Stakeholders call for Hong Kong seafood import regulation overhaul amid traceability concerns

Civil society organizations in Hong Kong, China, are calling on the government to “urgently” address critical gaps in the city’s seafood import regulations, which they insist are posing risks to public health, marine ecosystems, and consumer trust.

Hong Kong is one of the top seafood importers by value and volume, with average volumes of seafood imports to the city (both live and dead) amounting to over 350,000 metric tons per annum, according to the Hong Kong-based Asian investment management firm ADM Capital Foundation.

In an official letter to the authorities, the consortium has urged the government to review existing legislation and policy developments related to seafood trade. 

“Our call for action responds to the findings of research released over decades by different academics and NGOs, that continue to point to the same systemic issues which remain unresolved today,” says Sophie le Clue, CEO of ADM Capital Foundation.

Need for government intervention

Seafood importer 178 Degrees’ founder, Benjamin So, calls for a “level playing field” in the industry with government intervention and support.

“To remain competitive, Hong Kong must align with international standards and best practices by strengthening import controls. While certain leading businesses in the industry have been promoting sustainable seafood for years, and expending resources to ensure their seafood is sourced responsibly and sustainably, the issue is ignored by many in the sector.”

Hong Kong Sustainable Seafood Coalition (HKSSC)’s secretariat, Mandy Wong, echoes the need for government support.

“The HKSSC was established by industry leaders to advance sustainable seafood practices in Hong Kong and Macau. Our corporate members are deeply committed to responsible sourcing and are dedicated to mainstreaming sustainable seafood.”

“However, without government policies and legislation to address unethical practices and encourage responsible procurement, there are limits to what we can achieve.”

Hong Kong imports nearly 350,000 metric tons of seafood (both live and dead) annually (Image credit: Paul Hilton / Earth Tree Images).

Lack of import traceability

The coalition warns that Hong Kong’s current regulatory framework “dates back to the 1940s” and fails to ensure the safety, sustainability, and traceability of seafood products entering Hong Kong.

The city serves as an important hub for seafood trade in Asia, including luxury products like live reef food fish, shark fin, and fish maw. Most of its imports are re-exported to mainland China and other regional markets.

However, ADM calls the traceability for these imports “insufficient,” with its recent report stating that of all the data necessary to ensure sufficient traceability, “the Hong Kong authorities only require collection of 12% of such data.” 

This is in stark contrast to the city’s trading partners (mainland China, Japan, South Korea, Indonesia, the EU and the US), who are making “substantial efforts” to develop and implement measures to facilitate traceability.

Targeting such efforts can benefit suppliers and buyers in sourcing responsibly and sustainably, as well as consumer health and well-being, notes the firm.

Ethical and health concerns

According to ADM, Hong Kong’s seafood consumption is “exceptionally high” due to its dense population, affluent economy, and cultural preference for fresh seafood. 

Lydia Pang, head of Oceans Conservation at WWF-Hong Kong, expresses concern over consumer health. She explains that “while some businesses are proactive and engaged, without sufficient traceability requirements, we continue to risk consuming seafood that may be harmful to our health, sourced through illegal fishing practices, or contributing to the depletion of global fish stocks.”

Seafood consumption in Hong Kong is very high, owing its dense population and cultural preference for fresh seafood. A study by the University of Hong Kong (HKU) also pointed to significant data gaps in the live reef food fish trade, valued at over US$2 billion. 

“Such gaps lead to a multitude of issues — environmental harm through overfishing and ecosystem damage, economic losses, and illegal fishing,” says professor Celia Schunter from HKU.

“They also give rise to ethical concerns, such as labor exploitation, health risks, and present a slew of regulatory challenges.”

Targeting collaborations and safety

The consortium has listed a series of recommendations on traceability, health and safety, port measures, and stakeholder collaboration in its letter to the government.

To enhance traceability, they suggest adding Key Data Elements like the species’ scientific name, catch/farming method, and location and focusing on digital traceability standards. 

Amendments to the Fish Marketing Ordinance to include live fish, crustaceans, and mollusks are also recommended, as is the need for all Class III fish carrier vessels to comply with Marine Department clearance. 

They also call for mandatory health certificates, stricter import checks to ensure health and safety, and landing all seafood at designated ports for quarantine and monitoring. 

At the port, Hong Kong-registered vessels should report entry/exit and align with the FAO’s Transshipment Guidelines, adds the consortium.

Recommendations also include promoting stakeholder and government, industry, and NGO collaborations.

Last month, Food Ingredients First spoke with Rabobank to discuss the global seafood industry’s growth this year, as its report revealed that seafood is outpacing other protein sources globally.