Hong Kong: The Evolving Regulatory Landscape for Cultured Meats

As governments worldwide consider the potential contribution of alternative proteins to the overall national food security and food technology innovation, a few jurisdictions have developed guidance for clearing cultured meat and other novel protein ingredients. For instance, Singapore, the United States, and South Korea have each set out processes or guidance for the safety assessment and regulatory review of cell-cultured food products. Against this backdrop, Hong Kong has also issued guidance on how cultured meat may be assessed to confirm safety before entering the local market.

Specifically, the Centre for Food Safety (CFS) published the Technical Guidance Notes on the Safety Assessment of Cultured Meat [1], in which CFS stated that, before cultured meat is imported into Hong Kong for sale or manufactured locally for human consumption, the trade should submit safety assessment data to CFS for evaluation. This provides clear regulatory instructions to industry if they wish to launch such products in Hong Kong, noting that Hong Kong does not yet have a novel food approval system.

Specifically, the guidance outlines the types of information generally expected in a safety assessment, covering product characterization, production process, compositional data, specifications, proposed uses and levels of consumption, absorption, distribution, metabolism and excretion information, nutritional information, toxicological information, allergenicity, analytical detection methods, and safety assessment reports conducted by food safety authorities in other countries or regions.

For companies that have already pursued cultivated meat reviews in Singapore, the United States, Israel, Australia/New Zealand, or other jurisdictions, much of the underlying scientific and safety information may already be available, and, therefore, preparing a dossier based on Hong Kong’s requirements may be relatively “easier.” Thus, from a market-entry perspective, it is worthwhile to add Hong Kong to the list of go-to markets.

At present, the CFS guidance specifically addresses cultured meat. Other alternative protein products, such as biomass fermentation ingredients and precision-fermentation proteins, may raise different regulatory questions. These products should still be reviewed under Hong Kong’s general food safety, ingredients, contaminants, allergens, labeling, and advertising requirements.

We will continue to report regulatory updates on alternative proteins across Asia. Please sign up for our newsletters here.

Keller and Heckman represents the food industry, including alternative protein companies around the world, on various regulatory matters. If you have any questions about novel food application or need any assistance in better understanding the regulatory landscape of alternative proteins in Asia, please do not hesitate to contact David Ettinger (ettinger@khlaw.com), Jenny Xin Li (li@khlaw.com), or your existing contact at Keller and Heckman LLP.

[1] https://www.cfs.gov.hk/english/whatsnew/whatsnew_fst/files/Technical_Guidance_Notes_on_Safety_Assessment_of_Cultured_Meat.pdf