Hong Kong Food Additive Regulation

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


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


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


trisodium salt of 5-hydroxy-1-p-sulphophenyl-4-p-sulphophenylazopyrazole-3-carboxylic acid

  • and other colors, including:



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-


Vegetable Black



Beta-Apo-8'-carotenoic acid ethyl este

Chlorophylls and Chlorophyllins including Copper complexes


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:


Acesulfame Potassium






Aspartame-acesulfame Salt


Cyclamic Acid (and Sodium, Potassium, Calcium Salts)


Saccharin(and Sodium, Potassium, Calcium Salts)








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


Maximum Level

Firming Agents

Potassium chloride

2 grams per kilogram singly or 3 grams per kilogram in combination, expressed as anhydrous substances

Calcium chloride


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




Sodium carbonates

Potassium carbonates



150 milligrams per kilogram



Limited by good manufacturing practice

  • Additives in butter


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


Maximum Level


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




Acidity Regulators

Sodium carbonates

Limited by good manufacturing practice

Potassium carbonates

Lactic acid (L, D, and DL-)

Citric acid

Thickeners and emulsifiers


Limited by good manufacturing practice

Alginic acid

Sodium alginate

Potassium alginate

Ammonium alginate

Calcium alginate


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


Limited by good manufacturing practice


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