CFS 2019 — Guidelines on the Hong Kong Food Adulteration (Metallic Contamination) (Amendment) Regulation 2018

The Hong Kong Centre for Food Safety (CFS) published these Guidelines in 2019 to support trade compliance with the Food Adulteration (Metallic Contamination) (Amendment) Regulation 2018, which was enacted by the Legislative Council in October 2018 and came into operation on 1 November 2019 for fresh food and on 1 November 2020 for all other food. The Amendment Regulation increases the number of regulated metallic contaminants from 7 to 14 (adding barium, boron, copper, manganese, nickel, selenium, and uranium to the existing antimony, arsenic, cadmium, chromium, lead, mercury, and tin) and increases the number of maximum levels (MLs) from 19 to 144 across food groups. The document is the USDA Foreign Agricultural Service GAIN Report HK1922 (Caroline Yuen, prepared; Alicia Hernandez, approved; 20 May 2019) which relays the CFS Guidelines verbatim and adds a short USDA-side highlight summary.

The Guidelines themselves are interpretive rather than tabular: they cover the Amendment Regulation’s purpose, definitions, hierarchy of food groupings (Annex I), the rules for applying MLs to dried/dehydrated/concentrated foods and to compounded foods, sample-portion conventions adopted from Codex, and a Chapter 3 FAQ section. The 144-row Schedule of MLs is referenced as Part 2 of the Schedule to the Amendment Regulation but is not reproduced in full within this PDF; representative extracts (antimony across six food groups; cadmium in rice, leafy vegetables, oyster, and worked examples; lead across produce/seafood/meat, in dried apricot, and in concentrated orange juice; methylmercury in predatory fish) appear in the body text.

Key numbers

Scope of the Amendment Regulation:

• Metals regulated: 14 (up from 7). The seven previously regulated are antimony, arsenic, cadmium, chromium, lead, mercury, and tin; the seven added are barium, boron, copper, manganese, nickel, selenium, and uranium. Column 1 of Part 2 of the Schedule lists 17 entries because arsenic is split into total arsenic and inorganic arsenic and mercury is split into methylmercury, total mercury, and inorganic mercury.
• Maximum levels: 144 (up from 19) for the 14 metals across different food / food groups.
• Penalties: maximum fine HKD 50,000 and six months’ imprisonment for importing, consigning, delivering, manufacturing, or selling any specified food or compounded food containing a specified metal in excess of the ML, or any food containing any metal in an amount dangerous or prejudicial to health.

Effective dates:

• Enacted: October 2018.
• Commencement (fresh food, per Regulation 7): 1 November 2019.
• Commencement (all other food): 1 November 2020.
• Grace period: 1 November 2019 to 31 October 2020 (12 months) for non-fresh food that complied with the pre-Amendment maximum permitted concentrations.

Highlights extracted in the GAIN Report body (USDA-side summary):

The Cd-in-polished-rice ML is lower than the Codex level of 0.4 mg/kg but more lax than the prior Hong Kong level of 0.1 mg/kg; the Cd-in-leafy-vegetables ML aligns with the Codex standard of 0.2 mg/kg but is more lax than the prior Hong Kong level of 0.1 mg/kg. The MeHg-in-predatory-fish ML of 0.5 mg/kg is more stringent than the Codex standard of 1 mg/kg. The lead reduction from a single previous level of 6 mg/kg to category-specific levels ranging from 0.05 to 1.5 mg/kg adheres to the Codex standard.

Antimony Schedule extract (Part 2, Figure 1 of the Guidelines):

Conversion factor for dried, dehydrated, or concentrated forms (Regulation 3(2)(b)):

The ML in a dried, dehydrated, or concentrated form is proportionally adjusted according to the change in metal concentration caused by the process. Worked example (Section 2.11, Example 1, cadmium in dried oyster):

• ML of cadmium in oyster (bivalve molluscs) = 2 mg/kg (fresh-basis ML from the Schedule).
• Water content of fresh oyster = 79.2 to 87.1% (footnote 2: jointly cited to the ASEAN Food Composition Database (Electronic version 1, February 2014), the China Food Composition (Book 1, 2nd Edition), and the Taiwan Food and Drug Administration Food Nutrients & Composition Database).
• Water content of dried oyster sample = 13.1% (laboratory result for the sample).
• Adjusted ML of cadmium in dried oyster = (100% − 13.1%) / (100% − 87.1% to 79.2%) × 2 mg/kg = 8.4 to 13.5 mg/kg.
• “In other words, the cadmium content of the dried oyster sample concerned shall not exceed 13.5 mg/kg.”

Worked example (Section 2.11, Example 2, lead in 10× concentrated orange juice):

• ML of lead in orange juice (fruit juices, other than fruit juices exclusively from berries and other small fruits) = 0.03 mg/kg.
• Concentration factor: 10×.
• Adjusted ML of lead in concentrated orange juice = 0.03 × 10 = 0.3 mg/kg.

Compounded food rule (Regulation 3(4)):

If all ingredients of a compounded food are specified foods, the ML of a specified metal in the compounded food is the sum of the ingredient MLs multiplied by the ingredient proportions by weight. Worked example (Section 2.15, Example 1, cadmium in mixed vegetable salad with 30% sliced cucumber, 50% romaine lettuce, 20% shredded carrot):

• ML of cadmium in cucumber (fruiting vegetables, Cucurbits) = 0.05 mg/kg.
• ML of cadmium in romaine lettuce (leafy vegetables, including Brassica leafy vegetables) = 0.2 mg/kg.
• ML of cadmium in carrot (root and tuber vegetables) = 0.1 mg/kg.
• Adjusted ML = 0.05 × 30% + 0.2 × 50% + 0.1 × 20% = 0.135 mg/kg.

Worked example (Section 2.15, Example 2, lead in dried apricot with sulphur dioxide preservative):

• ML of lead in apricot (fruits, other than cranberry, currants, and elderberry) = 0.1 mg/kg.
• Sulphur dioxide is not considered an ingredient under Regulation 3 because it is used as an additive.
• The lead content of the dried apricot sample is compared against the 0.1 mg/kg ML for apricot with application of the appropriate water-content conversion factor (Section 2.13).

Hierarchy of food groupings (Annex I):

• Cereals: cereal grains (rice, wheat, maize, etc.); husked and polished rice (milled cereal products, early milling stages); wheat flour and maize flour (cereal grain milling fractions); others (wheat bran, wheat wholemeal, rye flour, etc.).
• Fruits: berries and other small fruits (cranberry, currants, elderberry, etc.); citrus fruits; pome fruits; stone fruits; assorted tropical and sub-tropical fruits — edible peel; assorted tropical and sub-tropical fruits — inedible peel.
• Vegetables: bulb vegetables; Brassica vegetables, other than Brassica leafy vegetables; fruiting vegetables, Cucurbits; fruiting vegetables, other than Cucurbits; leafy vegetables (including Brassica leafy vegetables); legume vegetables; pulses; root and tuber vegetables; stalk and stem vegetables; edible fungi; vegetables unless otherwise specified (cadmium only: applies to edible fungi and tomato).
• Aquatic animals: fish; bivalve molluscs (oyster, mussel, scallop, cockle, etc.); cephalopods (cuttlefish, octopus, squid, etc.); crustaceans (crab, prawn, shrimp, lobster, mantis shrimp, bay lobster, crayfish, etc.); gastropods (abalone, conch, etc.); others (sea cucumber, sea urchin, etc.).

Codex sample-portion conventions adopted (Table 1, Section 2.20): the ML applies to and is analysed in defined edible portions (e.g., berries — whole commodity after removal of caps and stems; pome fruits — whole commodity after removal of stems; stone fruits/dates/olives — whole commodity after removal of stems and stones with the level expressed on the whole commodity without stem; pineapple — whole commodity after removal of crown; potato — peeled potato; head cabbages — whole commodity as marketed after removal of decomposed or withered leaves; cauliflower and broccoli — flower heads only).

Risk-assessment provision (Section 2.16, Regulation 3AA): for food / food groups without relevant MLs under the Amendment Regulation, CFS continues to conduct risk assessment to determine whether the food contains the metal concerned in an amount dangerous or prejudicial to health. Section 54 of the Public Health and Municipal Services Ordinance (Cap. 132) requires that all food for sale in Hong Kong be fit for human consumption.

Methylmercury screening permission (Section 9 FAQ): for MLs expressed as methylmercury, the trade may screen by analysing total mercury. If total mercury ≤ the methylmercury ML, no further testing is required and the sample is deemed compliant. If total mercury > the methylmercury ML, further testing is necessary to determine methylmercury specifically. The same principle is permitted for inorganic arsenic screening against total arsenic.

Methods (brief)

Not an analytical study. The Guidelines describe Hong Kong’s regulatory framework for metallic contamination in food and provide interpretive rules for applying MLs. The underlying methodological basis cited in the Guidelines (Section 2.18) is JECFA’s evaluations of metallic contaminants and the health-based guidance values (HBGVs) JECFA has established. CFS draws on JECFA assessments, Codex Alimentarius Commission MLs (adopted unless otherwise specified), and domestic risk assessment data from the Hong Kong Population-based Food Consumption Survey (2005–2007; the Second Survey commenced April 2018) and from the Hong Kong Total Diet Study series. Sample-portion conventions and food classifications follow Codex (CAC/MISC 4-1993, Codex Classification of Foods and Animal Feeds, Second Edition, with 2012 fruit and 2017 vegetable revisions not yet incorporated in the Guidelines’ classification document).

Laboratory testing methods are not prescribed by the regulation. CFS notes (FAQ Question 9) that laboratories may develop testing methods by reference to international or national technical criteria and reference testing methods, and that further guidance for inorganic arsenic and methylmercury determination is available on the CFS and Government Laboratory (GL) websites. The sampling level for surveillance is via the Food Surveillance Programme at import, wholesale, and retail.

Implications

For the wiki regulations layer, this document is one of two anchor citations for any wiki claim about Hong Kong’s current metallic-contaminant regulatory framework: it gives the regulation’s effective dates, the 14-metal/144-ML scope, the compounded-food and dried-food adjustment rules, the methylmercury-by-total-mercury screening permission, and the antimony Schedule extract. The full 144-row Schedule itself lives in the Amendment Regulation (Cap. 132V sub. leg.) which is the authoritative ML source; the Guidelines reproduce only a subset of rows in worked examples. Any wiki page that claims a specific HK ML for a metal-in-food pair should cite the underlying regulation, not this Guidelines document, except where the worked examples here are the only place the rule’s interpretation is explicit (dried-oyster proportional adjustment; mixed-salad weighted-average compounded ML; concentrated-juice multiplication).

For courses: a worked example of how a jurisdiction can adopt Codex MLs as a baseline while diverging tighter (methylmercury in predatory fish at 0.5 mg/kg vs Codex 1 mg/kg) or more lax (cadmium in polished rice at 0.2 mg/kg vs the predecessor HK 0.1 mg/kg) on a case-specific risk-assessment basis. The compounded-food weighted-average rule is a pedagogically useful contrast to single-ingredient ML enforcement.

For the app: this source supplies regulatory ML inputs, not occurrence concentration data, and is not suitable for the contamination_profile per-cell occurrence format. App use would be limited to “Hong Kong currently regulates this metal in this food group at this ML” lookup statements derived from the underlying Schedule.

Wiki pages this source may touch

• antimony
• arsenic
• arsenic-inorganic
• arsenic-total
• barium
• cadmium
• chromium
• copper
• lead
• manganese
• mercury
• mercury-methyl
• mercury-total
• nickel
• tin
• uranium
• cereals
• rice
• vegetables
• leafy-vegetables
• fruits
• fish
• seafood
• shellfish
• molluscs
• meat
• eggs
• milk-and-dairy
• fruit-juice
• fish-marine-predatory
• fish-marine-non-predatory
• canned-fish
• canned-vegetables
• canned-fruit
• rice-bulk-grain
• fruit-juices-non-apple

Verification notes

Fresh ingest 2026-06-09 from raw/Manual Fetch Kimi /June 8/Kimi_Agent_Download Corruption Issue/_extracted_condiments2_05_Snacks_Canned_Prepared/05_Snacks_Canned_Prepared/HongKong_Guidelines_Metallic_Contamination.pdf (sha256 2fb3cd46f5287f3ce10c12ba5a147e9c61e92c503508677cb9fefaccb8daf125, 21 pages).

• The PDF is the USDA FAS GAIN Report HK1922 (20 May 2019), prepared by Caroline Yuen and approved by Alicia Hernandez, which relays the Hong Kong Centre for Food Safety Guidelines on the Food Adulteration (Metallic Contamination) (Amendment) Regulation 2018 verbatim and adds a short USDA-side highlight summary. The primary authorship credit is recorded as CFS because the Guidelines content is reproduced verbatim from the CFS publication; the USDA wrapper is recorded in publication and license.
• Distinct from existing cfs2013-hktds-metallic-contaminants (the First Hong Kong Total Diet Study Report No. 5, 2013, an occurrence/exposure study) and cfs2012-hktds-inorganic-arsenic (TDS Report No. 2, 2012). Both are cross-linked under related_sources because the Guidelines reference the Hong Kong Population-based Food Consumption Survey and Total Diet Study results as the domestic risk-assessment basis for the new MLs.
• metals array enumerates all 14 metals regulated under the Amendment Regulation plus the speciation distinctions the regulation itself recognises: arsenic as tAs and iAs, mercury as MeHg and tHg (inorganic mercury is also a Column 1 entry in the source but is not separately routed because the wiki abbreviation vocabulary does not currently include an iHg slug; the routing for inorganic mercury is captured under tHg and the Verification notes flag this for any future synthesis pass that needs to disambiguate).
• products and ingredients are kept broad per CLAUDE.md Part 5b (“If a source touches infant formula generally without specifying soy vs non-soy, the frontmatter should say matrices: [infant-formula], not matrices: [infant-formula-powder-non-soy]. The routing layer fans broad scopes out to sibling pages; the model does not pre-decide that fan-out by overspecifying frontmatter.”). The Guidelines apply to all food sold in Hong Kong; only the food groups explicitly named in the body text (cereals/rice, leafy vegetables, fish/predatory fish, oyster as bivalve mollusc, orange juice as fruit juice, apricot as fruits, cucumber/lettuce/carrot in worked examples) are included.
• No regulations/ slug exists yet for the Hong Kong Food Adulteration (Metallic Contamination) Amendment Regulation 2018 (Cap. 132V sub. leg.). Per CLAUDE.md Part 10 and the manual-fetch skill’s stop-condition for new regulation slugs (“Regulations have hard agency identifiers; surface in stop-report so the regulation page can be created with the correct rule ID/citation, do not guess”), the regulation page is not auto-created here. Surfacing for Karen: proposed slug hk-fadmc-amendment-2018 with title “Hong Kong Food Adulteration (Metallic Contamination) (Amendment) Regulation 2018 (Cap. 132V sub. leg.)” and citation anchor “Legislative Council, Hong Kong SAR, October 2018; in force 1 November 2019 (fresh food) and 1 November 2020 (all other food)“.
• Brand-firewall scan (CLAUDE.md Part 12): no brand names present. Only generic food-form descriptors (polished rice, leafy vegetables, predatory fish, dried oyster, concentrated orange juice, mixed vegetable salad, dried apricot, cucumber, romaine lettuce, carrot, apricot) and methodological references (ASEAN Food Composition Database, China Food Composition Book, Taiwan Food and Drug Administration Food Nutrients & Composition Database, Korean Standard Food Composition Table, Japan Standard Tables of Food Composition; these are reference databases, not branded foods, and fall under Exception 2 of the Part 12 strict reading).
• Wiki/HMTc-firewall scan (CLAUDE.md Part 2): the page reports what the Guidelines say, not how Hong Kong’s MLs compare to HMTc thresholds. The “Codex aligns” / “more stringent than Codex” / “more lax than the prior HK level” comparisons in the Key numbers table are reproduced from the GAIN Report and the Guidelines’ own framing, not introduced as wiki synthesis. The ## Implications section flags that any wiki page citing a specific HK ML should cite the underlying regulation (Cap. 132V sub. leg.), not this Guidelines document, except where the Guidelines are the only place a rule’s interpretation is explicit.
• Numerical fidelity: all numeric values in ## Key numbers are present on PDF pages 2 (highlight summary), 3 (overview of metals and MLs counts), 6 (antimony Schedule extract), 8–9 (dried-oyster worked example), 10 (concentrated-orange-juice worked example), 11 (dried-apricot worked example), 11 (mixed-salad worked example), 14 (12-month grace period), and 17 (HKD 50,000 / six months’ penalty).
• Audit subagent (2026-06-09) findings and resolution:
  • Check 1 ⚠️ on Note 3 paraphrase (auditor: wiki dropped “other” from “gonads, liver and other digestive organs”). Verified against source page 7, Figure 2 — auditor correct. Note 3 cell in the antimony Schedule extract table corrected to “including the gonads, liver and other digestive organs, after removal of shell and gills.”
  • Check 1 ⚠️ on water-content attribution (auditor: wiki attributed 79.2–87.1% solely to ASEAN; source footnote 2 jointly cites three databases). Verified against source page 8, footnote 2 — auditor correct. Cited the three databases jointly (ASEAN Food Composition Database Electronic version 1, February 2014; China Food Composition Book 1, 2nd Edition; Taiwan Food and Drug Administration Food Nutrients & Composition Database).
  • Check 2 ❌ on [[ingredients/seafood]], [[ingredients/shellfish]], [[ingredients/molluscs]] (auditor: not in ingredients snapshot). Verified by ls wiki/ingredients/ and by re-grepping the taxonomy-snapshot.md ingredients block: all three slugs exist in both the live directory (wiki/ingredients/seafood.md, wiki/ingredients/shellfish.md, wiki/ingredients/molluscs.md) and the snapshot’s comma-separated ingredients list (lines containing “seafood,seaweed,…”, “shellfish,skim-milk,…”, and “molluscs,non-apple-fruit,…”). The auditor produced three false positives. No change applied. The fact that the routing audit ran clean against the live wiki/ingredients/ taxonomy and emitted 13 routing rows confirms the slugs are valid.
  • Check 2 ⚠️ on iHg routing (auditor: regulation enumerates inorganic mercury but wiki vocabulary collapses it into tHg). Confirmed; left as documented limitation in the prior verification-note bullet. No change applied; flagged for any future synthesis pass that needs to disambiguate iHg.
  • Check 2 ⚠️ on matrices: [regulation, ...] (auditor: regulation as a matrix value is unusual for a regulatory document). Reviewed; regulation is the appropriate matrix tag for a regulatory-document source where the “matrix” is the regulatory instrument itself rather than a sampled food. Other matrix tags (fish, vegetable, fruit, etc.) capture the food groups the regulation explicitly references. No change applied.
  • Checks 3, 4, 5 returned ✅ clean.
  • Audit subagent verdict: REVISE. Two ⚠️ corrections applied; three ❌ false positives rejected with verification.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.