Skip to content

Swiss Chinese Law Association — Geneva

SCLA | Swiss Chinese Law Association

Legal Observatory / Sustainability and Responsibility

Explained China Hong Kong SAR Rules in force

Hong Kong SAR Addresses Non-Plastic Tableware Safety Risks, PFAS Testing, and Biodegradable Plastic Regulations

The Hong Kong SAR Secretary for Environment and Ecology delivered a Legislative Council written reply detailing PFAS safety risk assessments for tableware alternatives and clarifying the regulatory rationale regarding biodegradable plastics.

What Changed

  • Government confirmed overseas study data shows PFAS chemical leaching from paper and bamboo straws under normal use is far below public health risk thresholds.
  • The Green Tableware Platform Secretariat (HKQAA) proactively invited tableware suppliers to submit additional quality and PFAS testing proof from accredited bodies.
  • Hong Kong SAR maintained regulatory restrictions on biodegradable plastics such as PHA due to unproven degradation in landfill anaerobic conditions and ongoing marine life risks.

### Background: Regulation of Disposable Plastic Tableware in Hong Kong SAR

On October 7, 2026, the Secretary for Environment and Ecology, Mr Tse Chin-wan, delivered a written reply in the Legislative Council of Hong Kong SAR to a parliamentary inquiry raised by the Hon Steven Ho regarding safety risks associated with non-plastic disposable tableware and the broader regulatory framework governing alternative materials. This discussion follows the implementation of the first phase of regulation on disposable plastic products, which came into force on April 22, 2024.

The foundational motivation behind regulating disposable plastic tableware in Hong Kong SAR stems from the profound environmental and public health harms caused by persistent plastic waste. Conventional plastics do not decompose easily and can persist in natural environments for hundreds of years, breaking down over time into microplastics. When microplastics enter marine ecosystems, they are ingested by marine organisms and enter the human food chain, posing potential threats to human and animal health. Consequently, reducing disposable plastic waste at source is a key component of Hong Kong SAR's broader waste management and environmental protection strategy.

The primary policy objective established by the Environmental Protection Department (EPD) is source reduction through encouraging the public to adopt reusable tableware. Non-plastic disposable tableware is intended strictly as an intermediate alternative when the use of single-use items is unavoidable. According to government statistics, since the regulation took effect on April 22, 2024, implementation has yielded measurable results: major chain restaurants have reported that over 80 per cent of takeaway customers decline disposable cutlery, leading to an estimated annual reduction of over 60 million sets of single-use cutlery disposed of in landfills.

### Assessing Chemical Exposure and PFAS Risks

The Legislative Council inquiry raised safety concerns regarding per- and polyfluoroalkyl substances (PFAS)—a class of chemically stable, synthetic substances valued for their water-resistant, oil-resistant, and low-friction properties. PFAS are widely utilized as surface coatings across various consumer products, including waterproof clothes, protective paper films, food packaging materials, cookware, and plastic products. Because of their persistent nature, concerns have been raised regarding potential health risks—such as endocrine disruption and elevated cancer risks—associated with chronic exposure or chemical leaching when non-plastic tableware alternatives are exposed to acidic or high-temperature environments for prolonged periods.

Addressing these concerns, the Secretary for Environment and Ecology cited findings from an overseas university research team that conducted chemical analyses on straws made from various materials available on the market, including paper, bamboo, plastic, and glass. While PFAS were detected across these different materials, the research data showed that under normal conditions of use, the total amount of chemicals released by these utensils remains extremely low. The government emphasized that these release levels are far below established thresholds for health risks and therefore pose no threat to public health.

### Regulatory Oversight via the Green Tableware Platform

To assist the catering sector in adopting compliant non-plastic alternatives, the Environmental Protection Department established the Green Tableware Platform. The Platform acts as a centralized information repository for food businesses seeking non-plastic tableware that satisfies regulatory standards.

Under the operational mechanism of the Green Tableware Platform:

- Tableware suppliers seeking to register products must submit official material testing reports or certificates.

- Documents must be issued by accredited testing laboratories or recognized inspection bodies to prove compliance with non-plastic material criteria.

- The Secretariat of the Green Tableware Platform is operated by the Hong Kong Quality Assurance Agency (HKQAA).

- Since 2024, the HKQAA Secretariat has proactively invited registered tableware suppliers to provide supplementary evidence regarding product quality and performance, specifically including testing reports concerning PFAS.

### Evaluation and Current Stance on Biodegradable Plastics

The Legislative Council inquiry also raised questions regarding the regulation of biodegradable plastics, such as polyhydroxyalkanoate (PHA), which have seen application in mainland China and other markets. The inquiry questioned whether Hong Kong SAR would adjust its regulatory stance to accommodate biodegradable plastic materials capable of decomposing in natural environments.

In response, the government detailed its rationale for maintaining regulatory restrictions on biodegradable plastics. The core policy priority remains waste reduction at source and preventing plastic materials from entering ecosystems. The Secretary noted that current scientific evidence remains insufficient to prove that biodegradable plastics like PHA can fully decompose under the actual anaerobic conditions present within municipal landfills. Furthermore, even in marine environments where certain biodegradable plastics degrade, the process generally requires several months or even years. During this period, floating or submerged items continue to pose ingestion and entanglement threats to marine life. Additionally, the industrial manufacturing processes of biodegradable plastics often involve chemical additives that carry distinct environmental impacts.

Nevertheless, the Hong Kong SAR Government affirmed that it maintains an open-minded approach. The authorities will continue to monitor international scientific developments, evolving technical standards, and practical application outcomes regarding biodegradable plastics, including PHA, to review and adjust regulatory strategies as necessary while balancing public health, environmental benefits, and user experience.

---

### Frequently Asked Questions

**Q1: What is the main objective of Hong Kong SAR's regulation on disposable plastic tableware?**

**A1:** The main objective is to reduce plastic waste at source, prevent plastic items from breaking down into microplastics in marine ecosystems, and encourage the public to bring their own reusable tableware.

**Q2: Are non-plastic tableware alternatives, such as paper or bamboo straws, considered safe regarding PFAS exposure?**

**A2:** Yes. Citing an overseas university study, the government noted that while trace amounts of PFAS were detected in paper, bamboo, plastic, and glass straws, the chemical release under normal conditions of use is extremely low, far below health risk thresholds, and poses no threat to public health.

**Q3: How does the Green Tableware Platform verify tableware safety and compliance?**

**A3:** Managed by the Hong Kong Quality Assurance Agency (HKQAA) as Secretariat, the Platform requires suppliers to submit testing reports or certificates from accredited laboratories proving non-plastic material compliance. Since 2024, the Secretariat has proactively invited suppliers to provide additional performance proof, including PFAS testing data.

**Q4: Why does Hong Kong SAR continue to regulate biodegradable plastics like PHA?**

**A4:** There is currently insufficient evidence showing complete degradation under actual landfill anaerobic conditions. In marine environments, degradation can take months or years, during which marine life remains threatened, and manufacturing processes may involve chemical additives.

**Q5: Will the Hong Kong SAR Government review its rules on biodegradable plastics in the future?**

**A5:** The Government stated it will remain open-minded, monitoring international scientific research, evolving standards, and practical application outcomes to review and adjust regulatory strategies as necessary.

Who May Be Affected

Catering operators, takeaway food vendors, disposable tableware manufacturers and suppliers, and consumers in Hong Kong SAR.

Cross-Border Context

Compares Hong Kong SAR's regulatory approach on non-plastic alternatives and biodegradable plastics (PHA) with practices in mainland China, Europe, and the United States.

What to check next

  • Monitor official announcements from the Environmental Protection Department and the Green Tableware Platform regarding updated testing requirements for registered tableware suppliers.
  • Track government statements regarding future reviews of biodegradable plastic regulations as international scientific consensus evolves.

This article provides general information and does not constitute legal advice. Consult the official text and obtain advice appropriate to your circumstances where needed.

Keep the issues that matter to you in view

Subscribe to SCLA updates and choose your interests.