Import Surveillance and Control
4.1 What are the import restrictions on Japanese foods? What measures would the Centre for Food Safety (CFS) take to ensure food safety?
Vegetables, fruits, milk, milk beverages, and dried milk originating in Fukushima are prohibited from being imported into Hong Kong, whereas such foods originating in the four prefectures surrounding Fukushima, namely Chiba, Tochigi, Ibaraki, and Gunma, are permitted to be imported with a radiation certificate and an exporter certificate issued by the Japanese authority. Chilled or frozen game, meat, poultry, and poultry eggs from the above five prefectures are allowed to be imported if accompanied by a radiation certificate issued by the Japanese authority proving that the radiation levels do not exceed the Codex Guideline Levels. All aquatic products harvested, manufactured, processed, or packed in the ten metropolises/prefectures of Tokyo, Fukushima, Chiba, Tochigi, Ibaraki, Gunma, Miyagi, Niigata, Nagano, and Saitama are prohibited from being imported into Hong Kong, including live, chilled, frozen, dried, or otherwise preserved aquatic products, sea salt, and raw or processed seaweeds.
Two levels of gatekeeping are involved under the current arrangement. At export level, the Japanese authority which issues the radiation certificates and exporter certificates must ensure that each consignment of those products do not come from Fukushima and attest that the radiation levels of the food products do not exceed the Codex levels as well as the more stringent Japanese levels. At the import level, CFS will continue to conduct radiation tests on food products imported from Japan, and subsume the radiation testing on Japanese food under the routine annual food surveillance programme starting from 1 January 2021. CFS has gradually stepped up testing of food products imported from Japan since mid-April 2023, especially increasing the testing of aquatic products and the measurement of specific radionuclides.
CFS's situation update of radiation tests on food imported from Japan
4.2 What are the factors that the Centre for Food Safety (CFS) has taken into account when updating the import control on Japanese foods?
In response to the Fukushima nuclear incident, the CFS has immediately stepped up surveillance on radiation levels of food products imported from Japan to safeguard food safety. The CFS has been reviewing the risk management measures on food products imported from Japan in the light of the latest situation. Ensuring food safety is the Government's prime consideration. Other factors taken into account include local surveillance results, assessments made by international expert organisations, surveillance results of the Japanese Government, the latest position of import control on Japanese food by other economies, consistency of the control measures with the World Trade Organization's requirements1 and public concern, etc..
1 World Trade Organization's Sanitary and Phytosanitary Agreement stipulates that when establishing or maintaining sanitary or phytosanitary measures to achieve the appropriate level of sanitary or phytosanitary protection, Members shall ensure that such measures are not more trade restrictive than required to achieve their appropriate level of sanitary or phytosanitary protection, taking into account scientific evidence, relevant inspection, sampling and testing methods, technical and economic feasibility, etc..
4.3 What is the measurement for radioactive substances in foodstuffs?
The level of radionuclides in foodstuffs is presented as activity per unit volume or per unit mass. The activity is the number of disintegrations per unit time taking place in a radioactive material. The unit of measurement is Becquerel (Bq) in which one Becquerel equal to one radioactive disintegration per second.
For example, the guideline level established by Codex Alimentarius Commission for caesium-137 in infant foods is 1000 Bq/kg.*
*For multiple radionuclides, the activity concentrations of each radionuclide within the same group should be added together.
4.4 What is the testing procedure?
Consignments will be initially screened by the CFS staff using Hand-held survey meters .Sample will then be taken for screening using the Contamination Monitoring System (CMS). Sample with reading beyond the limits will be sent to Government Laboratory (GL) for further quantitative analysis of Iodine-131, Caesium -134 and Caesium -137. Besides, additional samples will also be sent to GL for test.
4.5 What are the criteria adopted at present in testing the level of radioactive contamination in Japanese food products, and the measures to be adopted when some food products are found to have a level of radioactive contamination exceeding the normal standard?
CFS currently adopts the standards laid down by the Codex Alimentarius Commission, which are international standards, in the Guidelines Levels for Radionuclides in Food following Accidental Nuclear Contamination in testing the radiation levels of food. Relevant radionuclides include iodine-131 (100 Bq/kg), caesium-134 and caesium-137 (1,000 Bq/kg), etc, which are most closely associated with health risks.
If a consignment of food is tested to have exceeded the contamination standard, the Food and Environmental Hygiene Department will immediately detain that consignment and arrange for disposal. According to Codex, when radionuclide levels in food do not exceed the corresponding guideline levels, the food should be considered as safe for human consumption.
4.6 It has been circulating on the internet that "the US Food and Drug Administration (FDA) has issued Import Alert #99-33 to prohibit the import of Japanese food products due to radionuclide contamination. The food products include milk, butter, dried milk , milk-based infant formula and other milk products, vegetables and vegetable products, rice, whole grain, fish, meat and poultry, venus clams, sea urchin, yuzu fruit, kiwi fruit. So it is better not to eat them!" Does Hong Kong's import control of Japanese foods suffice? Is it more lenient than other countries?
Export control measures adopted in Japan
After the incident at Tokyo Electric Power Company's Fukushima Daiichi Nuclear Power Station (Fukushima incident) in March 2011, the Japanese Government has instituted a series of remedial measures to ensure the safety of domestic and exported food supplies, such as tightening the regulatory limits of radionuclide levels in food, monitoring of food and materials for agricultural production, restricting distribution of food products with radionuclide levels that exceed the regulatory limits, as well as decontamination of farmland. For details, please refer to website of Ministry of Health, Labour and Welfare of Japan.
Import control of Japanese food products by the United States (US)
In the wake of the Fukushima incident, individual country / region has implemented measures deemed fit to the local circumstances and risk assessment results. As such, the number of prefectures and categories of food products covered under their import control measures may differ from those implemented in Hong Kong. In the US, for example, the Food and Drug Administration (FDA) imposed import restriction on Japanese foods (Import Alert 99-33) by making reference to the list of food products that were restricted from export by the Japanese Government based on Japan's food surveillance results. In other words, the Japanese food products and prefectures subject to import restrictions in the US mirrored the export prohibition measures taken by Japan. However, the US FDA deactivated Import Alert 99-33 and lifted the import control measures on Japanese foods products since September 2021.
Import control of Japanese food products by the Centre for Food Safety (CFS)
Currently, apart from the food items that are restricted from export by the Japanese authorities (the list can be found on the website of Ministry of Health, Labour and Welfare of Japan), Hong Kong has banned all vegetables and fruit, milk, milk beverages and dried milk from Fukushima according to the Order issued by the Director of Food and Environmental Hygiene on 20 July 2018. Vegetables, fruits, milk, milk beverages and dried milk from the four prefectures (namely Ibaraki, Tochigi, Chiba and Gunma) are allowed to be imported with the conditions that they are accompanied by both a radiation certificate and an exporter certificate issued by the Japanese authority. Moreover, all chilled or frozen game, meat and poultry, poultry eggs and live, chilled or frozen aquatic products from those five prefectures may be imported into Hong Kong only if accompanied by a certificate issued by competent authority of Japan certifying that the radiation levels do not exceed the Codex Guideline Levels. Also, according to the Order issued by the Director of Food and Environmental Hygiene on 23 August 2023, all aquatic products harvested, manufactured, processed, or packed in the ten metropolises/prefectures of Tokyo, Fukushima, Chiba, Tochigi, Ibaraki, Gunma, Miyagi, Niigata, Nagano, and Saitama are prohibited from being imported into Hong Kong, including live, chilled, frozen, dried, or otherwise preserved aquatic products, sea salt, and raw or processed seaweeds. The CFS will continue to monitor the latest development from international and Japanese authorities, and follow up on the restrictions on Japanese food imports in due course.
4.7 It is said that some importers would deliberately change the labels of origin for foods imported from Japan so as to avoid disclosing the prefectures of origin of the food products. How can the Government perform its gate-keeping role?
For prepackaged food, as stipulated in Cap. 132W of the Laws of Hong Kong, it shall be legibly labelled with the following particulars for consumers’ information or enquiries:
(a) the full name and address of the manufacturer or packer; or
(b) (i) an indication of its country of origin, (ii) the name of the distributor in Hong Kong and (iii) the address of the distributor in Hong Kong.
While the legislation does not further require specification of the prefecture of origin of the food product, the safety of Japanese food imports is protected as the Centre for Food Safety (CFS) conducts testing (including radiation tests) on foods imported from Japan under its Food Surveillance Programme (FSP). We will adjust the FSP in response to changes in the external environment such as increasing the quantities and types of food items for testing to safeguard food safety.
In 2011, the CFS began to implement additional control and surveillance measures on food products imported from Japan. Since then, the CFS has tested more than 750 000 samples of imported Japanese food products. None of the samples was found with radiation levels exceeding the guideline levels of the Codex Alimentarius Commission and no incorrect/false labelling was identified.