Hong Kong (HK)
It is a Hong Kong requirement for full cream milk to have a minimum milk fat content of 3.25%.
The Department is aware shipments of full cream milk which have been found to be compliant with Hong Kong's specifications at the time of export have tested on arrival in Hong Kong to have milk fat content levels of less than 3.25%.
Pending further investigations into the cause of these discrepancies, the Department strongly recommends that all companies exporting full cream milk to Hong Kong ensure milk fat content tests at ≥ 3.5% prior to export.
1.1 Establishment registration
| Initial listing procedure | Required? |
|---|---|
| Export Registration | Yes |
| Establishment listing required for Hong Kong | No |
Exceptions (ship stores)
Export certification is not issued for ships stores as the Export Control (Milk and Milk Products) Rules 2021 do not apply. Ships stores are milk and milk products on ships or aircraft for the use of passengers and crew or for the service of the ships or aircraft on a voyage from Australia.
1.2 Overseas listing
1.3 Prohibited products
There are no known products that are prohibited for export to this market.
1.4 General information
Guides to importing food, milk and milk beverages and frozen confections
The Centre for Food Safety in Hong Kong has a Guide to importing food into Hong Kong (English version) and the Hong Kong food legislation/ guidelines.
Exporters should also refer to the following guides on the Centre for Food Safety website:
- Guide to the import of milk and milk beverages into Hong Kong
- Guide to the import of frozen confections into Hong Kong (includes ice cream).
Regulations that apply to dairy products for sale in Hong Kong
The basic food law in Hong Kong is laid down in Part V of the Public Health and Municipal Services Ordinance (Cap 132). This law includes several regulations that apply to dairy products, such as the:
- Food and Drugs (Composition and Labelling) Regulations
- Milk Regulation
- Dried Milk Regulations
- Frozen Confections Regulation (PDF 130 KB) (applies to ice cream).
Exporters should clarify requirements with their customers/ buyers in Hong Kong and check what specific requirements need to be met.
2.1 Milk and milk products
Milk and milk products of bovine origin are defined as prescribed goods under the Export Control Act. Production of these products for export is regulated under the Export Control (Milk and Milk Products) Rules 2021.
Note
Milk and milk beverages are not permitted to be sold in Hong Kong for human consumption if it has been subjected to heat treatment more than once (double pasteurised), except in the case of imported frozen pasteurised whole milk.
Milk and milk products manufactured from non-bovine species, for example buffalo, goat and sheep, may also need to be regulated through the Export Control (Milk and Milk Products) Rules 2021. This is only required when export registration and health certification from the department is required by Hong Kong.
Hong Kong has no known additional requirements for the production and export of non-bovine milk and milk products.
2.2 Compositional requirements
Exporters should clarify compositional requirements with their importers. These requirements are outlined in Hong Kong's Food and Drugs Composition and Labelling Regulations and the Dried Milk Regulations are summarised in the following table.
| Type of Milk or Dairy Product | Specifications |
|---|---|
| Milk and milk beverages |
|
| Cream |
|
| Milk and Cream Mixture (Half and half) |
|
| Sweetened condensed or evaporated milk |
|
| Unsweetened condensed or evaporated milk |
|
| Dried milk (Milk powder) |
|
| Butter |
|
| Ghee |
|
| Cheese |
|
| Ice cream |
|
2.3 Further information
3.1 Technical grade and pharmaceutical products
Unless technical products and pharmaceutical material are prepared at an establishment that produces milk and milk products for export as food, these products are non prescribed goods. They are not regulated by the Export Control (Milk and Milk Products) Rules 2021.
3.2 Animal feed
Unless animal food is prepared at an establishment that produces milk and milk products for export as food, these products are non prescribed goods.
In accordance with the Export Control (Milk and Milk Products) Rules 2021, animal food must be clearly identified as animal food and not for human consumption. It must also be segregated from and not contaminate milk and milk products that are for human consumption.
3.3 Manufacturing grade products
Hong Kong has no known additional requirements for Manufacturing Grade milk and milk products that differ from the Export Control (Milk and Milk Products) Rules 2021.
3.4 Processing
3.5 Further information
4.1 Microbial and residue sampling
Requirements for the production of milk and milk products for export to Hong Kong can be met through the requirements of the Export Control (Milk and Milk Products) Rules 2021. Although milk and milk beverages must be heat treated using treatments such as pasteurisation and UHT, it must not be double pasteurised (heat-treated more than once).
Note
With the exception of imported frozen pasteurised milk, is not permitted to be sold in Hong Kong for human consumption if it has been subjected to heat treatment more than once).
Export registered establishments that intend to export dairy products to Hong Kong are required to either:
- reflect relevant microbiological requirements of Hong Kong authorities in their HACCP programs for dairy products
- present an analytical certificate from a NATA registered laboratory confirming that products (batches/ lots) intended for export to Hong Kong comply with relevant microbiological requirements of Hong Kong authorities.
Microbiological testing
Exporters should note that Hong Kong authorities have requested that samples of milk and dairy products intended for export to Hong Kong must undertake microbiological testing prior to export of the goods.
Details of the requirements for testing are outlined in the table below.
| Product | Specifications |
|---|---|
| Pasteurised milk, cream and milk beverages (includes extended shelf life milk) |
|
| UHT milk and UHT cream |
|
| Sour cream |
|
| Frozen dairy based ice confection (includes ice cream) |
|
Note
Microbiological criteria listed in the table above (with the exception of tests for sour cream) reflect those used by Hong Kong's authorities to test milk and dairy products which are outlined in the Milk Regulation, the Frozen Confections Regulations (PDF 130 KB) and the Microbiological Guidelines for Ready-to-Eat Food (PDF 1.6 MB).
Exporters should also be aware of Hong Kong's requirements for ready-to-eat foods which are summarised below. The guidelines are available on the Hong Kong Centre for Food Safety (CFS) website: Microbiological Guidelines for Food (PDF 1.6 MB). CFS has also provided a list of frequently asked questions.
| Food types | Satisfactory | Borderline | Unsatisfactory | ||
|---|---|---|---|---|---|
| Total plate count (30°C for 48 hours) | Shelf-stable products in cans, bottles, cartons (for example, UHT milk, UHT cream, UHT dairy beverages, UHT dairy desserts) | <10 cfu/g | Not applicable | Note 1 | |
| Heat treated or cooked foods requiring refrigeration and minimum handling before sale or consumption | <104 cfu/g | 104 - <107cfu/g | >107cfu/g | ||
| Bakery, confectionary, powdered foods (e.g. milk powder) | <104 cfu/g | 104 - <106cfu/g | >106cfu/g | ||
Cooked foods requiring refrigeration and some handling prior to sale or consumption (e.g. pasteurised foods, desserts) Non-fermented dairy products, mayonnaise and cooked sauces (e.g. butter, cheese, cakes with dairy cream, dairy desserts) | <105 cfu/g | 105 - <107cfu/g | >107cfu/g | ||
| Food mixed with dressings, dips, pastes (e.g. dairy dips) | <106 cfu/g | 106 - <107cfu/g | >107cfu/g | ||
| Extended shelf-life products requiring refrigeration (e.g. ESL milk, products in modified atmospheric packaging, vacuum packed products) | <106 cfu/g | 106 - <107cfu/g | >108cfu/g Note 2 | ||
| Preserved food products and fermented food products (e.g. yoghurt, and ripened cheeses) | Not applicable | Not applicable | Not applicable | ||
| Hygiene indicator organisms | Enterobacteriaceae in cheeses - Note 3 | <102 cfu/g | 102 - <104cfu/g | >104cfu/g | |
| Escherichia col (E.coli) - Note 4 | <20 cfu/g | 20 - <102cfu/g | >102cfu/g | ||
| Specific food borne pathogens | Campylobacter spp. (thermotolerant) | Not detected in 25g | Not applicable | Detected in 25g | |
| E.coli O157(and other Shiga toxin-producing E.coli, STEC) | Not detected in 25g | Not applicable | Detected in 25g | ||
| Salmonella spp. | Not detected in 25g | Not applicable | Detected in 25g | ||
| Listeria monocytogenes - Note 5 | Chilled food - Note 6 | Not detected in 25g | Not applicable | Detected in 25g | |
| Infant formula | Not detected in 25g | Not applicable | Detected in 25g | ||
| Other food | <10 cfu/g | 10 - <102cfu/g | >102cfu/g | ||
| Staphyloccus aureus and other coagulase positive staphylococci | <20 cfu/g | 20 - <104cfu/g | >104cfu/g | ||
| Clostridium perfringens | <10 cfu/g | 10 - <104cfu/g | >104cfu/g | ||
| Bacillus cereus | <103 cfu/g | 103 -<105cfu/g | >105cfu/g | ||
Notes:
- Products will be deemed to be 'unsatisfactory' if spore forming anaerobes are detected after additional testing.
- Hong Kong authorities are likely to look for signs of spoilage.
- Excludes cheese ripened with Hafnia alvei or Proteus vulgaris.
- Does not apply to raw milk cheeses.
- Use ISO 11290 - 1:1996/Amd 1:2004 or equivalent methods.
- Testing is not required if there is scientific evidence that growth of L. monocytogenes will not be supported.
- Not recommended for routine surveillance. Only tested in cases of food poisoning investigation or food complaints if the organism is implicated.
| COMMODITY | MICRO-ORGANISMS | SPECIFICATIONS (See Notes 1 and 2) | ||||
|---|---|---|---|---|---|---|
| n | c | m | Method | |||
| Powdered infant formula, formula for special medical use and human milk fortifiers | Cronobacter sakazakii (previously Enterobacter sazakii) | 30 | 0 | Not detected in 10g | ISO/TS 22964:2006 | |
| Salmonella spp. | 60 | 0 | Not detected in 25g | ISO 6579 | ||
| Powdered follow up formula | Salmonella spp. | 60 | 0 | Not detected in 25g | ISO 6579 | |
Notes:
- Where ‘n’ = number of samples that must conform to the criteria; ‘c’ = the maximum allowable number of defective sample units in a 2-class plan; ‘m’ = a microbiological limit which, in a 2-class plan separates good quality from defective quality.
- Other methods that provide equivalent sensitivity, reproducibility, and reliability can be employed if they have been appropriately validated.
For more information on Hong Kong's new Pesticides in Food Regulation, refer to information on Hong Kong's Centre for Food Safety website and the User Guide to the Regulation.
Hong Kong residue standards
Maximum residue limits (MRLs) or import tolerances for residues of specific agricultural and veterinary chemicals approved for use in Australia may not exist in Hong Kong or may be established at levels lower than those established in Australia. Maximum Limits (MLs) for contaminants may also vary between Hong Kong and Australia.
Food business operators should note that:
- These differences can be interrogated case-by-case by considering the Hong Kong standards and the Australian standards.
- Any detection of a residue above the Hong Kong MRLs/MLs (as applicable) at the border may result in rejection of the consignment.
Note
Importing country residue standards can usually be found via the official webpages of their competent authority. Links to a limited number of export markets and Australia are provided on the DAFF website.
4.2 Operational requirements additional to Australia's export legislation
It is a Hong Kong requirement for full cream milk to have a minimum milk fat content of 3.25%.
The Department is aware shipments of full cream milk which have been found to be compliant with Hong Kong's specifications at the time of export have tested on arrival in Hong Kong to have milk fat content levels of less than 3.25%.
Pending further investigations into the cause of these discrepancies, the Department strongly recommends that all companies exporting full cream milk to Hong Kong ensure milk fat content tests at ≥ 3.5% prior to export.
Hong Kong has no known additional requirements for general operations that differ from those required in the Export Control (Milk and Milk Products) Rules 2021.
4.3 Hygiene
Hong Kong has no known additional hygiene requirements that differ from those required in the Export Control (Milk and Milk Products) Rules 2021.
5.1 Milk and milk products
Milk and milk products that are prescribed under Australia's export rules
- are milk or milk products derived from a bovine animal; and
- are intended to be exported as food.
Milk and milk products that are not prescribed under Australia's export rules
Milk and milk products which do not meet the criteria under the Export Control (Milk and Milk Products) Rules 2021 are classified by Australia as non-prescribed goods. It is the responsibility of the exporter to confirm with the importing country if there are any specific requirements for the import of these products. Typically, non-prescribed goods include ice-cream, non-bovine milk products, colostrum and products with a minor component of dairy.
Further information on exporting non-prescribed goods from Australia is available on the department’s website.
In some cases, an importing country requires specific health certification and government oversight for what would typically be non-prescribed milk and milk products. When required, these products become prescribed under export legislation and must meet all export and importing country requirements. This includes the products being manufactured and stored at an export registered establishment and having a valid export permit and health certificate for each consignment. Guidance on export registration can be found at Dairy export registered establishments.
For further information on export registration and exporting non-bovine milk and milk products for human consumption to Hong Kong please contact the Dairy Eggs and Fish Program at DairyEggsFish@agriculture.gov.au.
5.1.1 Health certification for milk and milk products
For milk and milk products for human consumption (including milk and milk products classified as a prescribed good by an importing Country), use Health Certificate template ZD035.
The ZD035 Certificate contains the following attestations:
I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:
- In sound condition
- Fit for human consumption
- Of Australian Origin
Endorsements for cream, milk and non frozen yoghurt
Endorsement 380 - DAIRY - HONG KONG MIL, CRE and YOG - 72 degrees Celsius for not less than 15 seconds & disease
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 72 degrees Celsius for not less than 15 seconds.
Optional Endorsement 384 – DAIRY - HONG KONG MIL, CRE and YOG - 72 degrees Celsius for not less than 15 seconds, radioactivity & disease
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 72 degrees Celsius for not less than 15 seconds.
The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Endorsements for UHT milk products
Endorsement 378 – DAIRY - HONG KONG UHT milk heat treatment - not less than 132 degrees Celsius for not less than 1 second & disease statement.
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 132 degrees Celsius for not less than 1 second.
Optional Endorsement 382 - DAIRY - HONG KONG UHT milk - 132 degrees Celsius for not less than 1 second, radioactivity & disease statement.
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 132 degrees Celsius for not less than 1 second.
The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Endorsements for UHT cream products
Endorsement 379 – DAIRY - HONG KONG UHT cream heat treatment - not less than 133 degrees Celsius for not less than 1 second & disease statement
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 133 degrees Celsius for not less than 1 second.
Optional Endorsement 383 - DAIRY - HONG KONG UHT cream - 133 degrees Celsius for not less than 1 second, radioactivity & disease statement
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 133 degrees Celsius for not less than 1 second.
The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Endorsements for yoghurt (frozen)
Endorsement 1952 – DAIRY HONG KONG - Frozen Yoghurt, heat, handling, hygiene and acidity.
Frozen yoghurt has been subjected to proper heat treatment and afterwards fermented by an approved starter culture. Frozen yoghurt was handled, processed, and packed under hygienic conditions in accordance with relevant legislation of Australia. The titratable acidity of frozen yoghurt and the bacterial activity of it conform to relevant legislation in Australia.
Optional Endorsement 1953 - Hong Kong - Frozen Yoghurt heat, handling, hygiene, acidity and radioactivity
Frozen yoghurt has been subjected to proper heat treatment and afterwards fermented by an approved starter culture. Frozen yoghurt was handled, processed, and packed under hygienic conditions in accordance with relevant legislation of Australia. The titratable acidity of frozen yoghurt and the bacterial activity of it conform to relevant legislation in Australia. The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Endorsements for milk and milk products (except cream, milk, yoghurt, UHT and UHC)
Endorsement 453 – DAIRY - Foot and Mouth and Rinderpest statement
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
Optional Endorsement 360 - DAIRY - Radioactivity, Foot and Mouth & Rinderpest statement.
The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Australia was free from Foot and Mouth disease and Rinderpest for twelve months prior to the export of the above product.
Exporter declarations
The following exporter declaration is needed for MIL, CRE, CML, UHT, UHC:
'Milk products in this shipment meet Hong Kong product testing requirements. Results are supported by NATA certification, or covered in the manufacturers approved arrangement'
If a declaration is made on a health certificate that 'The milk has been handled, processed and packed under hygienic conditions and heat treated at a temperature of not less than 72°C for not less than 15 seconds’ for ice cream products, the manufacturer must be able to verify this claim at audit.
If a declaration is made on a health certificate that ‘The titratable acidity of frozen yoghurt and the bacterial activity of it conform to relevant legislation in Australia’, the manufacturer must be able to verify this claim at audit. The pH must comply with the requirements of the Food Standards Code.
Transit Certification Requirements
Milk and milk products transiting the European Union or the United States may require transit documentation. These certificates are available as additional certificates through the NEXDOC system. If the product is transiting the United States, standard certification is required and the exporter should contact the Department for advice on how this certification may be issued. If the product is transiting a European Union member state, see the particular European Union member state regarding the certificate template to select.
Frozen dairy-based confections
Ice cream and dairy based sorbet
The ZD001 Certificate as to Condition may be issued for ice cream and dairy based sorbet.
The ZD001 Certificate contains the following attestations:
I certify to the best of my knowledge that the information on this form is true and correct in every particular details and that the product described above is of Australian origin and is acceptable for sale in Australia.
Optional Endorsement 3091 - DAIRY - HONG KONG ice cream processing, standards and disease status
The Australian Government is responsible for inspection and certification of food products, including dairy products, exported from Australia. The Australian Government can confirm the following:
1. To the best of the Australian Government's knowledge the information on this form is true and correct in every particular detail and the product described above is of Australian origin and is acceptable for sale in Australia.
2. Australia was free from Foot and Mouth Disease and Rinderpest for twelve months prior to the export of the above product.
3. Based on the audit of the establishment preparing the above product for export to Hong Kong the establishment complies with requirements for hygiene and the Hazard Analysis Critical Control Point system specified in the Australian export legislation, ie the Export Control Act and associated Rules.
4. The above product has been handled, processed and packed under hygienic conditions and heat treated in accordance with relevant heat treatment requirements of Australian food regulation.
5. The Australian Government acknowledges test results of chemical and microbiological analyses conducted by an independent laboratory that confirm the following:
(a) the product / frozen confection contains no more than 50,000
bacteria per gram and no more than 100 coliforms per gram; and
(b) The product/frozen dairy based confection that is described as ice cream contains no less than 5% fat, 10% sugar and 7.5% milk solids non fat.
Optional Endorsement 3092 - DAIRY - HONG KONG ice cream processing, standards, disease status and radioactivity
The Australian Government is responsible for inspection and certification of food products, including dairy products, exported from Australia. The Australian Government can confirm the following:
1. To the best of the Australian Government's knowledge the information on this form is true and correct in every particular detail and the product described above is of Australian origin and is acceptable for sale in Australia.
2. Australia was free from Foot and Mouth Disease and Rinderpest for twelve months prior to the export of the above product.
3. Based on the audit of the establishment preparing the above product for export to Hong Kong the establishment complies with requirements for hygiene and the Hazard Analysis Critical Control Point system specified in the Australian export legislation, ie the Export Control Act and associated Rules.
4. The above product has been handled, processed and packed under hygienic conditions and heat treated in accordance with relevant heat treatment requirements of Australian food regulation.
5. The Australian Government acknowledges test results of chemical and microbiological analyses conducted by an independent laboratory that confirm the following:
(a) the product / frozen confection contains no more than 50,000
bacteria per gram and no more than 100 coliforms per gram; and
(b) The product/frozen dairy based confection that is described as ice cream contains no less than 5% fat, 10% sugar and 7.5% milk solids non fat.
The goods described in this certificate have not been contaminated by radioactive elements from nuclear fallout. Analysis of representative samples of similar products has shown that the radioactivity level does not exceed 50 Bq/kg.
Endorsement for sorbet
Optional Endorsement 3400 - Dairy - NPG - Hong Kong frozen confection
The frozen confection was handled, processed and packed under hygienic conditions and has been heat treated in accordance with the frozen confection heat treatment regulations of the country of origin.
The frozen confection contains not more than 50,000 bacteria per gram and not more than 100 coliform organisms per gram.
5.2 Manufacturing grade products
For Manufacturing Grade milk and milk products, use the ZD016 Certificate as to Condition for Manufacturing Grade products.
The ZD016 Certificate as to Condition contains the following attestations:
I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:
- In sound condition
- Of Australian origin
5.3 Technical grade and pharmaceutical products
The ZD001 Certificate as to Condition may be issued for technical products and pharmaceutical material.
The ZD001 Certificate contains the following attestations:
I certify to the best of my knowledge that the information on this form is true and correct in every particular details and that the product described above is of Australian origin and is acceptable for sale in Australia.
5.4 Animal feed
The ZD015 Certificate as to Condition for Stockfood can be issued for stockfood made from milk and milk products.
The ZD015 Certificate contains the following attestations:
I hereby certify that to the best of my knowledge the conditions or restrictions applicable under the particular inspection system prescribed under the Export Control Act have been complied with in respect of the prescribed good described above, being goods that are:
- In sound condition
- Of Australian origin.
5.5 Consignments under 10 kilograms and trade samples
It is the responsibility of exporters to determine through their importers if export certification is required for consignments and trade samples that are less than 10 kilograms or 10 litres, as an export permit is not required.
5.6 Additional certification/letters
The ZX01 Certificate as to Dioxin Status of Australian Dairy Products is available on request.
European Union (EU) transit certificates are available for consignments transiting the EU. Refer to the EU documentation requirements for edible products for the reference numbers and attestations in these certificates.
6.1 Import permit
Exporters should ensure that their importer complies with any requirements to obtain a permit for imports into Hong Kong.
6.2 Port-of-entry inspection and testing
7.1 Packaging
Hong Kong has no known specific requirements for packaging in addition to those provided in the Export Control (Milk and Milk Products) Rules 2021.
7.2 Labelling
Hong Kong has no known specific requirements for labelling in addition to those provided in the Export Control (Milk and Milk Products) Rules 2021.
7.3 Shelf life
Hong Kong has no known specific requirements for shelf life restrictions other than those provided in the Export Control (Milk and Milk Products) Rules 2021.
7.4 Shipping marks
Hong Kong has no known specific requirements for shipping marks (port marks).
7.5 Further information
Hong Kong has no known specific requirements for shipping and airfreight. Milk and milk products must be transported to ensure their condition and integrity is maintained in accordance with the requirements of the Export Control (Milk and Milk Products) Rules 2021.
8.1 Refrigeration, transfer and loadout
04/07/2022 - Removal of Dairy by Definition wording and updated operational requirements (section 2, 4 and 5).
20/02/2022 - Content on this page may have changed location to conform to standard Dairy headings.
15/02/2022 - Updating links to further information (section 1.4).
27/05/2021 - References to export legislation have been updated.