On September 4, 2026, the Environment and Ecology Bureau and the Centre for Food Safety (CFS) opened a three-month consultation on proposed amendments to the Sweeteners in Food Regulations (Cap. 132U) of Hong Kong SAR. Views must reach CFS by December 4, 2026.
The proposal would bring polyhydric alcohols (polyols) into the legal definition of "sweetener", expand the permitted list from 10 substances to 22, and introduce maximum permitted levels (MPLs) for more than 900 sweetener-food pairs under a Codex General Standard for Food Additives (GSFA) food-category system. Nothing binds until subsidiary legislation is tabled at the Legislative Council and a proposed 18-month transitional period expires. Manufacturers, importers and distributors must map portfolios against the draft and file comments before that December close.
What would change under Cap. 132U?
Cap. 132U has used a positive-list model since 1970. The last amendment, in 2010, added neotame and steviol glycosides. Ten sweeteners are permitted today, the current definition of "sweetener" expressly excludes polyols, and there are no numerical MPLs. The September 2026 consultation document would reverse that architecture.
The definition would drop the polyol exclusion, bringing ten GSFA polyols into scope: erythritol, isomalt (hydrogenated isomaltulose), lactitol, maltitol, maltitol syrup, mannitol, polyglycitol syrup, sorbitol, sorbitol syrup and xylitol. Advantame (INS 969) and monk fruit extract (INS 970, assigned by Codex in July 2026) would also be added, taking the permitted list to 22. Twelve of those (the ten polyols, thaumatin and monk fruit extract) would be GMP additives except in listed inapplicable food categories. More than 900 MPLs would enter the Schedule: 80% from the GSFA (July 2026 revision) and 20% from Mainland standard GB 2760-2024, covering products Codex does not address, such as Chinese-style candied fruit. Multi-function additives (for example neotame used as a flavour enhancer) would still have to stay within the Cap. 132U MPL. Cyclamates, saccharins and steviol glycosides would be specified as groups, with participating salts named and combined use capped at the group MPL. A Codex-style carry-over rule would apply, except into infant and young-child formulae (mannitol as a nutrient carrier remains permitted). Naturally occurring polyols that are not intentionally added would be exempt.
Who has to respond, and by when?
Anyone who sells, consigns, delivers or imports food containing sweeteners for the Hong Kong SAR market is in scope: local manufacturers, importers and distributors of sugar-free and reduced-sugar beverages, confectionery, dairy and baked goods, plus Mainland and other overseas suppliers. Private testing laboratories will need method adjustments once MPLs exist. Comments close on December 4, 2026. Send them by email to [email protected], by fax to 2893 3547, or by post to CFS, 43/F, Queensway Government Offices, 66 Queensway, Hong Kong.
CFS will run two forums listed on the dedicated consultation webpage: a physical session on September 23, 2026 in Wan Chai (register by September 17, 2026) and a Zoom session on October 23, 2026 (register by October 16, 2026). The CFS press release of September 4, 2026 records Expert Committee on Food Safety endorsement and general support from the Legislative Council Panel on Food Safety and Environmental Hygiene after a June 2026 briefing.
When would the amended rules start to bind?
Not now. After the consultation closes, the Government will prepare subsidiary legislation under Cap. 132 to amend Cap. 132U for tabling at the Legislative Council. Only then would the proposed 18-month transitional period begin. During the transition, a sweetener or a food containing a sweetener could lawfully comply with either the current or the amended Cap. 132U. From the end of those 18 months, every MPL and every list entry would apply in full. CFS will issue user guidelines and hold technical meetings. It reported that 98% of some 900 tests on local samples already met the proposed MPLs; the residual gap, and polyol products outside today's legal definition of "sweetener", is the formulation work that starts now.
| Stage | Action | Date |
|---|---|---|
| Consultation opens | Proposal published | September 4, 2026 |
| Physical forum | Wan Chai; register by September 17, 2026 | September 23, 2026 |
| Zoom forum | Online; register by October 16, 2026 | October 23, 2026 |
| Consultation closes | Written views due to CFS | December 4, 2026 |
| LegCo scrutiny | Subsidiary legislation tabled | After consultation |
| Transition | Either current or amended Cap. 132U may be met | 18 months after procedure |
| Full commencement | List, GMP rules and MPLs bind | End of transition |
What should compliance teams file before December 4, 2026?
Treat the annexes as the working specification. Map every sweetener in Hong Kong SKUs, including polyols used today as "not sweeteners", against Annex II (permitted list) and Annex III (MPLs). Flag carry-over, flavouring preparations, and multi-function use of neotame. Check infant and young-child foods for any sweetener carry-over other than mannitol as a nutrient carrier. Quantify testing capacity for the new MPL pairs, including GB 2760-2024-derived limits that Codex does not publish. File comments on any pair, group cap or GMP inapplicable category that would force a recipe or label change you cannot meet within 18 months of gazettal.
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Verify whether each SKU placed on the Hong Kong SAR market uses a polyol or a sweetener outside today's ten-item Schedule, diary the December 4, 2026 comment deadline, and brief formulation, labelling and quality teams. Continuous, per-jurisdiction real-time monitoring surfaces this kind of CFS consultation the moment it publishes. Obsidian tracks Cap. 132U from this consultation through LegCo tabling and gazettal.
