Over-stickering Imported Food for Hong Kong and Macau: What the Supplementary Label Must Say

1. First, what over-stickering can and cannot do in each market

Imported food usually arrives with artwork in the language of origin. Reprinting the whole run is expensive, so the industry norm is to fix the gap with a compliant sticker. Hong Kong and Macau give you different room to work in.

Hong Kong — stick-on labels are expressly allowed. Schedule 3 to the Food and Drugs (Composition and Labelling) Regulations (Cap. 132W) requires the marking or labelling of prepackaged food to be in English or Chinese, or in both languages; if both languages are used, the food name and the ingredient list must appear in both. In practice, stick-on labels may be used to remedy a non-compliant existing label, applied by the Hong Kong importer (with the manufacturer's permission). The sticker may be Chinese, English or both; when both are used, the food name, ingredient list and nutrition information must all be bilingual.
Macau — allowed, with one clause that matters. Decree-Law No. 50/92/M (as amended by Decree-Law No. 56/94/M and Administrative Regulation No. 7/2004) requires prepackaged food labels to carry the name under which the food is sold, the list of ingredients, the date of minimum durability, the name and address of the party responsible for labelling or of the importer, the net quantity and a batch identification — plus, where applicable, the country of origin, special storage or use conditions and instructions for use. The language may be Chinese, Portuguese or English; but prepackaged food produced in Macau must use Chinese and Portuguese together. The same decree requires the particulars to be in indelible characters, easily visible and legible, correct, clear and precise, and not concealed, covered or separated by other text or images. That single sentence decides where the sticker may go and how big it can be.

This article covers the language, format and printing side of labels — what a printer controls. It is not legal advice. Composition, additive limits and nutrition values must be confirmed with the local authority, your importer or your compliance consultant. Penalties under Decree-Law No. 50/92/M run from MOP 1,000 to MOP 50,000.

2. The six fields a supplementary label needs at minimum

#	Field	How to fill it
1	Name of the food	Must let the buyer know what the product actually is. A brand or fanciful name cannot stand alone — it must be accompanied by a true description.
2	List of ingredients	In descending order of weight, additives included, with allergens identifiable. If the original label already carries it, you may state "see original packaging" — provided that text stays readable and is not covered by the sticker.
3	Date marking	Hong Kong uses "best before" or "use by" wording; Macau uses the equivalent wording, in Arabic numerals in day / month / year order (the month may be in Portuguese or English).
4	Importer / party responsible, name and address	Hong Kong: name and address of the manufacturer or packer. Macau: name and address of the party responsible for labelling or of the importer. Your customer supplies this — never translate it yourself.
5	Net weight / volume / count	Metric units (g, kg, mL, L), applied consistently.
6	Storage and use instructions	Required where special storage conditions or instructions for use apply (chilled, once opened, and so on).

Add what the market requires on top: Hong Kong's 1+7 nutrition label (energy plus seven core nutrients — especially relevant when any nutrition claim is made) and Macau's country of origin and instructions for use. Also leave a variable-data box for batch code and expiry date, so a date change never forces a reprint of the whole sticker run.

3. Where it goes: three lines you cannot cross

Never cover required information. If the sticker hides the best-before date, the country of origin or the batch code on the original label, a compliant label becomes a non-compliant one. Macau goes further and expressly forbids concealing, covering or separating label particulars. Mark the readable area of the original pack first and place the sticker only in the free space.
Both languages on the same visible surface. When Chinese and English are used together, the food name and the ingredient list must both be visible — not one on the front and the other inside a peel-open flap or on the base.
A sticker repairs information; it does not rewrite facts. Covering a printed error, or hiding a date that has passed, is a violation — and responsibility lands on whoever applied the label. Fix the artwork, not the evidence.

4. Material and adhesive: the wrong choice lifts in three days

A sticker that falls off is a label that is not compliant. This is the most underrated part of over-stickering.

Use case	Face stock	Adhesive	Watch out for
Ambient cartons, paper bags (dry)	Coated or uncoated paper	Permanent water-based or hot-melt	Cheapest option; avoid long storage in damp warehouses.
Chilled (about 0–8°C, condensation)	PP synthetic paper, pearlescent	Chiller-grade permanent	Paper face stock wrinkles and blisters in condensation — not the place to save money.
Frozen (-18°C and below)	PP / PET	Freezer-grade, good low-temperature initial tack	Frost on the surface prevents bonding — warm the pack or blow-dry first.
Glass, PE / PP bottles	BOPP / PP	Low-surface-energy specific	PE and PP have low surface energy: trial a few bottles before a large run.
Must peel off cleanly	Paper or synthetic	Removable	Good for promotions and temporary fixes; weaker long-term holding.
May contact food (including indirect contact)	Must meet food-contact requirements	Food-contact grade	Ask the supplier for a compliance declaration (e.g. the GB 4806 series, the EU 10/2011 framework, FDA 21 CFR 175.105 as applicable).
Greasy, dusty or rough surfaces	Thicker synthetic	High initial tack	A micro-vented adhesive helps avoid bubbles and lifting edges.

These are common starting points, not the only answers. Storage, shelf and freezer conditions differ for the same shipment, so trial a small quantity on the real product in the real environment for a few days before the full run.

5. Variable data: batch codes and dates

Different date per batch: leave the field blank and overprint by thermal transfer, inkjet or a coder at packing time — or reserve a dedicated expiry box on the sticker.
Fixed content: print it with the sticker; cheapest route.
Small quantities, many variants: digital printing handles variable data, one batch code per label included.
Hard rule: the date on the sticker must match the product's actual shelf life. A sticker may not extend a date.

6. Pre-shipment checklist

Language: Hong Kong — Chinese, English or both (with food name, ingredient list and nutrition information bilingual when both are used); Macau — Chinese, Portuguese or English, but Chinese and Portuguese together if produced in Macau.
All six mandatory fields present, plus market-specific extras (Hong Kong 1+7 nutrition label, Macau country of origin and so on).
Nothing obscured — best-before, country of origin, batch code (expressly prohibited in Macau).
Material and adhesive matched to chilled, frozen, bottle, greasy or food-contact conditions.
Variable-data box reserved and date format correct (day / month / year for Macau).
Barcode: on retail packs, the EAN-13 and its quiet zones must not be trimmed or covered by the sticker.

7. Six things to send us for a supplementary label run

Destination market (Hong Kong / Macau) and sales channel (retail, food service, online)
Sticker size and the surface it goes on — a flat photo of the pack helps most
Language version and layout (Chinese, English, side by side; Portuguese where required)
The full text to be added, including the importer's registered name, address and licence number
Storage and transport conditions: ambient, chilled, frozen, possible food contact
Quantity and delivery format: rolls for applicators or sheets for hand application

One thing stated plainly: we are printers. Artwork, printing, die-cutting, slitting and rewinding all happen in our plant, and we can lay out the copy you supply and produce a small trial batch so you can check how the material and adhesive behave in real conditions. The act of labelling is normally carried out by the importer or the warehouse, not by the print supplier — worth settling before the container lands.

Need a quotation? Send artwork, size, quantity, material and target market.
Tel 180 1199 6161 | Email 189177122@qq.com