eliminated, the shelf-life can extend to months, yet there may not be significant difference in terms of the nutritive and other quality attributes as compared to products treated with other heat processes.

The letters "U.H.T.", which stand for Ultra Heat Treated, may be found on the product package. The use of preservative in U.H.T. products is generally considered not necessary. Also, U.H.T. products normally do not need refrigeration until opened.

11. What is the maximum penalty for the breach of regulations related to the labelling of food additives?

The maximum penalty is a fine of $50,000 and 6 months' imprisonment.

12. Some media in Hong Kong reported that "One Drop of Incense" used as a flavouring agent of soup products made its way into the restaurants of Hong Kong. What is "One Drop of Incense"?

Upon our enquiry, the concerned Mainland authority replied that "One Drop of Incense" was a hotpot flavouring agent. Generally speaking, hotpot flavouring agents may contain vegetable oils and flavouring substances. It was also reported in the media that the major component of "One Drop of Incense" was ethyl maltol, which could be used as a flavouring and a flavour enhancer. The Joint FAO/WHO Expert Committee on Food Additives (JECFA) has evaluated the safety of ethyl maltol and opined that the normal use of ethyl maltol as flavouring in food would not raise safety concern . The Centre for Food Safety also explained, in the February and December 2011 editions of the newsletter "Food Safety Focus", the incident to the public and the trade. For details, please refer to the links below:

Hot Pot Flavouring Agent "One Drop of Incense" (Food Safety Focus 55th Issue, February 2011)

From "One Drop of Incense" to Flavourings (Food Safety Focus 65th Issue, December 2011)

13. What has the Centre for Food Safety (CFS) done to ensure the correct use of food additives ?

Educational materials such as leaflets and booklets are distributed by the CFS through publicity channels including CFS website, periodicals, seminars and exhibitions to brief the public and the trade on various food additives and the relevant legislation. The CFS has also strengthened its publicity efforts by making use of its monthly e-publication "Food Safety Focus", which serves as a platform to introduce a series of articles covering holistically the safety concern of food additives like preservatives, colouring matters, sweeteners, etc. Such information is also available for the public and the trade on the CFS website. Meanwhile, testing on food additives in different types of foods is conducted by the CFS under the food surveillance programme.