1. Definition & Classification 

As per Cap. 612 Food Safety Ordinance, all dairy products (excluding infant formula) are classified into five kinds:

• Milk and milk beverages;

• Cream, cheese, butter;

• Condensed milk, evaporated milk, filled milk products;

• Dried milk;

• Other dairy products.

Cap. 132AQ Milk Regulation defines milk, milk beverage and reconstituted milk:

• Milk refers to cow's milk, buffalo's milk and goat's milk and also means cream and frozen or reconstituted milk and cream, but does not include separated milk, dried milk or condensed milk;

• Milk beverage refers to any beverage resulting from combining liquid milk fat with other solids derived from milk whether exclusive of any food additive or otherwise;

• Reconstituted milk refers to products resulting from the recombining with water of milk constituents, namely, milk fat and other solids derived from milk exclusive of any other substance, and includes the products resulting from the melting of frozen concentrated milk, and to reconstitute milk shall be construed accordingly.

Besides, Cap. 132R Dried Milk Regulations defines dried milk as milk, skimmed milk or partly skimmed milk which has been concentrated in the form of solid or powder by removal of water, and includes any such milk which has been sweetened, modified or compounded.

2. Competent authority 

3. Market access approval 

3.1 Importer/distributor registration 

Food importers, through close liaison with exporting countries, are responsible for ensuring that dairy products comply with Hong Kong legislation. Any person who carries on food importation/distribution business shall register with FEHD as a food importer/food distributor. Detailed information can be found at Guide to the Registration Scheme for Food Importers and Food Distributors.

3.2 Import permit application 

Any imported milk or milk beverage must be from a source of manufacture that has been approved by FEHD. Before importing, importers need to apply for an import permit from the Food Import & Export Section of the Centre for Food Safety through on-line system at FTP website or paper-mode application and provide the following information either in English or Chinese or accompanied by a verified translation in either English or Chinese:

• Copy of valid registration certificate of the product's manufacturing plant issued by a competent authority of the place of food origin;

• Supply certificate issued by the manufacturer certifying that it is the direct supplier of the product, together with the manufacturing flowchart showing details of the production facilities, heat-treatment method, etc.;

• Test report on the quality of water used in the manufacturing plant for food production, including results of coliform bacteria and free residual chlorine levels;

• Test report showing the chemical composition of the product;

• Test report showing the microbiological quality of the product;

• Declaration by the manufacturer on the shelf-life of the product;

• Sample of empty container of the product;

• Full clear pictures of the product package (showing clearly the brand name, product name, ingredients, heat-treatment method, name and address of the manufacturer, name and address of the importer);

• Specimen of certificate issued by a competent authority of the place of food origin certifying the product has been subject to appropriate heat-treatment, has been handled, processed and packed under satisfactory hygienic conditions, meets specific quality standards and is fit for human consumption; in case legal reference is quoted in the certificate, a copy of the original text of the relevant legislation shall be attached.

In addition to the information and documents listed above, FEHD may require the applicant to provide other supplementary information and documents depending on individual circumstances.

Notably, the import permit is valid for one year from the date of issue. Application for renewal shall be submitted within three months before expiry. For more details, please refer to Notes on Application for Import Permission (Applicable to New Application/Addition of Products to Existing Import Permission for Milk and Milk Beverages/Cream/Frozen Confections).

3.3 Inspection and quarantine 

When a milk or milk beverage consignment arrives Hong Kong and before its release, the products will be inspected and if necessary, sampled by FEHD. Upon the Department's satisfaction, a release letter will be issued to the importer.

4. Product compliance 

4.1 Product requirements 

Imported dairy products shall comply with hygienic standards in Hong Kong.

4.2  Label 

The labeling of dairy products shall comply with food labeling provisions stated in Cap. 132W Food and Drugs (Composition and Labeling) Regulations, and must be in either English or Chinese, or both.

Except common labeling requirements for general food, Schedule 2 of Cap. 132W Food and Drugs (Composition and Labeling) Regulations stipulates special labeling requirements for several dairy products, including separated milk, skimmed milk, partly skimmed milk, condensed or evaporated skimmed milk and condensed or evaporated partly skimmed milk.

In addition, Cap. 132R Dried Milk Regulations specifies special labeling requirements for dried milk products.

* Global Food Compliance Service

We provide various market entry services to help stakeholders better understand exporting requirements, establish business and secure a competitive place to facilitate trade development.

 Covered Countries

China, Thailand, Vietnam, Singapore, Malaysia, Philippines, Indonesia, Japan, South Korea, United States, European Union, Australia, New Zealand etc.

Our Services

• Food Ingredient Review

• Label Review

• Product Registration

• Regulatory Consultation

• Monitoring, Training and customized report

Please feel free to contact us via food@chemlinked.com if you need any help.