Macau food labels: six particulars, the language rule, and one label for Hong Kong and Macau

1. What the law covers — and what it does not

The scope is explicit: every prepackaged or non-prepackaged food in the state in which it is supplied to the final consumer, whether produced locally in Macau or imported. Two exclusions matter: non-prepackaged fresh products, and beverages containing more than 5% alcohol.

The texts are published in Macau's official gazette database (bo.dsaj.gov.mo) and summarised on the IAM food safety site (iam.gov.mo/foodsafety). For your specific product, confirm applicability with your Macau importer or broker — our job is to print the label correctly and legibly.

2. The six mandatory particulars

Article 3(1) lists only six, but each has detail behind it:

Three conditional particulars apply where relevant: country of origin (where its absence would mislead about origin or true source), special storage or use conditions, and instructions for use (where omitting them would hinder correct use).

Ingredient listing may be omitted for: products made from a single ingredient; fresh fruit and vegetables; carbonated water with no added ingredient other than CO2, where the name says so; vinegar from a single base with no other ingredient; and fermented milk, cream, butter and cheese containing nothing beyond milk products, enzymes, necessary cultures or salt.

3. Language: where Macau differs from Hong Kong

This is the most valuable paragraph on the page. The language article of Decree-Law 50/92/M provides that the particulars required by Article 3 must be given in Chinese, Portuguese or English — any one of the three; but prepackaged food produced in the Macau SAR must use Chinese and Portuguese together.

4. Dates: wording, order and precision

• Wording: "use by" for perishable food; "best before" where the date shows day and month; "best before end" otherwise.
• Order: Arabic numerals in day, month, year order; the month may be indicated in Portuguese or English.
• Precision: under three months' shelf life — day and month only; three to eighteen months — month and year only; over eighteen months — the production date should be given.
• Exempt from a durability date: fresh fruit and vegetables; bread and pastry normally consumed within 24 hours of manufacture; vinegar; salt; solid sugar; sugar confectionery of sugar, flavourings and/or colours; chewing gum.

5. The penalty clause worth memorising: never sticker over the expiry date

The law also requires label information to be printed indelibly, visibly and legibly, not hidden, covered or separated by other material or images, and not altered. That governs design (no pale type over artwork) as much as materials (no ribbon or ink that rubs off).

6. One label for Hong Kong and Macau: the conditions

Buyers covering both markets often want a single label to save one set of plates. It works when all four of these hold:

1. Take the union of fields, not the intersection. Hong Kong Cap. 132W requires food name, ingredients, date marking, storage instructions, manufacturer or packer name and address, and net weight (plus nutrition labelling rules); Macau requires its six particulars. The combined label must satisfy both; leaving one out makes it non-compliant in one market.
2. Language: one Chinese/English label meets both — provided the goods are imported, not made in Macau.
3. Dates: both accept day/month/year and English month names, but the wording differs. On a shared panel, two separate lines are safer than one merged line.
4. Additives: Macau wants the specific name plus the functional class; Hong Kong wants the functional class plus the name or international number. Because both require the functional class, writing to the Macau pattern (name + function) normally satisfies Hong Kong too — the reverse is where fields go missing.

There is no "Hong Kong only" or "Macau only" exemption for a shared label: if the label circulates in that market, the whole label is assessed. A line saying "for the Hong Kong market only" does not remove it from Macau's supervision.

7. Seven things to send with an enquiry

1. Product category, and whether it is a beverage above 5% alcohol (that falls outside this law);
2. Whether the goods are imported into Macau or produced/packed in Macau — this decides Portuguese;
3. The Macau importer's or label-responsible party's company name and address (or foreign trade operator number);
4. The required date wording and precision (shelf life length decides day/month versus month/year);
5. Ingredient list and additive list, including the functional class of each additive;
6. A photo or PDF of the current label, and whether you plan to add information by oversticker — if so, the usable sticker area and its position;
7. Quantity, number of versions, rolls or sheets (core size, unwind direction) and required arrival date.

8. Three questions buyers ask

Does imported food sold in Macau have to carry Portuguese?

No. The law accepts Chinese, Portuguese or English — any one. Chinese and Portuguese together are required only for prepackaged food produced in Macau. Much of the imported food on Macau shelves carries Chinese only, or English only. If your customer is a Macau government body, a Portuguese-speaking buyer, or you are aiming at Lusophone markets, adding Portuguese is a commercial choice, not a legal requirement.

Can a Hong Kong label be sold in Macau as it is?

Usually yes on language (Chinese/English is accepted in both), but check field by field: Macau's six particulars — sale name, ingredients including the functional class of each additive, durability date, label-responsible party or importer name and address, net quantity, batch identification — plus the date wording and precision, plus country of origin where omitting it would mislead. Where an oversticker fills the gap, it must never cover the original expiry date or batch code.

Are overstickers lawful in Macau?

The law does not prohibit overstickers; it prohibits sticking another label over the durability date, or otherwise making that date hard to read. So an oversticker must do three things right: not cover the expiry date, batch code or net quantity; not contradict the original label; and not remove or alter the original. Done that way it adds information — it does not alter the label.

Related reading: Hong Kong food labelling (Cap. 132W), overstickers for Hong Kong, local-language labels for Southeast Asia, allergen labelling compared, how to specify roll labels, Thai food labelling under MOPH Notification No. 450.