Food Safety Focus (221st Issue, December 2024) – Article 1
Metallic Contaminants in Food Part III – Proposed Changes to the Food Adulteration (Metallic Contamination) Regulations
Reported by Dr. Gloria SZE, Chemist, Risk Assessment Section,
Arthur YAU, Scientific Officer, Risk Communication Section,
Centre for Food Safety
After examining the presence and impact of lead, cadmium and methylmercury in food on health in the earlier articles in this series, we will now focus on the upcoming changes to the regulatory level of heavy metals in food.
Metals such as lead, cadmium, and methylmercury are naturally found in the environment and can enter our food supply through various means. For many people, diet is an important source of exposure to these harmful substances. 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.
Proposed Amendments
Currently, Hong Kong's Food Adulteration (Metallic Contamination) Regulations have established maximum levels for 14 types of metallic contaminants in various types of food. The Government conducted a review on the Regulations with a view to better protecting public health, facilitating effective regulation and promoting harmonisation between local and international standards. The proposed amendments to the Regulations aim to keep abreast of international development on maximum levels (MLs) of metallic contaminants in food. Twenty-seven new MLs for specified metal in specified food (food pair) are proposed to be added and 9 MLs for existing food pairs are proposed to be updated in the Regulations, with reference to latest standards of Codex Alimentarius Commission (Codex) and major food importing places. The total number of MLs will increase from 144 to 171 in Part 2 of the Schedule to the Regulations.
Figure 1: Examples of the food types involved in the proposed amendments to the Food Adulteration (Metallic Contamination) Regulations. The complete list of proposed changes is available in the annexes to this paper.
New Standards Based on International Guidelines
Among the proposed 27 new MLs, reference has been made to the Codex standards for metals like lead, cadmium and methylmercury for 16 of them. Chocolate and cocoa powder and fish are among the foods that have newly established MLs. For instance, the proposed MLs for cadmium in cocoa powder and various chocolates range from 0.3 to 2.0 mg/kg, while for methylmercury in six specified species of fish range from 0.8 to 1.7 mg/kg, in accordance with international recommendations. Meanwhile, reference has been made to relevant standards such as the Chinese GB, Korea standards, etc. with regard to the remaining 11 of the new MLs. After taking into consideration local consumption patterns and the major sources of food imports, new MLs are proposed for certain types of edible mushrooms, sugars and sugar syrups.
In addition, nine existing MLs will be updated with reference to Codex and Mainland standards. This includes adjustments in the MLs for lead and cadmium in foods like edible offal, salts, fat spreads and other non-specified edible fungi.
Local Context and Health Considerations
The Centre for Food Safety (CFS) has been monitoring the latest international developments in food safety standards closely, and these proposed changes have already considered local consumption patterns and results of risk assessments. The CFS will continue to provide dietary advices to the local population, susceptible groups in particular, in order to reduce their exposure to metallic contaminants from food.
Assessment on Implications on Food Supply
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 food pairs in this amendment exercise, we have taken into account Codex’s ALARA (As Low as Reasonably Achievable) 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).
Public Consultation
A two-month public consultation commenced on 16 December 2024. Consultation forums will be conducted, providing opportunities for members of the public, stakeholders and the industry to voice their opinions and concerns regarding the proposed changes. The details are available on the CFS website.
Transition to New Standards
A transitional period will be provided for food businesses to comply with the new and updated standards. During this time, food items can either comply with the existing or the revised regulations wholly, but not a combination of both. This can provide flexibility to the trade to ensure a smooth transition.