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Should Food Trade be Required to Conduct Mandatory Food Testing Regularly?

Should Food Trade be Required to Conduct Mandatory Food Testing Regularly?


(CMA Testing and Certification Laboratories)

In recent years, problematic foods are continuously found. This drives Taiwan Food and Drug Administration (TFDA) to propose a bill increasing the legal responsibility of food trade in self-management1. Starting from 31 July 2016, 17 types of food trade (in edible fats and oils, processed meat products, processed dairy products, aquatic products, food additives, special dietary foods, soybeans, corns, wheat, flour, starch, salt, sugar, soy sauce, tea leaves, tea beverages & general merchandise retailers excluding department store) are legally required to establish their own food safety monitoring programs by phases, so that hygiene and safety of foods sold in Taiwan can be better assured.

1 Source of Information: TFDA, 2015

The fine upon conviction shall be above NT$ 30,000 (~HK$ 7,500) but below NT$ 3 million (~HK$ 750,000). In addition, business operations and/or licenses (company, commercial and factory ones) of non-compliant companies may be suspended and cancelled respectively.

Mandatory Testing Requirements

The bill also sets out which items must be compulsorily tested for raw materials, semi-processed products and finished products, and how frequent food trade shall conduct the testing. Using traders of edible fats and oils as an example, the mandatory testing requirements include:

Regarding the mandatory testing requirements for other types of food trade, please refer to the TFDA guidance document available at

Notes to Establishment of a Food Safety Monitoring Program

When a food trader establishes her own food safety monitoring program, she must reasonably evaluate and choose test items superior or equivalent to the compulsory test items announced by the Taiwanese government. This shall be based on risk analysis and meet the principles of Hazard Analysis and Critical Control Points (HACCP), as well as take into account of factors like industry characteristics, production processes, supplier management and risk control. The final decision must be justified with appropriate supporting information. Food trade is required to control different critical points along the food supply chain, including source, production, storage and sale of food. Details of the control (including targets, control measures, frequencies and operators) shall be specified.

Should Food Trade in Hong Kong also be Required to Conduct Mandatory Food Testing Regularly?

To date, Hong Kong does not legally mandate food trade or importers to test their raw materials, semi-processed products and final products regularly.

Most food importers may simply rely on a test report provided by suppliers to conclude that their imported foods are safe for consumption and there’s no need to re-test the foods themselves anymore. However, it should be noted that test items chosen by the suppliers do not always cover all the hazards commonly associated with that food. Using tea leaves as an example, suppliers may just randomly choose 1 to 2 types of heavy metals and few pesticides for testing, and ignore other metallic contaminants and pesticides commonly found. In other words, selection of test items by suppliers is not based on risk analysis. This implies that food passing the “limited” testing conducted by suppliers is not necessarily safe.

Some local food trade or importers who care about food safety may voluntarily test their foods. However, the testing is usually one-off and not conducted periodically. For example, only first batch of imported / manufactured food will be tested; while the subsequent batches will be not tested anymore if the first batch is found satisfactory. It should be noted that satisfactory result of a batch cannot guarantee the safety of other batches in the future. Food trade should therefore conduct their own testing periodically before they can conclude that their raw materials, semi-processed products and final products are “really” and “continuously” safe.

In my opinion, self-management of food trade is a key to safeguard food safety. As such, Hong Kong should adopt the TFDA’s approach. Hong Kong government should list out the compulsory test items for some “high risk” foods and mandate the food trade to conduct a risk-based testing. This shall help to safeguard the interest of consumers and also upgrade the overall food safety management standard of local food trade.