[Updated] Hong Kong to Revise Food Adulteration (Metallic Contamination) Regulations

Editor's note: The article was published on October 15, 2024, and was updated on December 16, 2024, and June 30, 2025.

On June 27, 2025, Hong Kong published the Food Adulteration (Metallic Contamination) (Amendment) Regulation 2025 in the Gazette. The Amendment Regulation will be tabled before the Legislative Council on July 2 for negative vetting.

On December 16, 2024, Hong Kong government consulted on the amendments. Stakeholders are encouraged to submit opinions by February 16, 2025.

On October 8, 2024, the Panel on Food Safety and Environmental Hygiene of Hong Kong S.A.R. Legislative Council proposed amendments to the Food Adulteration (Metallic Contamination) Regulations (Cap. 132V).

The current regulations stipulate 144 maximum levels (MLs) for 14 metallic contaminants in food. To align with Codex standards and standards from key import sources, the Panel has proposed 27 new MLs for specified metals in designated foods (16 MLs with reference to Codex standards and 11 MLs with reference to the Chinese mainland standards). In addition, the proposal includes 9 updates to existing MLs for Lead in relevant foods (6 MLs with reference to Codex standards and 3 MLs with reference to the Chinese mainland standards). With these proposed changes, the total number of MLs will rise from 144 to 171.

According to the Panel, the proposed amendments will later go through a three-month public consultation and are expected to be submitted to the Legislative Council in the second half of 2025 for review.

Details of the proposed amendments:

27 New MLs for specified metals in designated foods

Part 1: With reference to Codex
Food		Hong Kong		Codex ML (mg/kg)
Food		Existing ML (mg/kg)	Proposed ML (mg/kg)	Codex ML (mg/kg)
Lead
1	Grape juice	0.05 (Fruit juice exclusively from berries and other small fruits)	0.04	0.04
2	Fresh farmed mushrooms (button mushrooms (Agaricus bisporous), shiitake mushrooms (Lentinula edodes), and oyster mushrooms (Pleurotus ostreatus)	1 (Edible fungi)	0.3	0.3
3	Cereal-based foods for infants and young children	N/A	0.02	0.02
4	Ready-to-eat complementary foods for infants and young children	N/A	0.02	0.02
5	Honey and candies made with food-grade sugar	N/A	0.1	0.1
Cadmium
6	Cocoa powder (100% total cocoa solids on a dry matter basis) ready for consumption	N/A	2.0	2.0
7	Chocolate containing or claiming to contain ≥ 70% total cocoa solids on a dry matter basis	N/A	0.9	0.9
8	Chocolate containing or claiming to contain ≥ 50% to < 70% total cocoa solids on a dry matter basis	N/A	0.8	0.8
9	Chocolate containing or claiming to contain ≥ 30% to < 50% total cocoa solids on a dry matter basis	N/A	0.7	0.7
10	Chocolate containing or claiming to contain < 30% total cocoa solids on a dry matter basis	N/A	0.3	0.3
Methylmercury Notes: the Panel also proposed to extend the existing ML for methylmercury in “Fish” (i.e., 0.5 mg/kg) to cover fish products “Fish balls/Fish cakes”.
11	Tuna	0.5 (Fish)	1.2	1.2
12	Alfonsino	0.5 (Fish)	1.5	1.5
13	Marlin	0.5 (Fish)	1.7	1.7
14	Shark	0.5 (Fish)	1.6	1.6
15	Orange roughy	0.5 (Fish)	0.8	0.8
16	Pink cusk-eel	0.5 (Fish)	1.0	1.0
Part 2: With reference to the Chinese mainland
Food		Hong Kong		Relevant GB 2762-2022 ML (mg/kg)
Food		Existing ML (mg/kg)	Proposed ML (mg/kg)	Relevant GB 2762-2022 ML (mg/kg)
Lead
17	Armillaria mellea	1 (Edible fungi)	0.3	0.3
18	“Boletus bainiugan, Lanmaoa asiatica, Sutorius brunneissimus, Rugiboletus extremiorientalis”, Tricholoma matsutake, Tuber spp., Russula virescens, Termitomyces spp., Cantharellus spp., and Lactarius volemus	1 (Edible fungi)	1.0	1.0
19	“Auricularia cornea, Auricularia heimuer” and Tremella fuciformis	1 (Edible fungi)	1.0 (In dried form)	1.0 (In dried form)
20	White and refined sugars, corn and maple syrups	N/A	0.5	0.5
21	Soft brown, raw, and non-centrifugal sugars	N/A	0.5	0.5
Cadmium
22	Edible fungi (unless otherwise specified)	0.1 (Vegetables unless otherwise specified)	0.2	0.2
23	Shiitake mushrooms	0.1 (Vegetables unless otherwise specified)	0.5	0.5
24	Morchella importuna, Sarcodon imbricatus, Russula virescens, Cantharellus spp., and Armillaria mellea	0.1 (Vegetables unless otherwise specified)	0.6	0.6
25	Tricholoma matsutake, “Boletus bainiugan, Lanmaoa asiatica, Sutorius brunneissimus, Rugiboletus extremiorientalis”, Termitomyces spp., and Lactarius volemus	0.1 (Vegetables unless otherwise specified)	1	1
26	Tuber spp. and Agaricus blazei	0.1 (Vegetables unless otherwise specified)	2	2
27	“Auricularia cornea, Auricularia heimuer” and Tremella fuciformis	0.1 (Vegetables unless otherwise specified)	0.5 (In dried form)	0.5 (In dried form)

9 Updated MLs for Lead in relevant foods

Part 1: With reference to Codex
Food		Hong Kong		Codex ML (mg/kg)
Food		Existing ML (mg/kg)	Proposed ML (mg/kg)	Codex ML (mg/kg)
Lead
1	Mango chutney	1	0.4	0.4
2	Edible offal of cattle	0.5	0.2	0.2
3	Edible offal of pig	0.5	0.15	0.15
4	Edible offal of poultry	0.5	0.1	0.1
5	Edible fats and oils	0.1	0.08	0.08
6	Salt, food grade (Other than salt from marshes)	2	1	1
Part 2: With reference to the Chinese mainland
Food		Hong Kong		Relevant GB 2762-2022 ML (mg/kg)
Food		Existing ML (mg/kg)	Proposed ML (mg/kg)	Relevant GB 2762-2022 ML (mg/kg)
Lead
7	Fat spreads and blended spreads	0.1	0.08	0.08
8	Lime preserved eggs	0.5	0.2	0.2
9	Edible fungi (unless otherwise specified)	1	0.5	0.5