1. Definition
Food additives means any substance, not commonly regarded or used as food, which is added to, or used in or on, food at any stage to affect its keeping qualities, texture, consistency, appearance, taste, odour, alkalinity or acidity, or to serve any other technological function in relation to food, and includes processing aids in so far as they are added to, or used in or on, food as aforesaid, but does not includes:
Vitamins, minerals or other nutrients in so far as they are used solely for the purpose of fortifying or enriching food;
Herbs or spices when used as seasoning;
Hops;
Salt;
Yeast or yeast extracts;
The total products of any hydrolysis or autolysis of food protein;
Starter cultures;
Malt or malt extract;
Any substance which is present in food solely as a result of its addition to animal, bird or fish feedingstuffs or its use in a process or treatment carried out in crop husbandry, animal husbandry, veterinary medicine or storage (including any pesticide, fumigant, sprout depressant or veterinary medicine); or
Air or water
2. Competent authority
Hong Kong’s Center for Food Safety, which operates under the Hong Kong Food and Environmental Hygiene Department (FEHD), is responsible for implementing food safety control policies and enforcing food related legislation.
FEHD takes food samples of imported food upon arrival.
3. Regulatory Status
Use of a food additive in food for sale in Hong Kong is subject to regulations prescribed locally in Part V of the Public Health and Municipal Services Ordinance (Cap.132) and its subsidiary legislations. At present in Hong Kong there are three subsidiary regulations regarding food additives and their limitations under operation, mainly covering coloring matters, sweeteners, preservatives and antioxidant. Meanwhile, specifications for dairy products have been laid down in Food and Drugs (Composition and Labeling) Regulation.
For other ingredients, CFS takes reference from the safety evaluation done by international food safety authorities such as the Joint FAO/WHO Expert Committee on Food Additives (JECFA) when considering whether to allow food additives, which do not fall within the regulated category, to be added to foods
4. Relevant regulations
4.1 Coloring Matter in Food Regulations
Permitted coloring matters are divided into two categories in this regulation, which are
Coal Tar Colors, including:
Common name | Scientific name |
Allura red (AC) | disodium salt of 6-hydroxy-5-[(2-methoxy-5-methyl-4-sulphophenyl)-azo]-2-naphthalene-sulphonic acid |
Amaranth | trisodium salt of 1-(4-sulpho-1-naphthylazo)-2-naphthol-3: 6-disulphonic acid |
Black PN (Brilliant black BN) | tetrasodium salt of 8-acetamido-2- (7-sulpho-4-p-sulphophenylazo-1-naphthylazo)-1-naphthol-3: 5-disulphonic acid |
Brilliant blue FCF (Brilliant blue FD & C No. 1) | disodium salt of 4-(4-(N-ethyl-p-sulphobenzylamino)-phenyl) -(2-sulphoniumphenyl)-methylene-(1-(N-ethyl-N-p- sulphobenzyl)-2, 5-cyclohexadien-imine) |
Brown FK | a mixture consisting essentially of the disodium salt of 1:3-diamino-4:6-di-(p-sulphophenylazo) benzene and the sodium salt of 2:4-diamino-5-(psulphophenylazo) toluene |
Carmoisine | disodium salt of 2-(4-sulpho-l-naphthylazo)-l-naphthol-4 -sulphonic acid |
Chocolate Brown HT | disodium salt of 2:4-dihydroxy-3:5-di-(4-sulpho-l-naphthylazo) benzyl alcohol |
Erythrosine (BS) | disodium or dipotassium salt of 2:4:5:7-tetra-iodo-fluorescein |
Green S | sodium salt of di-(p-dimethylaminophenyl)-2-hydroxy-3:6-disulphonaphthylmethanol andydride |
Indigotine(Indigo Carmine) | disodium salt of indigotin-5:5'-disulphonic acid |
Lithol Rubine BK | disodium salt of 3-hydroxy-4-[(2-sulpho-p-tolyl)azo]-2- naphthoic acid |
Patent Blue V | calcium salt of (4-[x-(p-(diethylamino) phenyl)-5-hydroxy-2, 4-disulphobenzylidene]-2, 5-cyclohexadien-1-ylidene) diethyl-ammonium hydroxide inner salt |
Ponceau 4R | trisodium salt of 1-(4-sulpho-l-naphthylazo)-2-naphthol-6:8- disulphonicacid |
Quinoline Yellow | disodium salt of disulphonic acid of 2-(2 quinolyl)-1,3-indandione |
Sunset Yellow FCF | disodium salt of 1-p-sulphophenylazo-2-naphthol-6-sulphonic acid |
Tartrazine | trisodium salt of 5-hydroxy-1-p-sulphophenyl-4-p-sulphophenylazopyrazole-3-carboxylic acid |
and other colors, including:
Description |
Caramel |
Cochineal (Carminic acid) 75470 Colouring matter natural to edible fruits or vegetables or their pure colouring principles whether isolatedfrom such natural colours or produced synthetically and including- Annatto Vegetable Black Carotenes Beta-Apo-8'-carotenal Beta-Apo-8'-carotenoic acid ethyl este Chlorophylls and Chlorophyllins including Copper complexes Saffron Tumeric (Curcumin) |
Iron Oxides |
Titanium dioxide |
Silver, Gold and Aluminium in leaf or powder form solely for external colouring of dragees and decoration of sugar-coated flour confectionery |
The Aluminium or Calcium salts (lakes) of any of the scheduled water-soluble colours |
4.2 Sweeteners in Food Regulations
Ten permitted sweeteners as of Apr 2015, including:
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 |
4.3 Preservatives in Food Regulation
There are around 29 permitted preservatives and antioxidants included in this regulation, and allowed proportions are specified by food category. Any other preservative or antioxidant which is not expressly listed in this regulation is not allowed in food prepared for Hong Kong market.
4.4 Food and Drugs (Composition and Labeling) Regulation
Additives in certain milk products have been incorporated in this regulation:
Additives in sweetened condensed or evaporated milk, sweetened condensed skimmed or separated milk and unsweetened condensed or evaporated milk
Additive | Maximum Level |
Firming Agents | |
Potassium chloride | 2 grams per kilogram singly or 3 grams per kilogram in combination, expressed as anhydrous substances |
Calcium chloride | |
Stabilizers | |
Sodium citrates | 2 grams per kilogram singly or 3 grams per kilogram in combination, expressed as anhydrous substances |
Potassium citrates | |
Calcium citrates | |
Acidity Regulators | |
Calcium carbonates | 2 grams per kilogram singly or 3 grams per kilogram in combination, expressed as anhydrous substances |
Sodium phosphates | |
Potassium phosphates | |
Calcium phosphates | |
Diphosphates | |
Triphosphates | |
Polyphosphates | |
Sodium carbonates | |
Potassium carbonates | |
Thickener | |
Carrageenan | 150 milligrams per kilogram |
Emulsifier | |
Lecithins | Limited by good manufacturing practice |
Additives in butter
Additive | Maximum Level |
Acidity Regulators | |
Sodium phosphates | |
Sodium carbonate | 2 grams per kilogram Limited by good manufacturing practice |
Sodium hydrogen carbonate | |
Sodium hydroxide | |
Calcium hydroxide | |
Additives in cream
Additive | Maximum Level | |
Stabilizers | ||
Calcium carbonates | Limited by good manufacturing practice | |
Sodium lactate | ||
Potassium lactate | ||
Calcium lactate | ||
Sodium citrates | ||
Potassium citrates | ||
Calcium citrates | ||
Calcium sulphate | ||
Sodium phosphates | 2 grams per kilogram, whether the additives are used singly or in combination, expressed as phosphorus pentaoxide (P2O5) | |
Potassium phosphates | ||
Calcium phosphates | ||
Diphosphates | ||
Triphosphates | ||
Polyphosphates | ||
Acidity Regulators | ||
Sodium carbonates | Limited by good manufacturing practice | |
Potassium carbonates | ||
Lactic acid (L, D, and DL-) | ||
Citric acid | ||
Thickeners and emulsifiers | ||
Lecithins | Limited by good manufacturing practice | |
Alginic acid | ||
Sodium alginate | ||
Potassium alginate | ||
Ammonium alginate | ||
Calcium alginate | ||
Agar | ||
Carrageenan and its sodium, potassium and ammonium salts | ||
Carob bean gum | ||
Guar gum | ||
Gum Arabic | ||
Xanthan gum | ||
Gellan gum | ||
Polyoxyethylene (20) sorbitan monolaurate | 1 gram per kilogram | |
Polyoxyethylene (20) sorbitan monooleate | ||
Polyoxyethylene (20) sorbitan monopalmitate | ||
Polyoxyethylene (20) sorbitan monostearate | ||
Polyoxyethylene (20) sorbitan tristearate | ||
Pectins | Limited by good manufacturing practice | |
Cellulose | ||
Methyl cellulose | ||
Hydroxypropyl cellulose | ||
Hydroxypropyl methyl cellulose | ||
Methyl ethyl cellulose | ||
Sodium carboxymethyl cellulose | ||
Mono- and diglycerides of fatty acids | ||
Acetic and fatty acid esters of glycerol | ||
Lactic and fatty acid esters of glycerol | ||
Citric and fatty acid esters of glycerol | ||
Potassium chloride | ||
Calcium chloride | ||
Monostarch phosphate | Limited by good manufacturing practice | |
Distarch phosphate esterified with sodium trimetaphosphate; distarch phosphate esterified with phosphorus oxychloride | ||
Phosphated distarch phosphate | ||
Acetylated distarch phosphate | ||
Starch acetate esterified with acetic anhydride | ||
Acetylated distarch adipate | ||
Hydroxypropyl starch | ||
Hydroxypropyl distarch phosphate | ||
Starch sodium octenyl succinate |
| |
5. Labeling requirements
Under the Food and Drugs (Composition and Labeling) (Amendment) Regulation 2004, prepackaged food sold in Hong Kong should declare details of the food additives used on their labels, both by their exact names and by their functional classes so as to provide consumers with accurate and meaningful information on the exact type of additives present and their functions in the food. INS could be used as general reference for labeling purpose.
Subject to section 58 of the Ordinance and unless the Authority otherwise allows in any particular case, an additive (except an additive specified in subsection (7)) constituting one of the ingredients of a food shall be listed by its functional class and
(a) its specific name; or
(b) its identification number under the International Numbering System for Food Additives; or
(c) its identification number under the International Numbering System for Food Additives with the prefix"E" or "e". (L.N. 85 of 2004)
The functional classes of additive are
Acid
Acidity regulator
Anti-caking agent
Anti-foaming agent
Antioxidant
Bulking agent
Color
Color retention agent
Emulsifier
Emulsifying salt
Firming agent
Flavor enhancer
Flour treatment agent
Foaming agent
Gelling agent
Glazing agent
Humectant
Preservative
Propellant
Raising agent
Stabilizer
Sweetener
Thickener
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