Is “Light Refreshment” now a viable low cost food business to build in Hong Kong?

By HK Lawyer AJ Halkes Barrister-at-Law

New approaches mean a wider range of foods can now be offered in Hong Kong to unlock revenue

Quietly the Food and Environmental Hygiene Department in Hong Kong streamlined the scope of what activities can take place in a light refreshment restaurant licensed premises. This is of interest to anybody in the food and beverage business, where the right food offering is essential for the success of the business involved but the costs of fit-out and ventilation installations can be very high; specially if a full restaurant licence is being applied for.

Back in the day

Up to Q2 of 2023, the operator of a food and beverage premises under a light refreshment restaurant license had to make a choice; either they faced a narrow six list choice; from western style snacks to “Chinese” versions; which basically revolved around dim sum, and relatively simple dishes. These separate lists were literally “vintage” in what they described yet deviation from the approved items lists was a breach of the conditions of the licence.

I’ve not come across many prosecutions for deviating from these lists or offering products essentially not permitted as the reality was often that some operators took some latitude and expanded their line, the old lists were historical and for some had become totally unrealistic in the 2020’s.

Fast forward:

The good news is that these approaches have been abandoned in favour of the cooking method.

As COVID restrictions ended in 2023; Light Refreshment Restaurants can now sell almost any food item that needs boiling, stewing, steaming, braising and simple frying (excluding deep frying and stir frying). The exclusion of deep-fry & stir-fry was claimed to be to avoid greasy fumes during food preparation; though cooking, or food re-heating activities, like hotpot, Teppanyaki or Korean style BBQs are allowed in seating areas. Ultimately the ventilation needs of deep-fat-frying remain in place; however it all represents moves in the right direction.

Of course deep fat frying of traditional donuts and things like chips will be still seen by many as the only way to go at a snack business : however the old categories remain options for anyone who doesn’t want the new flexibility.

It seems that food and beverage licensing in Hong Kong sometimes moves painfully slowly and falls behind the times; often decades behind. However, the government is finally moving on loosening restrictions and hopefully we can look forward to more enlightened and industry supportive approach aligned with the modern food and beverage landscape. Hong Kong has no reason to be saddled with regulations that are decades behind the needs of the fast moving and highly competitive hospitality industry.

The Six Groups of Approved Food Items for Light Refreshment Restaurants

Reforming the Food Business Licensing Regime – Relaxing the Restrictions on Food Items Sold by Light Refreshment Restaurants

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