Scope
Cap. 132V is subsidiary legislation under section 55(1) of the Public Health and Municipal Services Ordinance (Cap. 132). It prohibits the import, consignment, delivery, manufacture, or sale for human consumption of any specified food, or compounded food, that contains a specified metal above the maximum level set for that metal in that food in Part 2 of the Schedule. A separate provision prohibits food containing any metal in an amount that is dangerous or prejudicial to health, independent of the tabulated maxima. The loaded rows are the Part 2 Schedule “Maximum Level of Metal in Food” as consolidated on 5 September 2025, amended through L.N. 140 of 2025.
Exact limit and units
Part 2 tabulates maximum levels in mg/kg for seventeen metals across a granular list of foods. HMI records the 163 current rows whose metals map to the tracked species vocabulary: antimony, arsenic expressed as total arsenic, arsenic expressed as inorganic arsenic, cadmium, chromium as total chromium, lead, mercury expressed as methyl-mercury, mercury expressed as total mercury, mercury expressed as inorganic mercury, nickel, tin, and uranium. Barium, boron, copper, manganese, and selenium rows are present in the Schedule but are not loaded because they fall outside the vocabulary. Source values in mg/kg are normalized to ug/kg in the structured register (mg/kg multiplied by 1000).
The Schedule is more granular than most national contaminant tables. Lead alone carries sixty-two rows, cadmium thirty-nine, spanning species-level mushroom rows, cocoa-solids-tiered chocolate, canned foods, tea and coffee, salt from marshes as distinct from other food-grade salt, and dedicated infant-formula and complementary-food rows. Representative anchor values, in the source unit of mg/kg, are below; the full 163-row schedule with per-row basis and note text is held in the structured register.
| Metal | Food | Maximum level (mg/kg) |
|---|---|---|
| Lead | Infant formula and follow-up formula (reconstituted, ready to drink) | 0.01 |
| Lead | Cereal-based food for persons under 36 months | 0.02 |
| Lead | Canned fruits; canned vegetables | 0.1 |
| Lead | Sugar-based candies and honey | 0.1 |
| Lead | Coffee beans | 0.5 |
| Lead | Tea, Green, Black | 5 |
| Cadmium | Leafy vegetables (including Brassica leafy vegetables) | 0.2 |
| Cadmium | Shiitake mushrooms (Lentinula edodes) | 0.5 |
| Cadmium | Cocoa powder, 100% cocoa solids, dry-matter basis | 2 |
| Cadmium | Chocolate, less than 30% total cocoa solids, dry-matter basis | 0.3 |
| Arsenic (inorganic) | Husked rice | 0.35 |
| Arsenic (inorganic) | Polished rice | 0.2 |
| Mercury (methyl-mercury) | Fish, general | 0.5 |
| Mercury (methyl-mercury) | Marlin | 1.7 |
| Tin | Canned food, other than canned beverages | 250 |
| Tin | Canned beverages | 150 |
Basis rules travel with each row and are not conflated. Regulation 3(3) applies each maximum to the edible portion of the food, or to the portion or form named in a Schedule note. Regulation 3(2)(b) requires the maximum for a food that has been dried, dehydrated, or concentrated to be adjusted proportionally to the change in concentration caused by the process. Meat, offal, and aquatic-animal rows apply after specified removals of bone, fat, digestive tract, shell, gills, or viscera. Cocoa and chocolate rows are stated on a dry-matter basis. The Note 12 dried-fungi rows apply to product in dried form. Beverage, milk, secondary-milk-product, and infant-formula rows apply to product that is, or is reconstituted to be, ready to drink; these are recorded as as-consumed, while the solid-food rows are recorded as as-sold.
How tested
The Schedule sets maximum levels and the associated edible-portion and basis rules. It does not print a metal-specific analytical method in the Schedule text.
Enforcement posture
Contravention of the maximum-level prohibition or the dangerous-or-prejudicial-to-health prohibition is an offence carrying a fine at level 5 and imprisonment for six months. The maxima do not apply to food that is air-transit or air-transhipment cargo unless it is removed from the cargo transhipment area of the airport. The Director of Food and Environmental Hygiene may amend the maximum levels by notice in the Gazette, and prosecutions may be brought in the Director’s name.
History of changes
The regulation commenced on 27 May 1983. The former First and Second Schedules stated broad maxima by food form, for example a tin limit of 230 mg/kg for all food in both solid and liquid form, lead at 6 mg/kg for solid food and 1 mg/kg for liquid food, and mercury at 0.5 mg/kg for all food. L.N. 113 of 2018 repealed and substituted the Schedule with the current granular per-food table, removing the general non-canned tin limit and setting tin at 250 mg/kg for canned food other than canned beverages and 150 mg/kg for canned beverages. L.N. 140 of 2025 further amended the Schedule and its notes, adding the dried-form and reconstituted-basis notes, with a grace period for existing stock running from 5 September 2025 to 5 March 2027. The pre-2019 tin value is retained in the structured register as a superseded historical row so that the requirement in force before L.N. 113 of 2018 can be reconstructed for any date. The local PDF is the e-Legislation verified copy consolidated 5 September 2025.
How it compares
Cap. 132V does not tighten any value that already binds in the register, and it introduces no new strictest-sovereign floor for the major certification cells. It does two useful things. First, it adds a second or third concurring sovereign to several rows, which strengthens the pooled basis without moving the number: lead in honey at 0.1 mg/kg matches the Israeli limit; lead in canned fruits and canned vegetables at 0.1 mg/kg matches Thailand, the GCC Standardization Organization, and Israel; lead in canned chestnuts at 0.05 mg/kg matches Thailand and the GCC; lead in roasted coffee beans at 0.5 mg/kg matches the Mercosur value; and lead in cultivated common, oyster, and shiitake mushrooms at 0.3 mg/kg matches the European Union and others. Second, it fills lookup gaps for ready-to-drink beverages that other sovereigns leave unregulated on an as-consumed basis, notably a lead maximum of 0.2 mg/kg for reconstituted coffee and tea beverages.
Where Cap. 132V is looser than an existing sovereign it does not bind and does not change any cell. Its tin maxima of 250 and 150 mg/kg sit above the European Union values of 200 mg/kg for canned food and 100 mg/kg for canned beverages, so tin is unchanged. Its cadmium maxima for cultivated and wild fungi, from 0.2 to 2 mg/kg, sit above the European Union values of 0.05 mg/kg for common cultivated fungi and 0.15 mg/kg for oyster and shiitake, so fungi cadmium is unchanged. Its cocoa-solids-tiered chocolate cadmium maxima sit at or above the European Union tiers, so chocolate cadmium is unchanged. Its lead maxima for wild mushrooms and for tea leaf, at 1 and 5 mg/kg, sit above the Paraguay and Thailand values, so those cells are unchanged.
Sources
Update history
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