3. Compositional Aspects

Beers and RTDs
Hong Kong

This section provides the compositional requirements for the food category and/or food products in scope and information on permitted nutrients, ingredients, and additives.

3.1 Composition Requirements

General Food

General Food composition requirements are laid down in the Food and Drugs (Composition and Labeling) Regulations (Cap. 132) [1]. 

Composition requirements are laid down in detail for a limited number of products such as milk-based products, infant formula, margarine, vinegar, and baking powder. The regulations also provide the general definitions of ingredients and additives that can be used in food. These regulations do not provide composition criteria for beverage drinks with an alcoholic strength by volume of more than 1.2% but specifically exclude them from the labeling and nutritional labeling provisions of these regulations.

Category

Alcoholic drinks

By definition [2], liquor (酒類), alcoholic liquor (飲用酒類), spirituous liquor(烈酒), or spirit (酒精) means any liquid which contains more than 1.2% of ethyl alcohol by volume except—

1. denatured spirits;
2. any such liquid that is an ingredient in any goods, if that liquid cannot be converted to pure ethyl alcohol or to intoxicating liquor, or if such a conversion would not be economical. 

According to Dutiable Commodities Regulations (Cap. 109, section 6) [2] for all intoxicating liquors, every such liquor shall possess the aroma and flavor natural to liquor of its type.

Product

1) Beer

There are no compositional criteria for beer. By definition, beer includes ale, porter, stout, spruce beer, black beer, and any other kind of beer and extends to any liquor made or sold as beer or as a substitute for beer. In addition, the requirements for liquor apply (See Category - alcoholic drinks - above).

2) Ready-to-drink beverages (mainly Chuhai)

There are no compositional criteria for ready-to-drink beverages. According to Dutiable Commodities Regulations (Cap. 109, section 6) [2], for all intoxicating liquors, every such liquor shall possess the aroma and flavor natural to the liquor of its type. 

3.2 Raw Material Requirements

General Food

Please refer to Section 3.1 above. 

Category

Alcoholic drinks

No specified raw material requirements for the production of alcoholic drinks are defined. 

Product

1) Beer

No specified raw material requirements for the production of beer are defined.  

2) Ready-to-drink beverages (mainly Chuhai)

No specified raw material requirements for the production of Chuhai are defined.  

3.3 Fortification

General Food

Requirements for General Food fortification are laid out in the Food and Drugs (Composition and Labeling) Regulations (Cap. 132). [1] 

Category

Alcoholic drinks

There is no guidance on the addition of nutrients. Nutrients are normally added to food to improve the nutritional quality of the food. As alcoholic drinks are not regarded as ‘nutritious food’, it is not advisable to add these substances to alcoholic drinks. 

Product

1) Beer

Same as "Category" (alcoholic drinks) above. 

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above. 

3.4 Other Permitted Ingredients

General Food

Permitted ingredients for General Food are laid out in the below regulations:

1. Coloring Matter in Food Regulations (Cap. 132H) [3]
2. Sweeteners in Food Regulations (Cap. 132U) [4]
3. Food and Drugs (Composition and Labeling) Regulations (Cap. 132W) [1]
4. Preservatives in Food Regulation (Cap. 132BD) [5]  

For ingredients and food additives not specifically listed in the regulations, the general provisions of the Public Health and Municipal Services Ordinance (Cap. 132) [7] will apply. This ordinance requires that all food sold in Hong Kong must be safe for human consumption. In general, ingredients considered safe by international standards—such as the Codex Alimentarius are acceptable [8].

Category

Alcoholic drinks

There are no specific other ingredients laid out for “Alcoholic drinks”. This category should comply with the requirements of “General Food” above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above.

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above.

3.5 Permitted Additives

General Food

Provisions for additives are laid down in the Food and Drugs (Composition and Labeling) Regulations (Cap. 132W [1]) where Additive (添加劑) means any substance, not commonly regarded or used as food, that is added to, or used in or on, food at any stage to affect its keeping qualities, texture, consistency, appearance, taste, odor, alkalinity or acidity, or to serve any other technological function in relation to food, and includes processing aids in so far as they are added to, or used in or on, food as aforesaid, but does not include—

1. vitamins, minerals, or other nutrients in so far as they are used solely for the purpose of fortifying or enriching food or of restoring the constituents of food;
2. herbs or spices when used as seasoning;
3. hops;
4. salt;
5. yeast or yeast extracts;
6. the total products of any hydrolysis or autolysis of food protein;
7. starter cultures;
8. malt or malt extract;
9. any substance that is present in food solely as a result of its addition to animal, bird, or fish feeding stuff or its use in a process or treatment carried out in crop husbandry, animal husbandry, veterinary medicine, or storage (including any pesticide, fumigant, sprout depressant or veterinary medicine); or
10. air or water; (L.N. 222 of 1985).

Permitted Sweeteners in Sweeteners in Food Regulations (Cap. 132U) [4] for General Food are as follows:

1. Acesulfame Potassium
2. Alitame
3. Aspartame
4. Aspartame-acesulfame Salt
5. Cyclamic Acid (and Sodium, Potassium, Calcium Salts)
6. Saccharin (and Sodium, Potassium, Calcium Salts)
7. Sucralose
8. Thaumatin
9. Neotame 
10. Steviol Glycosides

The Sweeteners in Food Regulations (caps. 132U) [4] excludes any sugars or other carbohydrates or polyhydric alcohols.  

Category

Alcoholic drinks

The permitted preservatives and antioxidants for Alcoholic drinks are listed in various sub-categories of Food Category 14.2 in the Schedule of Preservatives in Food Regulations [5].

Product

1) Beer

The permitted preservatives and antioxidants for Beer are as below [5]:

Note 6: As benzoic acid. 

Note 10: As tartaric acid.

Note 26: As para-hydroxybenzoic acid

Note 30: As residual sulphur dioxide

Note 42: As anhydrous calcium disodium ethylenediaminetetraacetate

Note 50: Benzoates and para-hydroxybenzoates can be used in combination only if the following condition is satisfied: when the quantity of each such food additive present in that food is expressed as a percentage of the maximum permitted level, the sum of those percentages does not exceed 100. 

2) Ready-to-drink beverages (mainly Chuhai)

The permitted preservatives and antioxidants for Ready-to-drink beverages (mainly Chuhai) are as below [5] :

Note 6: As benzoic acid.

Note 9: As sorbic acid.  

Note 10: As tartaric acid.

Note 26: As para-hydroxybenzoic acid.

Note 30: As residual sulphur dioxide.

Note 42: As anhydrous calcium disodium ethylenediaminetetraacetate.

3.6 Permitted Flavors and Colors 

General Food

There is currently no specific legislation in Hong Kong governing the use of flavoring agents. The food law in Hong Kong under the Public Health and Municipal Services Ordinance (Cap. 132) [7] covers general protection for food purchasers, offenses in connection with the sale of unfit food and adulterated food, composition, and labeling of food, food hygiene, seizure and destruction of unfit food.

When considering whether any flavoring agent is allowed to be added to foods, reference from safety evaluation done by international food safety authorities such as JECFA.

The permitted colorants are listed in Coloring Matter in Food Regulations (Cap. 132H) [3] and are:

Permitted Coloring Matter

Part I

Coal Tar Colors

Part II

Other Colors

Category

Alcoholic drinks

Same as "General Food" above. There are no flavors and colorants specifically allowed in “Alcoholic drinks”. 

Product

1) Beer

Same as "Category" (alcoholic drinks) above. 

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above. 

3.7 Permitted Processing Aids 

General Food

There is no definition for processing aids in Hong Kong Legislation. As a result, there is no specific requirement for processing aids. All ingredients including processing aids that constitute part of the food and contain an allergenic substance must be declared in the ingredients list in accordance with Schedule 3 to the Food and Drugs (Composition and Labeling) Regulations [1].  

In general, the Hong Kong authority recognizes Codex standards and Guidelines including its definition of processing aid which the industry may follow. By Codex definition, “Processing aid means any substance or material, not including apparatus or utensils, and not consumed as a food ingredient by itself, intentionally used in the processing of raw materials, foods or its ingredients, to fulfill a certain technological purpose during treatment or processing and which may result in the non-intentional but unavoidable presence of residues or derivatives in the final product”. The industry may follow Codex principles in CAC/GL 75-2010 Guidelines on Substances Used as Processing Aids [9].

Category

Alcoholic drinks

Same as "General Food" above.

Product

1) Beer

Same as "Category" (alcoholic drinks) above. 

2) Ready-to-drink beverages (mainly Chuhai)

Same as "Category" (alcoholic drinks) above. 

3.8 Additional Notes

None. 

3.9 References

1. Food and Drugs (Composition and Labelling) Regulations (Cap. 132W)

https://www.elegislation.gov.hk/hk/cap132W

2. The Dutiable Commodities (Amendment) Ordinance 2018 

https://www.elegislation.gov.hk/hk/cap109

3. Colouring Matter in Food Regulations (Cap. 132H)

https://www.elegislation.gov.hk/hk/cap132H

4. Sweeteners in Food Regulations (Cap. 132U)

https://www.elegislation.gov.hk/hk/cap132U

5. Preservatives in Food Regulation (Cap. 132BD)

https://www.elegislation.gov.hk/hk/cap132BD

6. Colouring Matter in Food Regulations (Cap. 132H)

https://www.elegislation.gov.hk/hk/cap132H

7. Cap. 132 Public Health and Municipal Services Ordinance

https://www.elegislation.gov.hk/hk/cap132?xpid=ID_1438402663868_001

8. Hong Kong CFS Food Safety Focus Article 1_Codex Alimentarius and Food Safety

https://www.cfs.gov.hk/english/multimedia/multimedia_pub/multimedia_pub_fsf_198_01.html

9. Codex Guidelines on Substances Used as Processing Aids

https://www.fao.org/fao-who-codexalimentarius/sh-proxy/en/?lnk=1&url=https%253A%252F%252Fworkspace.fao.org%252Fsites%252Fcodex%252FStandards%252FCXG%2B75-2010%252FCXG_075e.pdf