Hong Kong-Bound Food Labelling Guide (Part 1): A Full Interpretation of the Seven Mandatory Items

       You have proper labels and test reports on the Mainland — so when they reach Hong Kong, at most you just change the price tag?

       If that is what you think, the danger has already begun.

       Hong Kong is a separate customs territory. Its labelling requirements are independent of the Mainland, and its regulation and sampling inspections form a separate system. If labels do not comply with Hong Kong legislation, products do not even have the qualification to enter the market.

       So what exactly does Hong Kong require to be labelled? None of the following seven items can be omitted:

       1. Food name

       The name must enable consumers to fully understand the nature and category of the food, and must not contain any false, misleading or fraudulent elements.

       Therefore, the food name must reflect the true nature of the food; it cannot be only a brand name or a fancy name; nor can it skirt the edges — exaggerated or suggestive wording must be rejected.

       2. List of ingredients

       The labelling rules for the list of ingredients are divided into four levels:

       Heading: An appropriate heading must be given, containing the words “ingredients”, “composition”, “substances contained” or words of similar meaning — you cannot simply list ingredient names without a heading;

       Order: Ingredients must be listed in descending order of weight or volume at the time of packaging (after cooking and concentration);

       Additives: The functional class of the additive must be stated, together with its own name or its International Numbering System (INS) identification number.

       For example, if sulphur dioxide is used as a preservative, it must be labelled as “preservative (sulphur dioxide)”, “preservative (E220)” or “preservative (220)”;

       Allergens: If the food contains any of the eight specified allergens, it must be declared in the list of ingredients.

       It should be noted that vague wording (such as “cream or butter”) must not be used in the list of ingredients.

       3. Shelf life / Date marking

       “Best before”: applies to general foods, indicating that under proper storage conditions the food can retain its characteristics up to and including that date;

       “Use by”: highly perishable foods that may pose an immediate health risk after a short period (such as chilled ready-to-eat foods) must use this type and cannot be replaced by “best before”.

       Specific format requirements: dates shall be expressed in Arabic numerals or in Chinese and English; day, month and year shall be indicated as “DD/日”, “MM/月” and “YY/年” respectively, in any order.

       Compliant example: “Best before 28/06/22 (DD/MM/YY)”. If special storage is required to keep the food until that date, the storage conditions must be stated together with the date.

       4. Special storage conditions or instructions for use

       If special storage methods are required to preserve quality, or special attention is needed when using, this should be clearly stated on the label.

       Common examples include “Please store in a cool, dry place” and “Keep frozen (below -18°C)”;

       Products that require special conditions before consumption (such as crayfish that need reheating) must be labelled with “instructions for use”; those without special conditions may omit this.

       5. Quantity, weight or volume

       The net quantity must be stated — net weight for solid foods, net volume for liquids, and number of pieces for items sold by piece. The declared value must match the actual contents.

       6. Name and address of manufacturer or packer

       The full name and full address must be clearly stated.

       7. Language: Chinese, English or bilingual

       Labels must use Chinese (Traditional), English, or both Chinese and English.

       When bilingual labelling is adopted, the food name, list of ingredients and nutrition label must be bilingual.

       III. Exemptions

       List of ingredients may be exempted: single-ingredient foods (such as pure olive oil) and seasonings. Note that if a single-ingredient food voluntarily lists ingredients on the label, that list must still fully comply with all requirements of Schedule 3;

       Shelf-life statement may be exempted: cooking salt, sugar without added ingredients, chewing gum, etc.

       List of ingredients, storage instructions and manufacturer information may be exempted: packaging with a maximum surface area of less than 10 square centimetres;

       The entire Schedule may be exempted (i.e. all seven statutory mandatory items above may be omitted): pre-packaged food sold for immediate consumption in food supply establishments (such as restaurants and canteens).

       Label compliance is one link in the chain of supplying Hong Kong and going global.

       Qualification filing, system building, residue testing plans, and matchmaking with Hong Kong importers and channels — every step requires professional judgement and practical experience. And this is exactly where Jade Premium excels. You are welcome to add Jade Premium Butler… A free compliance assessment is now available to help you clarify your current situation, calibrate your direction, and then formulate a step-by-step implementation plan.