What each one covers
| Item | Restaurant licence | Restricted food permit |
|---|---|---|
| Covers | A food business selling meals or unbottled non-alcoholic drinks for consumption on the premises | Selling any food listed in Schedule 2 of the Food Business Regulation |
| Valid for | 12 months (full licence) | One year |
| Fee | General restaurant up to 100 m2: $1,110 to grant, $2,520 to renew, per year | $540 for one restricted food, or for sushi and sashimi; $1,360 for a vending machine (as stated to LegCo in April 2024) |
| Several restricted foods | Not applicable | Composite Restricted Foods Permit, $810, or $540 for hairy crab with other shellfish |
When the applicant already holds a valid FEHD licence, the permission is granted free of charge and stays valid as long as the licence; anyone else pays the prescribed fee in advance for a 12 month permission[1].
The restricted foods
Schedule 2 of the Food Business Regulation lists, among others: milk and milk beverages, soft ice cream and other frozen confections, Chinese herb tea, non-bottled drinks, cut fruit, leung fan, food sold by means of a vending machine, sashimi, sushi, oysters to be eaten raw and meat to be eaten raw[1]. FEHD's licence guide adds live fish and shellfish to the list of foods needing a permit[2].
Two details often missed: a milk permit is not needed for sterilized milk sold in sealed containers that FEHD has approved, and a shop with a soft ice cream machine needs a separate frozen confections factory licence on top of the permit[3].
General or light refreshment restaurant
A general restaurant licence permits any kind of cooking. A light refreshment restaurant licence allows only simple methods such as boiling, stewing, steaming, braising and simple frying, excluding deep frying and stir frying[2]. Both are restaurant licences; neither covers restricted foods on its own.
Applying for both at once
If you say when you apply for the restaurant licence that you intend to sell restricted foods such as sashimi and sushi, FEHD processes both together and, once you meet the requirements, endorses the permission on the licence free of charge[6]. A shop that does not run a restaurant, such as a fruit stall selling cut fruit or a drinks kiosk, applies for the permit on its own before it starts selling[3]. Since 1 January 2025 a shop selling several restricted foods can hold one Composite Restricted Foods Permit instead of a permit for each[3].
Selling without either
Operating a food business without a licence, or selling restricted foods without permission, is an offence with a maximum fine of $50,000 and imprisonment for six months[7]. The Regulation adds $900 for each day the offence continues[1].
Which to check first
List every item you plan to sell, mark any that appear in Schedule 2, and decide whether customers will eat on the premises. That tells you which applications to file together.
Rules, forms and figures can change, and the official pages listed below are the authority wherever this summary differs from them.