Food Additives in Hong Kong: From 32 to 58 and Cumulative Exposure

Hong Kong has expanded its list of permitted preservatives and antioxidants from 32 to 58. Does that mean food has suddenly become more dangerous?

The answer is not a simple yes or no. A larger permitted list does not mean that 26 new “toxins” have been added to every food. It does, however, provide a useful opportunity to understand dose, frequency, food labels and cumulative dietary exposure.

What does the change from 32 to 58 actually mean?

Hong Kong’s Preservatives in Food (Amendment) Regulation 2024 updated definitions, food categories and maximum permitted levels. The Centre for Food Safety states that the total number of permitted preservatives and antioxidants increased from 32 to 58, including 24 additives that may be used according to good manufacturing practice.

The amendment also removed three previously permitted preservatives and introduced stricter limits for certain additive–food combinations. It is therefore more accurate to view the change as a regulatory update aligned more closely with Codex standards, rather than unconditional approval to add every listed substance to every food.

Food additives are not automatically poisons

Additives may help control microbial growth, slow oxidation, regulate acidity, maintain texture or improve product stability. Some substances used as additives also occur naturally in foods, including citric acid, ascorbic acid and acetic acid.

The World Health Organization explains that food additives are assessed before authorisation. The Joint FAO/WHO Expert Committee on Food Additives reviews toxicological, metabolic and dietary-exposure evidence and may establish an acceptable daily intake.

What are E numbers and INS numbers?

The International Numbering System provides standard identifiers for food additives. E numbers are commonly used on European labels. These numbers are identification tools—not toxicity rankings.

A numbered ingredient is not automatically dangerous, and an ingredient without a number is not automatically natural or risk-free. Its function, permitted conditions, actual intake and the consumer’s health circumstances all matter.

What is cumulative exposure?

People may encounter additives with similar functions in several foods during the same day. Bread, sauces, snacks, processed meats and frozen products may contain preservatives, emulsifiers, flavour enhancers, antioxidants or phosphates.

Cumulative exposure assessment may consider:

• total intake of the same substance from different foods;
• whether several substances act on the same organ or biological system;
• frequency and duration of exposure;
• differences in age, body weight, kidney function and metabolism.

EFSA uses the term “chemical mixtures” for the combined presence of two or more chemicals and continues to develop methods for assessing combined exposure, sometimes described as a “cocktail effect”.

This does not mean that all additives permanently accumulate in the body, or that several permitted additives will necessarily cause harm when present together. Dose, mechanism and duration remain essential.

What does acceptable daily intake mean?

An acceptable daily intake, or ADI, estimates the amount of a substance that can be consumed every day over a lifetime without an appreciable health risk. It is normally expressed per kilogram of body weight and incorporates safety factors.

ADI is not a boundary where one side is perfectly safe and a small amount above it causes immediate poisoning. It is a long-term risk-management value.

How should recent research be interpreted?

Recent large observational studies have explored statistical associations between intake of certain preservatives and outcomes such as cancer, hypertension and cardiovascular disease. These findings deserve continued research, but association does not prove direct causation.

People who consume more highly processed food may also differ in sugar, sodium, saturated fat and fibre intake, physical activity, sleep and other factors. A responsible conclusion is not that every preservative causes disease, but that long-term dietary patterns matter and that some additives require ongoing study.

Phosphates as an example

Phosphates may be used as acidity regulators, stabilisers, water-retaining agents or texture modifiers in processed meat, some seafood, baked goods, dairy products and drinks.

Phosphorus is an essential nutrient and occurs naturally in many foods. The relevant issue is total exposure from natural food and additive sources. People with impaired kidney function should follow individual medical or dietetic advice regarding phosphorus.

Five practical steps for reading food labels

1. Check the main ingredients. Ingredients are generally listed from highest to lowest weight.
2. Identify the function. Is it a preservative, antioxidant, colour, emulsifier, thickener, sweetener, flavour enhancer or water-retaining agent?
3. Look for repeated sources. Several foods consumed in one day may contain the same additive category.
4. Do not rely only on “no additives” claims. A product without preservatives may still be high in sugar, sodium or refined starch.
5. Consider frequency. Occasional consumption is different from daily dependence.

How can families reduce unnecessary exposure?

• Increase the proportion of fresh and minimally processed foods.
• Avoid making processed meats, ultra-processed snacks and ready meals everyday staples.
• Choose products with clear sourcing and understandable ingredient lists.
• Drink water more often instead of sweetened beverages.
• Rotate food choices rather than repeatedly relying on the same products.
• Do not panic because of a single unfamiliar number.
• Seek professional advice when managing kidney disease, asthma, allergies or metabolic conditions.

Why The Farm To Table Hub 2.0 focuses on real food

The Farm To Table Hub 2.0 is not intended to be only a place that sells food. Its wider purpose is to help families understand ingredients, sourcing and everyday food choices.

We value clear sourcing, understandable ingredients and avoiding unnecessary processing. Practical wellness is not about chasing an impossible “chemical-free” world. It is about knowing what you eat, how much you eat and how frequently you eat it—and building most meals around varied, recognisable and minimally processed foods.

Coming next in this series

Bobo Wellness will continue this series with guides to E and INS numbers, nitrites, sulphites, phosphates, artificial colours, thickeners, monosodium glutamate, sweeteners, ingredient lists and practical ways to reduce ultra-processed foods.

References

• Hong Kong Centre for Food Safety: Preservatives in Food (Amendment) Regulation 2024 FAQs
• World Health Organization: Food additives
• European Food Safety Authority: Chemical mixtures
• EFSA: Re-evaluation of phosphates as food additives
• NutriNet-Santé observational research
• NutriNet-Santé cardiovascular observational research