Frequently Asked Questions (Trade)

Products Affected

Q1. Which types of lard/ lard products were involved in this incident?
Q2. Which types of food products may be involved in this incident?
Q3. I have consumed the food specified in the Food Safety Order, any adverse health effect will be anticipated?

Food Safety Order

Q4. Why there is a need to issue the Food Safety Order for this incident?
Q5. Why does the Food Safety Order cover the lard/lard products produced by Chang Guann Co. Ltd in Taiwan and food products made with the affected lard/lard products on or after 1 March 2014?
Q6. I am the importer involved in Food Safety Order, what should I do?
Q7. I am the distributor involved in Food Safety Order, what should I do?
Q8. I am the retailer involved in Food Safety Order, what should I do?

Control of Oil Products

Q9. How does the CFS test and identify the cooking oil made by "gutter oil"?
Q10. Is there any international, regional or national regulation on B[a]P in edible oil?
Q11. What is the action level for B[a]P in edible oil set by the CFS?
Q12. Why does the CFS set 10 μg/kg as the action level for B[a]P in edible oil?
Q13. Can the action level of B[a]P in edible oils be applied to fat?
Q14. What are the follow-up actions taken by the CFS against edible oil samples found to exceed the action level i.e. 10μg/kg for B[a]P?
Q15. PAHs are a group of substances. Why does the CFS set action level for B[a]P only?

Benzo[a]pyrene and Health

Q16. What is gutter oil?
Q17. What is Benzo[a]pyrene?
Q18. Does the existence of B[a]P in oil mean that the oil is "gutter oil"?
Q19. What amount of B[a]P consumed will be harmful to health?

Advice to the Trade

Q20. How could the trade ensure the food safety of their cooking oil or food products?

Products Affected

Q1 Which types of lard/ lard products were involved in this incident?
A1 Taiwan authorities detected "substandard lard" and the use of it in the production of food for sale in Taiwan market. According to the existing information from the Taiwan authorities, various lard/lard products produced on or after 1 March 2014 by Chang Guann Co., Ltd (Chang Guann) in Taiwan were involved.
Q2 Which types of food products may be involved in this incident?
A2 According to the existing information from the Taiwan authorities, the incident may involve a wide spectrum of food trade and food. The Taiwan authorities had released a list of affected products in their website. Relevant information had been uploaded onto the Centre for Food Safety (CFS) website. The public may pay attention to the information published on the website to keep update to the incident.

In Hong Kong, the Maxim's Cakes had used the incriminated lard 「全統香豬油」 produced by the Chang Guann Co., Ltd in making its pineapple buns. The vendor concerned had taken the affected product off the shelves and stopped using the incriminated lard. Besides, two kinds of products manufactured by Wei Chuan Foods Corporation with substandard lard had been exported to Hong Kong. The CFS has alerted the trade to stop sale of these products and issued a food alert on the products.

Q3 I have consumed the food specified in the Food Safety Order, any adverse health effect will be anticipated?
A3 According to existing information from the Taiwanese authorities and the reported analytical test results from the CFS (including benzo[a]pyrene, aflatoxins and metallic contaminants), the risk assessment from the CFS showed that the food safety risk might be increased if consuming the specified food. Nevertheless, the risk is considered to be not high and there is no cause for undue concern.

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Food Safety Order

Q4 Why there is a need to issue the Food Safety Order for this incident?
A4 According to the information from the Taiwanese authorities, the substandard lard/lard products from Chang Guann were produced from substandard ingredients such as recycled waste oils and lard for animal feeds. Since the lard/lard products so produced are subject to contamination by harmful substances such as Benzo[a]pyrene, aflatoxins and metal contaminants, and possibly pose risks to public health, the CFS decided to issue an Order in accordance with section 30(1) of the Food Safety Ordinance (Chapter 612) to prevent and reduce a possibility of danger to public health.
Q5 Why does the Food Safety Order cover the lard/lard products produced by Chang Guann Co. Ltd in Taiwan and food products made with the affected lard/lard products on or after 1 March 2014?
A5 The incident of "sub-standard lard" from Taiwan was first reported by Taiwan authorities on 4 September 2014. On 11 September 2014, the Taiwan authorities announced that in addition to the initially affected lard "全統香豬油(合將香豬油)", another 24 lard/lard products produced by CHANG GUANN Co. Ltd in Taiwan might have been contaminated. These products have been impounded by the Taiwan authorities. In addition, the risk assessment from the CFS showed that the food safety risk might be increased if consuming the affected lard/lard products and the food products made with the affected lard/lard products. In the light of the above reasons and in order to protect public health, the Food Safety Order covers the lard/lard products produced by Chang Guann Co. Ltd in Taiwan and all food products made with the affected lard/lard products in Hong Kong and Taiwan on or after 1 March 2014.
Q6 I am the importer involved in Food Safety Order, what should I do?
A6

If you are the importer involved in Food Safety Order, you should:

  1. Immediately conduct a stock take of the storage facilities and isolate any remaining stock of the food specified in Food Safety Order.
  2. Set up telephone enquiry service to handle enquiries related to recall of the food specified in Food Safety Order as soon as possible.
  3. Immediately notify all known distributors of the recall and its arrangement.
  4. Inform FEHD (Email: dmylam@fehd.gov.hk, Fax: 2776 5226), upon commencement of recall, of detailed description of the products to be recalled and the recall period.
  5. Display posters of not less than A4 size (21cm x 30cm) at a conspicuous location on the importer's premises. The posters shall have:
    1. the heading ‘Food/Product's Name – Recall Announcement';
    2. the description and brand (if any) of the food;
    3. picture(s) of the food;
    4. details of the recall arrangement (such as period of recall, place of recall or return of the food);
    5. the full name, address and telephone number of the recalling importer; and
    6. the telephone enquiry service for the recall.
  6. Retract the food concerned returned by distributor(s), retailer(s) or consumers. Report to FEHD within two working days upon completion of recall for advice on final disposal of the recalled food and any remaining stock.
  7. Submit report to FEHD within one week from the date of completion of recall, and the report should contain the following information:
    1. the names of the companies, organizations or persons from whom the food was returned;
    2. the description of the recalled food and the amount of the food returned;
    3. the description and amount of any remaining stock;
    4. a reconciliation between the delivered and recovered quantities of the food, as well as the stock in hand; and
    5. the final disposal of the returned food and any remaining stock.
Q7 I am the distributor involved in Food Safety Order, what should I do?
A7 If you are the distributor involved in Food Safety Order, you should:
  1. Immediately conduct a stock take of the storage facilities, isolate any remaining stock of the food specified in Food Safety Order and return the food concerned to the supplier.
  2. Set up a telephone enquiry service to handle enquiries related to recall of the food specified in Food Safety Order as soon as possible.
  3. Immediately notify all known retailer(s) and consumers of the recall and its arrangement.
  4. Inform FEHD (Email: Food_Recall_Notification@fehd.gov.hk, Fax: 2521 4784), upon commencement of recall, of detailed description of the products to be recalled and the recall period.
  5. Display posters of not less than A4 size (21cm x 30cm) at a conspicuous location on the distributors' premises. The posters shall have:
    1. the heading ‘Food/Product's Name – Recall Announcement',
    2. the description and brand (if any) of the food;
    3. picture(s) of the food;
    4. details of the recall arrangement (such as period of recall, place of recall or return of the food);
    5. the full name, address and telephone number of the recalling trader(s)/ organization(s)/person(s); and
    6. the telephone enquiry service for the recall.
  6. Retract the food returned by retailer(s) or consumers and return to the supplier.
  7. Keep records of recalled food, including :
    1. a description of the food returned such as brand and product name, size, identifying codes;
    2. the date and quantity of food returned; and
    3. the disposal of the food, for example, returned to the supplier(s).
  8. Report to FEHD within two working days upon completion of recall, the quantity and description of the recalled food and any remaining stock, and the date of return to the supplier.
Q8 I am the retailer involved in Food Safety Order, what should I do?
A8 If you are the retailer involved in Food Safety Order, you should:
  1. Immediately stop sale and use of all the food specified in Food Safety Order, and return them to the supplier.
  2. Immediately remove from the shelves all the food specified in Food Safety Order, and return the food concerned to the supplier. In case there is no supplier, the food concerned should be properly destroyed by the retailer.
  3. Keep record on quantity and description of the food such as brand and product name, size, identifying codes, and date of return to the supplier (or destruction as appropriate) of the food concerned; and report the same to FEHD (Email: Food_Recall_Notification@fehd.gov.hk, Fax: 2521 4784) within two working days upon return to the supplier (or destruction as appropriate) of the food concerned.

Control of Oil Products

Q9 How does the CFS test and identify the cooking oil made by "gutter oil"?
A9 At present, there is not any established scientific method to test and identify the cooking oil made by "gutter oil". The international practice for ascertaining the quality of cooking oil is by conducting tests on the amount of Benzo[a]pyrene (B[a]P), aflatoxins and metal contaminants contained in the oil. The CFS was given to know that the Taiwan authorities adopted a similar approach for testing. The CFS, in principle, will adopt the aforesaid method as well.
Q10 Is there any international, regional or national regulation on B[a]P in edible oil?
A10 The Codex Alimentarius Commission has not established standard of B[a]P in edible oil. The standard of B[a]P in edible oil in Mainland China was 10 μg /kg for edible oil.
Q11 What is the action level for B[a]P in edible oil set by the CFS?
A11 In 2005, the Joint Food and Agriculture Organization/World Health Organization Expert Committee on Food Additives (JECFA) concluded that the estimated intakes of polycyclic aromatic hydrocarbons (PAHs) including B[a]P were of low concern for human health. In order to protect public health and address public concerns, the CFS has set an action level of 10μg/kg for B[a]P in edible oil, which is in line with the mainland China standard. The action level was endorsed by the Expert Committee on Food Safety (Expert Committee).
Q12 Why does the CFS set 10 μg/kg as the action level for B[a]P in edible oil?
A12 The ultimate goal for setting an action level is to protect public health. The Expert Committee noted that based on local consumption data, even in the unlikely event that all edible oil consumed by a person is contaminated with 10μg/kg of B[a]P (the maximum limit established in the mainland China ), the derived Margin of Exposure (MOE) will be greater than 10,000, indicating the estimated intake of B[a]P is of low concern for human health. In addition, since mainland China is our main food supplier, setting the same action level as Mainland at 10 μg/kg can also avoid unnecessary trade barrier.
Q13 Can the action level of B[a]P in edible oils be applied to fat?
A13 Since oils can be converted to fat by various chemical methods (e.g. hydrogenation), the action level of B[a]P on edible oils can also be applied to fat.
Q14 What are the follow-up actions taken by the CFS against edible oil samples found to exceed the action level i.e. 10μg/kg for B[a]P?
A14

If an edible oil sample is found to contain B[a]P at level equal or greater than 20μg/kg, the derived MOE will be lower than 10,000, indicating a public health concern. As such, CFS would take enforcement action in accordance with Section 541 of the Public Health and Municipal Services Ordinance (Cap. 132), and initiate a mandatory recall of the edible oil concerned. If an edible oil sample is found to contain B[a]P at level greater than 10μg/kg but lower than 20μg/kg, the derived MOE will be higher than 10,000, indicating that the public health concern is low. Nevertheless, under such scenario, CFS may still take enforcement action in accordance with Section 522 of the Public Health and Municipal Services Ordinance (Cap. 132).

1 Section 54 of the Ordinance also stipulates that all food (including cooking oil) for sale must be fit for human consumption.

2 Section 52 of the Public Health and Municipal Services Ordinance (Cap. 132) provides that if any person sells to the prejudice of a purchaser any food which is not of the nature, or not of the substance, or not of the quality, of the food demanded by the purchaser, he shall be guilty of an offence.

Q15 PAHs are a group of substances. Why does the CFS set action level for B[a]P only?
A15 Currently, B[a]P is the only PAH classified as "carcinogenic to human" (i.e. Group 1 agent) by the International Agency for Research on Cancer (IARC) of the World Health Organization. The Codex Alimentarius Commission has not established any standard for PAHs including B[a]P in food. It is noted that the European Commission, Korea and mainland China have established maximum level for B[a]P in edible oil while only the European Commission has set maximum level for other PAHs in food. The CFS will continue to monitor the international development.

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Benzo[a]pyrene and Health

Q16 What is gutter oil?
A16 There is no agreed definition of "gutter oil". Generally, it refers to discarded oil recovered from gutters and ditches.
Q17 What is Benzo[a]pyrene?
A17 Benzo[a]pyrene (B[a]P) is a kind of polycyclic aromatic hydrocarbons (PAHs). PAHs are ubiquitous in the environment as contaminants, being present in air, soil, water and food.
Q18 Does the existence of B[a]P in oil mean that the oil is "gutter oil"?
A18 No. The presence of B[a]P in oil can be due to many different factors. Plant materials for oil production can be contaminated through deposits from air. The level of B[a]P in these materials can also increase through drying process using direct application of combustion gases. Furthermore, B[a]P level in oil may increase upon repeated use.
Q19 What amount of B[a]P consumed will be harmful to health?
A19 B[a]P is toxic to genes and can cause cancer in human. B[a]P is classified as "carcinogenic to human" (i.e. Group 1 agent) by the International Agency for Research on Cancer (IARC) of the World Health Organization in 2009. Therefore, a safety reference value cannot be determined for B[a]P. To reduce the health risk associated with B[a]P, efforts should be made to minimise exposure to B[a]P as far as practicable.

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Advice to the Trade

Q20 How could the trade ensure the food safety of their cooking oil or food products?
A20 The trade should buy cooking oil or food products from reputable suppliers. They may consider signing contracts with the suppliers, which include clauses on irregular audit or responsibility of violating the food regulations in Hong Kong. Don't just solely consider the cost when purchasing and buy cooking oil or food products from dubious sources or with unclear labels. The trade should also maintain a good recording system in accordance with the Food Safety Ordinance to allow source tracing if needed.

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