Consultation Document

Proposed Amendments to
the Food Adulteration
(Metallic Contamination)
Regulations (Cap. 132V)

December 2024
 Consultation Document

Proposed Amendments to the Food Adulteration

(Metallic Contamination) Regulations (Cap.132V)

Environment and Ecology Bureau

Food and Environmental Hygiene Department
Centre for Food Safety

December 2024
List of Abbreviations

1st HKTDS The First Hong Kong Total Diet Study

ALARA As low as reasonably achievable
CFS Centre for Food Safety
Codex Codex Alimentarius Commission
EU European Union
FAO Food and Agriculture Organization of the United Nations
GAP Good Agricultural Practice
GMP Good Manufacturing Practice
HBGV Health-based guidance value
JECFA Joint FAO/WHO Expert Committee on Food Additives
ML Maximum level
The Expert Committee Expert Committee on Food Safety
The Mainland The Mainland China
The Ordinance Public Health and Municipal Services Ordinance (Cap. 132)
The Regulations Food Adulteration (Metallic Contamination) Regulations
(Cap. 132V)
WHO World Health Organization
 CONTENTS

Page

Chapter 1 Introduction 1-4

Chapter 2 Proposed Amendments to the Regulations 5-12

Chapter 3 Views Sought 13

Annex I Proposed Maximum Levels (MLs) with reference 14-16

to the latest Codex MLs

Annex II Proposed MLs for methylmercury in fish and fish 17

balls/fish cakes

Annex III Codex MLs for lead in wines and fortified/liqueur 18

wines proposed not to adopt

Annex IV Proposed MLs for cadmium and lead in specified 19-20

foods with reference to the latest standards of major
importing places
Chapter 1 Introduction

Metallic contaminants in Food

1.1 Metals are naturally present and ubiquitous in the environment.

Metals such as mercury, arsenic, and cadmium occur naturally in the earth’s crust.
They can be released into the environment through various natural processes or
human activities. Metallic contaminants are often present in foods in trace
amounts. They can enter the food supply through environmental elements, such
as air, soil, and water, or during the food production processes. For the general
adults population, diet is the main source of exposure to some common metallic
contaminants, such as cadmium, lead, and methylmercury.

1.2 Excessive dietary exposure to metallic contaminants may lead to

chronic toxicity and cause adverse health effects, since they may accumulate in
the body. Acute poisoning from metallic contaminants is rare and happens more
likely through non-food route.

1.3 The adverse health effects posed by metallic contaminants in food

depend on the nature of the metallic contaminants, as well as the amount and
duration of exposure, etc. International food safety authorities such as the Joint
Food and Agriculture Organization of the United Nations (FAO)/World Health
Organization (WHO) Expert Committee on Food Additives (JECFA) 1 have
conducted evaluations on the adverse health effects of various metallic
contaminants.

1.4 As these heavy metals get into the soil and water, they are easily taken
up by the plants, animals and aquatic life that we consume. This makes the
presence of metallic contaminants in our food, in most cases, unavoidable. To
protect public health, levels of metallic contaminants in food should be as low as
reasonably achievable (ALARA) through best practices such as Good

1
JECFA is the international food safety authority responsible for evaluating the safety of food additives,
contaminants, naturally occurring toxicants and residues of veterinary drugs in food.

1
Agricultural Practice (GAP) and Good Manufacturing Practice (GMP). In order
to reduce the exposure to metallic contaminants from food in the population,
regulatory measures such as the establishment of statutory control over the types
and levels of metallic contamination in food are adopted in most jurisdictions,
including Hong Kong. Also, competent authorities of individual jurisdictions
provide dietary advices to their people, particularly to susceptible groups of the
population2.

The Practices of Codex Alimentarius Commission (Codex)3

1.5 Codex deliberates, adopts, reviews and updates the maximum levels
(MLs) for contaminants, including metallic contaminants 4, for various foods from
time to time in view of the advancement of science and the outcome of risk
assessment from the JECFA. According to the Codex principles for establishing
MLs for contaminants in food, MLs shall only be set for food in which the
contaminant may be found in amounts that are significant for the total exposure
of the consumers, i.e. the general local population. In other words, it is not
necessary to set ML for each and every type of food that contains a contaminant.

1.6 In addition, MLs shall be set in such a way that the consumer is
adequately protected based on scientific principles leading to standards which are
designed to assure the quality and safety of food. At the same time, the
principles of GAP and GMP as defined by Codex, and other legitimate factors5
2
Taking mercury in fish as an example, while eating fish as part of a balanced diet offers significant health
benefits, women planning for pregnancy, together with expectant and lactating mothers should avoid large
predatory fish as they may contain high level of methylmercury. The Centre for Food Safety has given
advices on fish consumption to consumers, particularly women of childbearing age.
3
Codex, established by FAO and WHO in 1960s, is the single most important international source of reference
for consumers, food producers, processors, national food control agencies and the international trade in
developing food associated standards.
4
Majority of Codex MLs for metallic contaminants are set out in the General Standard for Contaminants and
Toxins in Food and Feed (CODEX STAN 193-1995). Some are set out in the “Codex Standard for Natural
Mineral Waters (CODEX STAN 108-1981)” and the “General Standard for Bottled/Packaged Drinking Waters
(Other than Natural Mineral Waters) (CODEX STAN 227-2001)”.
5
The consideration of legitimate factors, relevant for the health protection of consumers and for the promotion
of fair practices in food trade, shall be performed in accordance with the Codex Working Principles for Risk
Analysis for Food Safety for Application by Governments (CAC/GL 62-2007) and the Criteria for
Consideration of the Other Factors Referred to in the Second Statement of Principles (see “Statements of

2
need to be considered so that there is no unjustified barrier to international trade.

Existing regulatory control on levels of metallic contamination in food

1.7 The food safety laws of Hong Kong are mainly laid down in Part V of
the Public Health and Municipal Services Ordinance (Cap. 132) (the Ordinance).
The provisions in the Ordinance cover general protection for food purchasers,
offences in connection with the sale of food which are not fit for human
consumption and adulterated food, etc. Standards relating to food safety are
provided in various subsidiary legislations of the Ordinance. In particular, the
Food Adulteration (Metallic Contamination) Regulations (Cap. 132V) (“the
Regulations”) focus on regulating metallic contamination in food. The
Regulations were first enacted in 1960. Amendments to the First and Second
Schedules to the Regulations, which stipulate the maximum permitted
concentrations of metallic contaminations, were made in 1983. The latest
amendments were made in 2018.

1.8 Specifically, the Ordinance and the Regulations control the levels of
metallic contamination in food in the following ways:-

(a) Section 54 of the Ordinance stipulates that all food for sale must be fit
for human consumption;

(b) Regulation 3AA(1) of the Regulations prohibits the import,

consignment, delivery, manufacture or sale, for human consumption, of
any food containing any metal in an amount that is dangerous or
prejudicial to health; and

(c) Part 2 of the Schedule to the Regulations stipulates 144 MLs for 14
metallic contaminants, namely antimony, arsenic, barium, boron,

Principle Concerning the Role of Science in the Codex Decision-Making Process and the Extent to which other
Factors are Taken into Account”, Appendix of the Codex Procedural Manual (28th edition)). Relevant
production, storage and handling practices used throughout the food chain including traditional practices,
methods of analysis, sampling and inspection, feasibility of enforcement and compliance, and the prevalence
of specific adverse health effects shall be taken into account. In addition, the economic consequences and the
feasibility of risk management options shall also be considered.

3
cadmium, chromium, copper, lead, manganese, mercury, nickel,
selenium, tin and uranium in specified food. Any specified food
which contains a specified metal in excess of the ML is not allowed to
be imported to or sold in Hong Kong.

4
Chapter 2 Proposed Amendments to the Regulations

2.1 One of the initiatives set out in the Supplement of the Chief Executive’s
2024 Policy Address is to review food safety standards regarding metal content
in food under the Regulations with reference to international standards and
practices, with a view to formulating legislative amendment proposals and
launching public consultation.

2.2 The last amendment exercise to the Regulations largely adopted the
prevailing Codex standards on metallic contaminants in specified foods in 2017
except for a few cases with justifications taking into account the local situation.
Since 2018, Codex has established new/updated certain standards on metallic
contamination. Also, various other jurisdictions including the Mainland China
(the Mainland) have revised their standards on metallic contamination, taking into
account the evolving Codex standards, the occurrence data of metallic
contamination in foods and their own food consumption patterns/dietary practices,
as well as their risk assessment results, etc.

2.3 To keep abreast of international development, the Environment and

Ecology Bureau and the Centre for Food Safety (CFS) of the Food and
Environmental Hygiene Department conducted a review on the Regulations with
a view to identifying aspects in the Regulations which need updating 6 , in
consultation with the Expert Committee on Food Safety (the Expert Committee)7,
to better protecting public health, facilitating effective regulation and promoting
harmonisation between local and international standards.

6
The last amendment exercise of the Regulations has already identified food/food groups which are of
significance to the local population and established relevant MLs for metallic contamination in food.
Therefore, the scope of food/food groups which should be covered in the Regulations for protecting public
health are sufficient.
7
The Expert Committee, set up under CFS, is responsible for advising the Director of Food and Environmental
Hygiene in the formulation of food safety measures, review of food safety standards in light of international
practices, trends and developments, as well as risk communication strategies. The Expert Committee consists
of academics, professionals, food experts, members of the trade and consumer group, and other experts. The
current membership includes experts from other places.

5
2.4 The review keeps the Codex standards as the backbone, supplemented
with the standards of major food importing places including the European Union
(EU), Korea and the Mainland etc, while local food consumption pattern and their
dietary practices, results of risk assessment, and stakeholder concerns were also
considered. We propose to amend the Regulations in the following areas:-

(a) To add or update the MLs for lead, cadmium and methylmercury in
specified foods with reference to the latest 8 Codex standards; and

(b) To add or update the MLs for lead and cadmium in specified foods with
reference to the latest standards of major importing places.

(a) To add or update the MLs for lead, cadmium and methylmercury in
specified foods with reference to the latest Codex standards

2.5 Codex has adopted 28 new and/or updated MLs for cadmium (5 MLs),
lead (17 MLs) and methylmercury (6 MLs) in certain foods during the period from
2018 to 2023. We propose to add 16 MLs for lead, cadmium and methylmercury
in specified foods and update 6 existing MLs for lead in specified foods in the
Regulations with reference to Codex standards (Annex I) 9 . Keeping the
Regulations abreast of the Codex standards will safeguard food safety, bring our
regulatory practices in alignment with international standards, and prevent
possible trade barriers and disputes.

MLs for methylmercury in fish species

2.6 Codex has adopted 6 new MLs for methylmercury in specified
predatory fish species (ranging from 0.8 to 1.7 mg/kg) based on the principle of
ALARA from 2018 to 2022 (Annex II).

2.7 In line with the latest Codex standards, we propose to add new MLs for

8
Codex reviews the types of metallic contaminants on which MLs should be set and the MLs from time to time.
Codex’s update in 2018-2023 were taken into account in this updating exercise of the Regulations.
9
Consequential amendments to existing MLs for food groups in the Regulations are also included in the Annex.

6
methylmercury in 6 specified fish species. In Hong Kong, the dietary exposure
to methylmercury arising from the consumption of the 6 fish species accounts for
a relatively low proportion of the population’s total dietary exposure to
methylmercury (with a total of 3%) and hence we expected that a significant
impact on the exposure of the local population to methylmercury is unlikely.

2.8 According to the JECFA, providing advices for targeted population

subgroups that might be at risk from methylmercury exposure could provide an
effective method for lowering the number of individuals with exposures greater
than the health-based guidance values (HBGV) 10 of methylmercury. CFS will
continue to provide dietary advices to local population, especially the population
sub-groups (e.g. pregnant women) that might be more susceptible to the risk from
methylmercury exposure.

2.9 Meanwhile, we will maintain the existing ML for methylmercury in

“Fish” at 0.5 mg/kg in the Regulations for fish other than these 6 specified fish
species to protect public health. This approach of setting MLs to cover all fish
is consistent with the regulatory approach in some places such as the Australia
and New Zealand, Canada, EU, Korea, the Mainland, Singapore and the United
States.

MLs for methylmercury in fish balls/fish cakes

2.10 According to the latest Mainland standards (GB 2762-2022 “Maximum
levels of Contaminants in Foods”), MLs for methylmercury in fish species also
apply to its products (Annex II). In the Second Hong Kong Population-based
Food Consumption Survey conducted by CFS from 2018 to 2020, the
consumption of “fish balls/fish cakes” by the local population is the highest
amount fish products.

2.11 We propose to add ML for methylmercury in fish balls/fish cakes at 0.5

10
HBGV is an estimate of the amount of a chemical that can be ingested over a defined time period (e.g. 24 hours)
without any appreciable health risks. For example, acute reference dose, acceptable daily intake, provisional
tolerable monthly intake, etc.

7
mg/kg, which is of the same value as existing ML for methylmercury in “Fish” in
the Regulations. The amendment would provide better clarity to the trade while
protecting public health.

2.12 Since the proposed ML values for methylmercury in “fish balls/fish

cakes” and fish other than the 6 fish species specified are the same (0.5 mg/kg), it
is suggested combining the two MLs into a single ML with food description “Fish
balls/fish cakes” and “fish unless otherwise specified” (Annex II).

MLs for cadmium in chocolate products

2.13 Codex has adopted 5 new MLs for cadmium in different chocolate
products (ranging from 0.3 to 2 mg/kg). We propose to set MLs for cadmium in
chocolate products with reference to Codex standards with a view to better
protecting the local population, especially children, from any potential health risks
posed by exposure to cadmium from consumption of chocolate products.

MLs for lead in wines and fortified/liqueur wines made from grapes harvested
before/after July 2019
2.14 Codex has revoked the prevailing ML for lead in wine at 0.2 mg/kg and
set 3 different MLs (ranging from 0.1 to 0.2 mg/kg) for wines and fortified/liqueur
depending on whether they were wines made from grapes harvested before or
after July 2019. We propose not to adopt these MLs (Annex III). “Alcoholic
beverages” only contributes 0.7% of the total exposure to lead for an average
consumer as shown in the First Hong Kong Total Diet Study (1st HKTDS). The
current ML for wine at 0.2 mg/kg is considered appropriate for public health
protection. Besides, the harvesting month of the grapes may not be indicated on
the label of the wine.

(b) To add or update the MLs for lead and cadmium in specified foods with
reference to the latest standards of major importing places

MLs for lead in “White and refined sugar, corn and maple syrups”, and “Soft
brown, raw, and non–centrifugal sugars”

8
2.15 There is currently no ML for lead in sugar in the Regulations. Codex
has adopted new MLs for lead in “White and refined sugar, corn and maple syrups,
honey” (0.1mg/kg), and “Soft brown, raw, and non–centrifugal sugars” (0.15
mg/kg). To protect public health, we propose to set new MLs for lead in “White
and refined sugar, corn and maple syrups” and “Soft brown, raw, and non-
centrifugal sugars” at 0.5 mg/kg in the Regulations with reference to the standards
of the Mainland and Korea. Since the Mainland and Korea are the major sources
of sugar imports for Hong Kong, and both places set the ML for lead in sugar at
0.5 mg/kg, the proposed addition of the new MLs should not affect the supply of
sugars in Hong Kong. Nevertheless, we propose to set a stricter ML for lead in
honey at 0.1 mg/kg having regard to the Codex ML, the relevant standards of our
importing partners such as EU and a relatively higher consumption of honey than
syrups in children (Annex IV).

ML for lead in “Fat spreads and blended spreads”

2.16 Currently, the MLs for lead in both “Fat spreads and blended spreads”
and “Edible fats and oils” are set at the same level at 0.1 mg/kg with reference to
the prevailing MLs from Codex. Codex has updated the ML for lead in “Fat
spreads and blended spreads” from 0.1 mg/kg to 0.04 mg/kg whereas the ML for
lead in “Edible fats and oils” was updated from 0.1 mg/kg to 0.08 mg/kg.
However, taking into account that “Fat spreads and blended spreads” is made
from the ingredient “Edible fats and oils” up to 90% fat 11, and that, currently, the
MLs for both “Fat spreads and blended spreads” and “Edible fats and oils” are set
at the same level, we propose to update the two existing MLs in the Regulations
from 0.1 mg/kg to the same level at 0.08 mg/kg for these two commodities, in line
with the relevant standards of the Mainland (Annex IV).

MLs for cadmium in certain edible fungi

2.17 The latest Mainland standards, which came into force on 30 June 2023

11
According to the CODEX STAN 256-1999 “Standard for Fat Spreads and Blended Spreads”, fat spreads and
blended spreads may contain not less than 10% and not more than 90% fat. Available from URL:
https://www.fao.org/fao-who-codexalimentarius/sh-
proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandard
s%252FCXS%2B256-1999%252FCXS_256e.pdf

9
to replace the earlier version of the Mainland standards (GB 2762-2017),
established/updated the MLs for cadmium in various kinds of edible fungi (Annex
IV). Since Codex has no relevant MLs for cadmium in edible fungi and the
Mainland is our primary source of edible fungi, we propose to make reference to
the MLs in the latest Mainland standards to set 6 MLs for cadmium in various
kinds of edible fungi produces.

2.18 According to the results of the 1st HKTDS, the dietary exposures to
cadmium of average and high consumers of the local population were 8.3 µg/kg
bw/month and 19 µg/kg bw/month respectively. As these levels are below the
corresponding HBGV of 25 µg/kg bw/month, normal dietary exposure to
cadmium is unlikely to pose health risk to the local population.

MLs for lead in certain edible fungi

2.19 The existing ML for lead in “Edible fungi” at 1 mg/kg in the
Regulations was made with reference to GB 2762-2017. Under the latest
Mainland standards, the corresponding ML for lead has been replaced by separate
MLs for four groups of edible fungi (ranging from 0.3 to 1 mg/kg). We propose
to update the ML for lead in edible fungi in the Regulations with reference to the
latest Mainland standards 12 (Annex IV)13.

ML for lead in lime preserved eggs

2.20 Codex had no relevant ML for lead in lime preserved eggs. The
existing ML for lead in “Lime preserved eggs” at 0.5 mg/kg in the Regulations
was made with reference to GB 2762-2017. Under the latest Mainland standard,
the corresponding ML for lead has been changed to 0.2 mg/kg for “Eggs and egg
products”. As lime preserved eggs are mainly imported from the Mainland, we
propose to update the ML for lead in lime preserved eggs in the Regulations from

12
Except the ML for 3 specified mushrooms i.e. common mushrooms (Agaricus bisporus), shiitake mushrooms
(Lentinula edodes), and oyster mushrooms (Pleurotus ostreatus). It is because Codex has set ML for these
specified fresh farmed mushrooms and considered that the ML should be limited to cultivated mushrooms since
it would be difficult to establish MLs for wild mushrooms in view of the variability of the levels of lead due to
seasonal and other geoclimatic conditions
13
Consequential amendments to existing MLs for food groups in the Regulations are also included in the Annex.

10
0.5 mg/kg to 0.2 mg/kg, in line with the relevant standard of the Mainland (Annex
IV).

Overview of the proposed amendments to the Regulations

2.21 Under the proposed amendments to the Regulations:-

(a) The total number of MLs will increase from 144 to 171 in this exercise,
with 27 new MLs for specified metals in specified foods (food pairs)
and 9 update of MLs for lead in the existing food pairs;

(b) The increase in the number of MLs is mainly the results of proposed
adoption of latest Codex MLs and any necessary update to establish
separate MLs for specified foods which are currently covered by
existing food groups.

Assessment on implications on food supply

2.22 The proposed amendments, with Codex standards as the backbone, are
expected to have no substantive impact to the trade and Hong Kong’s food supply,
as Codex standards are developed through thorough discussion among its
members and adopted by consensus. In addition, in proposing the MLs for
foods/food groups in this amendment exercise, we have taken into account
Codex’s ALARA principle. According to the results of the food surveillance
programme and additional baseline studies of CFS, the levels of metallic
contamination in foods available in local market can generally comply with the
proposed MLs (more than 99% of the food samples can meet the proposed MLs).

Transitional period

2.23 We will take into account the views received during the two-month
public consultation exercise before finalising the legislative proposals and tabling
the proposed amendments to the Regulations to the Legislative Council for

11
consideration. We propose that a transitional period of 18 months be given after
enactment of the amended legislation. This seeks to strike a balance between
protecting public health with standards that are up-to-date with international
development and allowing a reasonable lead-time for the trade and the private
testing and laboratory sector to get prepared for the updated standards.

2.24 During the transitional period, it would be legal for any single food item
to comply wholly with the requirements of either the existing Regulations or the
amended Regulations 14. After the end of the transitional period, the trade should
fully comply with the requirements of the amended Regulations.

14
Compliance with some of the requirements under the existing Regulations and the other requirements under
the amended Regulations is not allowed.

12
Chapter 3 Views Sought

3.1 We welcome views from members of the public on the proposed

amendments to the Regulations detailed in Chapter 2. Please send your
comments by post, facsimile or e-mail to CFS on or before 16 February 2025:-

Centre for Food Safety

Food and Environmental Hygiene Department
43/F, Queensway Government Offices,
66 Queensway, Hong Kong
Facsimile: (852) 2893 3547
E-mail address: metal_consultation@fehd.gov.hk

3.2 The Government may, either in discussion with others or in any

subsequent reports, whether privately or publicly, quote the contributing parties
and the views they submitted in response to the consultation document, without
seeking prior permission of the contributing parties. If any contributing parties
do not wish to have their names or affiliations disclosed by the Government,
please expressly state so in their written comments.

3.3 Any personal data provided will only be used by the CFS and other
government departments/agencies for purposes which are related to this
consultation. The parties receiving the data are bound by such purposes in their
subsequent use of the data.

3.4 The contributing parties providing personal data to the CFS in their
submission will have the right of access and correction with respect to such
personal data. Any request for data access or correction of personal data should
be made in writing to the CFS.

13
 Annex I

Proposed Maximum Levels (MLs) with reference to the latest1

Codex MLs

Proposed
Existing ML
Food items ML Proposed Note/Remark
(mg/kg)
(mg/kg)

Part I: New MLs

Cadmium
#Cocoa powder (100% total cocoa solids on a
1. N/A 2.0 --
dry matter basis) ready for consumption
#Chocolates containing or declaring ≥ 70%
2. N/A 0.9 --
total cocoa solids on a dry matter basis
#Chocolates containing or declaring ≥ 50% to
3. N/A 0.8 --
< 70% total cocoa solids on a dry matter basis
#Chocolates containing or declaring ≥ 30% to
4. N/A 0.7 --
< 50% total cocoa solids on a dry matter basis
#Chocolates containing or declaring < 30%
5. N/A 0.3 --
total cocoa solids on a dry matter basis
Methylmercury
0.5
6. #Tuna 1.2 See Note 2
Fish (Note 2)
0.5
7. #Alfonsino 1.5 See Note 2
Fish (Note 2)
0.5
8. #Marlin 1.7 See Note 2
Fish (Note 2)
0.5
9. #Shark 1.6 See Note 2
Fish (Note 2)
0.5
10. #Orange roughy 0.8 See Note 2
Fish (Note 2)
0.5
11. #Pink cusk-eel 1.0 See Note 2
Fish (Note 2)
Lead
12. Fruit juices, other than fruit juices exclusively 0.03 0.03 Applies to fruit juices (not
from berries and other small fruits (Note 8) concentrated) or products
reconstituted to the original
juice concentration that are
ready to drink. Also
applies to nectars that are
ready to drink and fruit
juices intended to be
consumed principally by

1
Codex’s update in 2018-2023 were taken into account in this updating exercise of the Regulations.

14
 Proposed
Existing ML
Food items ML Proposed Note/Remark
(mg/kg)
(mg/kg)

persons under the age of

36 months.

Fruit juices exclusively from berries and other 0.05 0.05 See Note 8
small fruits, other than grape juice (Note 8)

#Grape juice 0.05 0.04 Applies to fruit juices (not

(Fruit juices concentrated) or products
exclusively reconstituted to the original
from berries juice concentration that are
and other ready to drink. Also
small fruits) applies to nectars that are
ready to drink and fruit
juices intended to be
consumed principally by
persons under the age of
36 months.
13. #Fresh farmed mushrooms (Agaricus 1 0.3 --
bisporus, Lentinula edodes and Pleurotus (Edible fungi)
ostreatus)

14. #Cereal-based foods intended to be consumed N/A 0.02 Applies to products that are
principally by persons under the age of 36 as sold; not reconstituted to
months. be ready to eat.
15. #Ready-to-eat complementary foods intended N/A 0.02 --
to be consumed principally by persons under
the age of 36 months. (Other than cereal-based
foods intended to be consumed principally by
persons under the age of 36 months.)

16. #Honey and sugar-based candies N/A 0.1 --

Part II: Update of MLs

Lead
17. *Salt from marshes, food grade 2 2 --
(Salt, food
grade)
Salt, food grade 2 1 --
(Other than salt from marshes, food grade) (Salt, food
grade)
18. Mango chutney 1 0.4 --
19. Edible offal of cattle 0.5 0.2 --
20. Edible offal of pig 0.5 0.15 --
21. Edible offal of poultry 0.5 0.1 --

22. Edible fats and oils 0.1 0.08 --

15
Note in existing Cap.132V
Note 2: Applies to edible portion after removal of the digestive tract.
Note 8: Applies to fruit juices (not concentrated) or products reconstituted to the original juice
concentration that are ready to drink. Also applies to nectars that are ready to drink.

*: New specified food is created to maintain the scope of coverage of salt, food grade.
#: New ML for specified food.
Text in bold and underlined indicate consequential amendments to existing ML for food group in
the Regulations.

16
 Annex II

Proposed MLs for methylmercury in fish and fish balls/fish cakes

Codex ML Mainland ML
Proposed ML (mg/kg),
Food items GB 2762-2017 GB 2762-2022
(mg/kg) [Year of
adoption] (mg/kg) (mg/kg)

Methylmercury

1.2 1.2 (Note A),

Tuna 1.2 (金槍魚及其製品)
(See Note 2) [2018]

1.5 1.5 (Note A),

Alfonsino 1.5 (金目鯛及其製品)
(See Note 2) [2018]

1.7 1.7 (Note A),

Marlin 1.7 (槍魚及其製品)
(See Note 2) [2018]

1.6 1.6 (Note A), 0.5 (水產動物

Shark 1.6 (鯊魚及其製品)
(See Note 2) [2018] 及其製品(肉食
性魚類及其製
0.8 0.8 (Note A), 品除外)) 1.0 (肉食性魚類及其
Orange roughy
(See Note 2) [2022] 製品 (金槍魚、金目
1.0 (肉食性魚 鯛、槍魚、鯊魚及以
1.0 1.0 (Note A),
Pink cusk-eel 類及其製品) 上魚類的製品除外))
(See Note 2) [2022]
1.0 (肉食性魚類及其
0.5 製品 (金槍魚、金目
(Proposed Note: 鯛、槍魚、鯊魚及以
“Fish balls/fish cakes”
Applies to edible 上魚類的製品除外))
and “fish unless --
portion after removal
otherwise specified”
of the digestive tract 0.5 (水產動物及其製
(if any)) 品 (肉食性魚類及其
製品除外))
Note in Codex
Note A: Whole commodity fresh or frozen (in general after removing the digestive tract).

Note in existing Cap.132V

Note 2: Applies to edible portion after removal of the digestive tract.

Text in bold and underlined indicate consequential amendments to existing ML for food group in
the Regulations.

17
 Annex III

Codex MLs for lead in wines and fortified/liqueur wines proposed

not to adopt

Existing ML Codex ML
Food items Codex’s Note/Remark
(mg/kg) (mg/kg)

Lead

0.1 The ML applies to wine made from

Wine grapes harvested after the date of
(Note B) adoption (CAC42, July 2019)
0.15 The ML applies to wine made from
Fortified / Liqueur wine 0.2 grapes harvested after the date of
(Note B) adoption (CAC42, July 2019)
(Wine)
The ML applies to wines and
Wine (wine and fortified / 0.2 fortified / liqueur wines made from
liqueur wine) (Note B) grapes harvested before (CAC42,
July 2019)
Note in Codex
Note B: Whole commodity.

18
 Annex IV

Proposed MLs for cadmium and lead in specified foods with

reference to the latest standards of major importing places

Existing Proposed Proposed Relevant Mainland ML

Food items ML ML Note/ (GB 2762-2022)
(mg/kg) (mg/kg) Remark (mg/kg)

Lead

#Soft brown, raw, and non- *0.5

1. N/A 0.5 --
centrifugal sugars (食糖及澱粉糖)

#White and refined sugar, corn *0.5

2. N/A 0.5 --
and maple syrups (食糖及澱粉糖)

0.08
3. ^Fat spreads and blended spreads 0.1 0.08 --
(油脂及其製品)

1 0.3
4. #Armillaria mellea (Edible 0.3 -- (雙孢菇、平菇、香菇、榛蘑
fungi) 及以上食用菌的製品)

#“Boletus bainiugan, Lanmaoa

asiatica, Sutorius brunneissimus, 1.0
Rugiboletus extremiorientalis”, 1 (牛肝菌、松茸、松露、青頭
5. Tricholoma matsutake, Tuber (Edible 1.0 --
菌、雞樅、雞油菌、多汁乳
spp., Russula virescens, fungi)
Termitomyces spp., Cantharellus 菇及以上食用菌的製品)
spp. and Lactarius volemus

1 1.0
#“Auricularia cornea, Auricularia In dried
6. (Edible 1.0 (木耳及其製品、銀耳及其製
heimuer” and Tremella fuciformis form
fungi) 品) (乾重計)

0.5
(食用菌及其製品(雙孢菇、平
菇、香菇、榛蘑、牛肝菌、
^Edible fungi unless otherwise
7. 1 0.5 -- 松茸、松露、青頭菌、雞
specified
樅、雞油菌、多汁乳菇、木
耳、銀耳及以上食用菌的製
品除外))

19
 0.2
8. ^Lime preserved eggs 0.5 0.2 --
(蛋及蛋製品)

Cadmium
0.2
0.1 (食用菌及其製品 (香菇、羊
(Vegetables 肚菌、獐頭菌、青頭菌、雞
#Edible fungi unless otherwise
9. unless 0.2 -- 油菌、榛蘑、松茸、牛肝
specified
otherwise 菌、雞樅、多汁乳菇、松
specified) 露、姬松茸、木耳、銀耳及
以上食用菌的製品除外))
0.1
(Vegetables
0.5
10. #Lentinula edodes unless 0.5 --
(香菇及其製品)
otherwise
specified)

0.1 0.6
#Morchella importuna, Sarcodon
(Vegetables
imbricatus, Russula virescens, (羊肚菌、獐頭菌、青頭菌、
11. unless 0.6 --
Cantharellus spp. and Armillaria 雞油菌、榛蘑及以上食用菌
otherwise
mellea 的製品)
specified)

#Tricholoma matsutake, “Boletus

0.1
bainiugan, Lanmaoa asiatica, 1.0
(Vegetables
Sutorius brunneissimus,
12. unless 1 -- (松茸、牛肝菌、雞樅、多汁
Rugiboletus extremiorientalis”,
otherwise 乳菇及以上食用菌的製品)
Termitomyces spp. and Lactarius
specified)
volemus

0.1
(Vegetables 2.0
13. #Tuber spp. and Agaricus blazei unless 2 -- (松露、姬松茸及以上食用菌
otherwise 的製品)
specified)

0.1
(Vegetables 0.5
#“Auricularia cornea, Auricularia In dried
14. unless 0.5 (木耳及其制品、银耳及其製
heimuer” and Tremella fuciformis form
otherwise 品) (乾重計)
specified)

#: New ML for specified food.

*: Relevant standard in Korea is also 0.5mg/kg.
^: Update of ML in existing specified food.
Text in bold and underlined indicate consequential amendments to existing ML for food group in
the Regulations.

20
Published by the Centre for Food Safety, Food and Environmental Hygiene Department
Printed by the Government Logistics Department (12/2024)