Food Labelling for Hong Kong: What Must Be on the Pack

If you sell food, tea or supplements into Hong Kong, what goes on the pack is not a design question — it is a regulatory one. Hong Kong runs two labelling regimes side by side for prepackaged food: the basic marking and labelling requirements (regulation 4A, Schedule 3) and nutrition labelling (regulation 4B, Schedule 5). This page sets out both lists from a printer's point of view, the items most often missed, and the space your artwork has to reserve.

1. Two separate checklists

• Basic labelling — Food and Drugs (Composition and Labelling) Regulations (Cap. 132W), regulation 4A and Schedule 3: name of the food, list of ingredients, date marking, storage or use instructions, name and address of the manufacturer or packer, net weight or volume, and so on.
• Nutrition labelling — regulation 4B and Schedule 5: unless the food is exempt, the label must show energy value plus seven core nutrients — commonly called the “1+7” panel. In force in full since 1 July 2010.

These two are routinely mixed up. Buyers assume a nutrition panel means compliance, then ship with an ingredients list in the wrong order or no date mark at all.

2. Basic labelling: what Schedule 3 requires

• Name of the food — must not be false or misleading as to the nature of the food. Where a brand name could mislead, the word “Brand” or “TM” must immediately follow it, in letters at least 3 mm high. Dried, condensed, smoked or otherwise processed foods must say so in the name.
• List of ingredients — in descending order of weight or volume as used in the pack (water making up less than 5% by volume excepted). Additives that are ingredients must be shown with their functional class plus the additive's own name, its INS number, or its “E” number. Sulphites at or above 10 ppm, and hydrogenated oils, must be declared.
• Date marking — “best before” or “use by”. Note that selling food after its “use by” date is itself an offence.
• Storage conditions / instructions for use — any special storage condition must be stated.
• Name and address of the manufacturer or packer. Imported food also involves importer / distributor information — confirm the current requirement with the Centre for Food Safety.
• Net weight or volume (or the number of items), expressed in SI units under the Weights and Measures Ordinance (Cap. 68) or the Decimalisation Ordinance (Cap. 214).

3. Nutrition labelling: what the 1+7 panel must show

The nutrient table must list energy value plus protein, available carbohydrates, total fat, saturated fatty acids, trans fatty acids, sodium and sugars. Three rules that are missed most often:

• Any nutrition claim about another nutrient means that nutrient's content must also be declared.
• A claim about any type of fat triggers a mandatory cholesterol declaration.
• Values must be declared as absolute numbers, never as a range (no “less than 0.5 mg”). Energy is expressed in kcal or kJ; nutrients in metric units (g / mg / µg).

4. Format and layout: the four things that go wrong in artwork

• Basis of expression — normally per 100 g or per 100 mL. Per package or per serving is allowed only where the conditions are met (for example a pack containing a single serving, quantified in g or mL on the pack).
• Format — a tabular format in a prominent position, with an appropriate heading. Where the total surface area of the package is less than 200 cm², a linear format is allowed — that concession matters for small cartons, sachets and tea packs.
• Bilingual artwork — when Chinese and English are both used, the nutrient table itself must be in both. Reserve width for two columns; shrinking type below readable size breaks the “legible” requirement and gets shipments rejected.
• Print conditions — print mandatory information and the nutrition panel in solid single-colour black (K), not a four-colour build: fine type in a process build goes soft and fuzzy. For surface finish, matte lamination reads better than high gloss, which throws glare back at barcode scanners and readers alike.
• Placement — keep clear of seals, folds, shrink areas and label overlaps. If the panel goes on the base or a side panel of a carton, mark the area on the die-line drawing and we will hold that space.

5. When exemption applies — and when it disappears

Items listed in Part 1 of Schedule 6, and items granted an exemption (including the small-volume exemption), do not need a nutrition label. But note the trap: the moment you print energy or nutrient content on the pack, or make any nutrition claim on the label or in advertising, the exemption is lost and a compliant nutrition label becomes mandatory.

6. Penalties

Advertising, selling or manufacturing prepackaged food not marked or labelled as required by regulation 4A(1) or 4B(1), or carrying a non-compliant nutrition claim, attracts a Level 5 fine and imprisonment for 6 months.

7. What the brand owner supplies — and what a printer cannot do for you

• Nutrition data must come from you. Either lab testing or a calculation from the recipe, following the Centre for Food Safety's technical guidance. As a printer we do not invent or fill in nutrition values, and we will not trim numbers to make the panel fit.
• Legal wording is yours to sign off. Food name, ingredient list and claim wording are regulatory decisions. We typeset from the text you approve and flag layout and legibility problems.
• One market's label is not another's. If the same product also sells in Singapore, Malaysia, Thailand or Indonesia, the language rules and panel formats differ — as a rule of thumb, Singapore works in English, Malaysia accepts Bahasa Malaysia or English, Indonesia expects Bahasa Indonesia, and Thailand expects Thai. Confirm each one with the authority before printing; a Hong Kong-compliant label is not automatically usable elsewhere.

8. Pre-press and pre-shipment checklist (six checks)

• 1. Are all mandatory items present? Name, ingredients, date mark, storage / use, manufacturer or packer details, net weight.
• 2. Ingredient list detail — descending order, functional class paired with additive name / INS / E number, sulphites and hydrogenated oils declared.
• 3. Is the 1+7 complete? Energy plus seven core nutrients — and cholesterol where a fat claim is made.
• 4. Language — in bilingual artwork, is the food name, ingredient list and nutrient table all in Chinese and English?
• 5. Judge small type on a printed proof, not by zooming on screen.
• 6. Version control — the file you approve must be the file that goes to plate; after any change, re-approve.

9. Questions buyers ask

Q: We have the artwork but not the nutrition data yet — can you start?
We can lay out and proof the pack, but the nutrition panel is signed off only once your data arrives. Reserving the space up front is far more reliable than squeezing figures in later.

Q: The package is too small for a nutrition panel.
Three routes: use the linear format (under 200 cm² total surface area); move mandatory information to a side or back panel and enlarge the print area; or revisit pack dimensions and add a label with the brand owner.

Q: Can the label be in Simplified Chinese?
The law says “Chinese”. In practice Hong Kong retail channels and consumers read Traditional Chinese, so settle it with the buyer and the channel — we can output both versions from one file.

Q: Can you handle the regulatory approval?
No — we give no legal opinion. We check press feasibility, legibility and version control. Final legal sign-off belongs with you or your regulatory adviser.

Related reading: Food Labelling for Singapore, Malaysia and Indonesia: Language, Font Size and Mandatory Particulars, Over-stickering Imported Food for Hong Kong and Macau: What the Supplementary Label Must Say, Allergen labelling in Hong Kong, Singapore, Malaysia and Indonesia, Roll label specifications: unwind, core, OD, gap and count.