Food Commons Foundation Submission on the 2026 Policy Address

Promoting a "Business-NGO Direct Linkage with Tax Incentives" Food Rescue Mechanism – Transforming Surplus Food into Community Resources for Targeted Poverty Alleviation

The Foundation urges the Government to spearhead cross-departmental collaboration in the 2026 Policy Address to promote a "Business-NGO Direct Linkage, Resource Matching" surplus food rescue mechanism. Specific recommendations are as follows:

1. Introduce Tax Incentives: Amend the Inland Revenue Ordinance to establish a "150% Green Food Waste Super Tax Deduction" to encourage private enterprises to directly fund charitable organisations in food rescue and assistance.

2. Revise Government Tenders: Improve standard tenders issued by the Environmental Protection Department (EPD) and the Food and Environmental Hygiene Department (FEHD) by incorporating "Surplus Food Priority Interception" clauses, reallocating a portion of the budget from back-end food waste disposal to front-end poverty alleviation.

3. Improve Supporting Measures: Provide government markets and idle government land as nominal-rent transit points, and legislate a Good Samaritan food donation exemption clause to alleviate business concerns.

Background and Operational Performance

As of March 2026, the Foundation's relevant projects have cumulatively recovered over 11,467 metric tonnes of edible food in local communities, benefiting over 10.23 million person-times. According to SROI calculations, for every $1dollar invested in community food recovery, it can create a comprehensive social benefit equivalent to 6.5 dollars.

Through a model of "businesses and businesses tender funding, government provision of space, and charitable organisations providing labour," perishable fruits, vegetables, and bread that would otherwise be sent to landfills are distributed "point-to-point" to grassroots recipients during market and store closing hours. This simultaneously achieves a win-win situation: reducing landfill tipping fees, lowering public healthcare expenditure, enabling businesses to fulfil ESG commitments at low cost, and improving nutrition for the grassroots. This steadily responds to the city's first "Five-Year Plan" targets for green transition and targeted poverty alleviation.

I. A "Four-Party Win-Win" Resource Restructuring Framework

This mechanism aims to redirect societal resources currently spent on "waste disposal" and "medical subsidies" towards the frontline food-sharing network:

Ÿ   Government and Taxpayers (Reducing Fiscal Burden and Landfill Pressure): Through minor tax margin concessions and tender structure adjustments, the government can save landfill disposal fees. With stable business funding and tender support, community groups can also reduce their reliance on traditional public funding (e.g., from the Environment and Conservation Fund).

Ÿ   Business Sector (Achieving ESG Carbon Reduction Goals at Very Low Net Cost): After tax benefits, enterprises can achieve significant food waste reduction at very low net cost, while building a brand image as a socially responsible corporate citizen.

Ÿ   Charitable Organisations (Breaking Funding Bottlenecks, Building Stable Operational Teams): Institutionalised cooperation ensures the stability of frontline recovery staff and logistics management teams, maintaining the healthy operation of a territory-wide green logistics network.

Ÿ   Grassroots and Elderly (Improving Nutritional Intake, Reducing Public Healthcare Pressure at Source): The direct linkage model significantly shortens transit time, delivering fresh produce and bread to grassroots and elderly recipients on the same evening. Adequate nutrition for the elderly strengthens immunity, directly reducing emergency visits and hospitalisations due to chronic disease exacerbation, thereby alleviating pressure on the public healthcare system from the source.

II. A "Three-Tier, Three-Track" Direct-Link Food Rescue Safety Net

To enable efficient direct linkage between diverse surplus food sources across Hong Kong and welfare organisations, the policy should be implemented in three tiers according to local conditions:

Tier 1: Large Chain Supermarkets and Restaurant Groups (Enterprise Self-Managed Direct Linkage Model)

Ÿ   Operational Mechanism: Large supermarkets and groups directly coordinate with charitable organisations, funding frontline logistics "cash administrative costs" (including staff salaries, transport, and data auditing).

Ÿ   Tax Arrangement: Enterprises submit special "Green Receipts" issued by charitable organisations to the Inland Revenue Department to claim a 150% profits tax super deduction.

Tier 2: Private and Outsourced Market Management Companies (Centralised Coordinated Direct Linkage Model)

Ÿ   Operational Mechanism: For fragmented individual stallholders (e.g., vegetable stalls), the market operator or "management company" acts as a single reporting entity, uniformly paying "Market Food Rescue Administrative Fees" to support charitable organisations' frontline recovery.

Ÿ   Tax Arrangement: The management company similarly claims the 150% tax deduction and includes it in its ESG report, overcoming the obstacle that individual operators cannot participate in tax filing.

Tier 3: Public Venues and Government Markets (Tender Function Extension Model)

Ÿ   Policy Pivot: Drawing on the EPD's "Food Waste Collection Pilot Scheme" launched in 2021, the government should extend the policy function of existing food waste collection tenders and FEHD public markets' routine cleaning and waste reduction contracts from "back-end disposal" to "front-end surplus food interception".

Ÿ   Tender Sum Allocation: Contracts should explicitly stipulate that contractors must, before delivering food waste to O·PARK1, prioritise intercepting surplus food that meets food safety standards and subcontract it to charitable organisations recognised under Section 88. The "rescue administrative fees" paid to charitable organisations shall be directly listed as part of the regular tender sum. The contractor acts solely as an intermediary and is not eligible to claim tax deductions, thoroughly eliminating the risk of double deduction.

III. Government "Spatial Resources" and "Legal Exemption" Supporting Measures

To remove frontline operational obstacles, the government should provide support from two key sources: "rent" and "regulations":

1.       Revitalise Idle Government Space: Prioritise allocating vacant stalls in government markets and idle government land to recognised charitable organisations at nominal rent (e.g., $1 per month) for use as regional "surplus food sorting and transit stations".

2.       Establish On-site "Food Rescue Direct-Link Workstations": When redeveloping large government markets, reserve small workspaces equipped with basic electricity and rodent-proof facilities to enable "on-site weighing, sorting, and transport", minimising cross-district transport costs.

3.       Introduce a "Good Samaritan Food Donation Exemption Clause": Drawing on established international legislation, incorporate an exemption clause into local law. Explicitly stipulate that food suppliers and charitable organisations, acting in good faith and where the food meets basic food safety standards at the time of donation or recovery, shall be exempt from liability for subsequent unintentional or unforeseen consequences, thereby completely eliminating business concerns.

IV. Anti-Abuse and Management Mechanisms

Ÿ   Adopt Inland Revenue Ordinance Section 88 and IoT Weighing Systems: Fully utilise the existing list of tax-exempt charitable organisations in Hong Kong without establishing new approval bodies. Charitable organisations will implement "IoT smart weighing and cloud-based direct-connect systems" for automated data upload and auditing, eliminating additional administrative burdens.

Ÿ   Reimbursement and Auditor Verification: The Tier 1 and 2 150% super deduction is strictly limited to "frontline logistics and operational administrative costs" paid to charitable organisations. Claims require "Green Food Waste Receipts" issued by charitable organisations and annual audited accounts by independent auditors, with a cap of 15% of the enterprise's total assessable profits per year to prevent tax evasion risks.

Ÿ   Strictly Prohibit Commercial Resale and Ensure Food Safety: Received items must be 100% distributed for free to vulnerable groups; commercial resale is strictly prohibited. Standardised recovery guidelines should be established based on the "Food Safety Guidelines for Food Recovery Programmes" compiled with assistance from the FEHD's Centre for Food Safety, recovering only surplus food that complies with Hong Kong food safety laws and is of sound quality.

Conclusion

"Direct linkage between suppliers and welfare organisations" is the most effective use of resources to ensure the freshness, safety, and logistics efficiency of surplus food. Through "150% tax deduction for private initiatives," "extension of existing food waste tender functions," "idle space support," and "legal exemption clauses," the government can establish a territory-wide food rescue safety net at very low marginal public fiscal cost. This would serve as a key policy in the 2026 Policy Address for implementing green transition and targeted poverty alleviation, precisely aligning with the HKSAR Government's first "Five-Year Plan" and the Policy Address's deployments to boost the economy, promote development, and enhance citizen well-being.

Annex 1: Financial and Comprehensive Social Benefit SROI Model Explanation

1. Detailed Government and Enterprise "Tax Deduction and Forgone Revenue" Accounting (Exclusive to Private Initiatives)

Based on Hong Kong's current 16.5% profits tax rate, assuming a private enterprise directly pays $5,000 cash to a charitable organisation for a quarter's "rescue administrative fees":

2. Institutionalised Pricing Based on SROI 1:6.5 "Administrative Cost per kg of Food"

Based on the SROI financial valuation logic, the estimated comprehensive social value per kilogram of fresh surplus food is as follows:

Ÿ   Value of Substituted Food Aid (1 kg food = 1.2 meals, $30 substituted cost):36/kg

Ÿ   Environmental Waste Reduction & Carbon Sequestration Value (avoided landfill fees and methane emissions): $5/kg

Ÿ   Public Healthcare Expenditure Savings (improved nutrition for elderly, reduced medical visits):

Ÿ   Total Comprehensive Social Output Value per kg of food rescued: $53/kg

Pricing Implementation and Cost Allocation for Charitable Organisations:

Ÿ   Standard Weight-Based Settlement: When SROI reaches a high-efficiency return of 1:6.5, the institutionalised administrative cost per kg of food should be set at HK$5.5-6.5. Whether funded by private tax deduction (Tiers 1 & 2) or government tender allocation (Tier 3), settlement is based on actual weight measured, covering frontline staff salaries, logistics, and reasonable technology & audit management administrative expenses.

Ÿ   Special Cooked Food Settlement: For cooked food rescue with high time-sensitivity and insulation requirements, the administrative fee is calculated as "fixed transport fee + (number of dispatched staff × industry hourly wage) + 10% administrative management fee".

Annex 2: International Reference Cases on Green Food Rescue Policies and Legal Exemptions

Ÿ   United States (Good Samaritan Food Donation Acts):

n   Bill Emerson Good Samaritan Food Donation Act (1996): Protects suppliers and non-profits donating "apparently wholesome food" in good faith from civil or criminal liability.

n   Food Donation Improvement Act (2023): Further extends protection to "low-value good faith donations" and "direct donations to individuals," significantly reducing donation risks for businesses.

Ÿ   Taiwan (Food Donation Safety and Civil Law Principles):

n   The Ministry of Health and Welfare has established the "Guidelines for the Hygiene and Safety of Short-shelf-life and Immediate-consumption Food Donations," clearly defining responsibilities for packaging, storage, and distribution of short-shelf-life food, and combined with civil law principles on gratuitous gifts to mitigate negligence liability for good-faith donors.

Ÿ   France (Excess Tax Credits and Mandatory Donation):

n   LOI n° 2016-138 (2016) and LOI n° 2020-105 (2020): Mandate large supermarkets to sign surplus food donation agreements with charities; the French tax authority provides a tax credit of up to 60% of the donated inventory's value. (Note: The Foundation recommends adopting a 150% profits tax deduction (Tax Deduction) consistent with Hong Kong's tax system.)

Ÿ   Singapore (Grants and Cost Write-offs):

n   Resource Sustainability Act (2019) and Food Waste Funding Scheme: Require large malls and hotels to manage food waste, providing grants of up to SGD 100,000 to support installation of treatment systems, and allowing relevant expenses to be written off for tax purposes.

Ÿ   EU and Netherlands (Green Public Procurement Clauses):

n   Directive 2014/24/EU: Allows inclusion of environmental and social criteria in public procurement. Several local governments in the Netherlands and elsewhere have stipulated in waste treatment tenders that contractors must intercept a portion of surplus food and subcontract it to NGOs.

4 August 2026

Recommendation for the Shared Food Fund's 2026-27 Budget

To: Financial Secretary Mr. Paul Chan

This proposal suggests that the "regional food resource sharing" model be institutionalized in the 2026-27 fiscal budget. Through regular funding, space planning, tax incentives, inter-agency collaboration, and community nutrition support, the excess food generated daily in markets and retail outlets can be transformed into community capital.

Our practical experience shows that every 1 yuan of public funds invested generates a 6.5 yuan Social Return on Investment (SROI), making it the most cost-effective tool for targeted poverty alleviation and waste reduction policies.

Furthermore, referencing the successful experience of Shenzhen's Futian District's 24-hour "Food Bank," it is demonstrated that government incentives such as public welfare labeling, tax deductions for donations, and honorary awards can effectively increase corporate participation and form a stable food resource recycling network.

This proposal aims to assist the government in implementing "high-quality development" and "strengthening community resilience" in its 2026 policy objectives, and to achieve the triple policy goals of waste reduction, support for the vulnerable and community governance at low cost.

I. Policy Background

• Hong Kong generates a large amount of surplus food that is still edible every day, but most of it ends up in landfills.

• The community-based "collect and distribute" model has proven effective in many areas, enabling rapid recycling and local sharing in a low-carbon and low-cost manner.

• The government's 2026 policy direction of "high-quality development" and "strengthening community resilience" presents an opportunity to incorporate food resource recycling into institutionalized support.

• Operational data from local non-profit organizations demonstrate that localized models are highly efficient, cost-effective, and sustainable, making them important tools for targeted poverty alleviation and waste reduction policies.

II. Policy Opportunity

When formulating the 2026-27 Budget, the government can leverage institutionalized funding and space allocation to allow experienced organizations to deeply engage with communities, ensuring that surplus food from markets and businesses does not end up in landfills but is instead transformed into resources for neighborhood mutual aid.

This approach simultaneously addresses:

• Waste reduction and carbon emission policies

• Financial pressures on low-income families

• Community resilience and mutual aid networks

• Public finance efficiency

III. Specific Recommendations

1. Space Development: Establish Regular "Community Food Sharing Stations"

Recommendations

• Establish "Community Food Sharing Stations" in vacant or recyclable spaces within existing public housing estates (such as former mutual aid committee sites and vacant shops).

• Reserve independent spaces in the planning of new housing estates and new development areas (including the Northern Metropolis).

• Include food sharing stations in regular funding programs.

Benefits

• Enable professional organizations to cultivate long-term community involvement.

• Prevent edible resources from ending up in landfills, directly converting them into community capital.

• Reduce future costly redevelopment.

2. Financial Incentives: Implementing "Food Resource Recycling Tax Incentives" and "Green Label" Certification

Recommendations

• Profits Tax Deduction: Provide reasonable tax deduction arrangements for businesses donating excess food.

• Green Label and Public Welfare Marking: Establish an official certification system to recognize actively participating businesses.

• Honorary Award System: Referring to the practices of Futian District, Shenzhen, establish an annual "Food Saving Partner" or "Waste Reduction Contribution Award."

• Policy Incentive Integration: Give appropriate priority to certified businesses in government leasing, procurement, or market arrangements.

Benefits

• Drive business behavior transformation through financial and reputational incentives.

• Compensate merchants for labor costs, increasing their willingness to donate.

• Align with waste charging policies, transforming "disposal costs" into "public welfare."

• The Shenzhen case demonstrates that this model can attract a large number of enterprises to participate long-term.

3. Planning Support: Mandatory Reserved Space for Food Recycling in New Development Areas

Recommendation

• Mandatory reservation of food recycling and sharing space during the planning phase of the Northern Metropolitan Area and new markets.

• Spaces should be located near markets, shopping malls, or transportation hubs to support the "collect and sort" model.

Benefits

• Avoids future renovation costs.

• Accelerates pilot implementation, supporting waste reduction and carbon reduction goals.

4. Human Resources: Supporting "Localized Human Resources" and Professional Management

Recommendations

• Establish a special fund to appoint grassroots residents in the district as "Food Saving Ambassadors."

• Responsible for ensuring the quality of food recycling in markets, timely sorting, and distribution in the vicinity.

Benefits

• Create local green jobs.

• Maintain a low-carbon, low-manpower, and high-efficiency model.

• Strengthen residents' sense of belonging and cohesion within the community.

5. Community Support: Strengthening the "Community Nutrition Mutual Aid Network"

Recommendations

• Support sharing stations in providing "community nutrition subsidies," directly benefiting the elderly and low-income families.

• Collaborate with nutritionists and social welfare organizations to provide healthy eating education.

Benefits

• Alleviate the pressure of the cost of living.

• Establish a closer mutual aid safety net.

• Enhance the overall health and resilience of the community.

IV. Fiscal Impact

• High Return on Investment: Every NT$1 invested in public funds generates up to NT$6.5 in social returns.

• Waste Reduction Benefits: Reduces waste disposal costs for businesses and decreases carbon emissions.

• Public Finance Benefits: Achieves the triple goals of waste reduction, support for vulnerable groups, and community governance at low cost.

V. Recommendations for Inter-departmental Collaboration

It is recommended that the Financial Secretary lead the establishment of an inter-departmental collaboration mechanism, including:

• Environment and Ecology Bureau: Coordinating waste reduction and carbon emission policies.

• Labour and Welfare Bureau: Supporting low-income families and the elderly.

• Housing Bureau: Providing space planning and housing estate facilities.

• Homeand Youth Affairs Bureau: Coordinating district networks and community spaces.

Inter-departmental collaboration can avoid duplication of investment and improve policy continuity and effectiveness.

VI. International and Regional Cases

• Shenzhen Futian District 24-Hour Food Bank: Successfully attracted 87 companies to participate through incentives such as public welfare labeling, tax deductions for donations, and honorary awards, forming a stable food resource recycling network.

• EU CULTIVATE Scheme: Emphasizes integrating food systems into urban planning and community participation.

• UK WRAP Scheme: Assists retailers in reducing food waste through "Target, Measure, Act".

• Australia End Food Waste CRC: Promotes nationwide waste reduction through government funding and cross-sectoral collaboration.

These cases demonstrate that, when coupled with policy incentives, spatial planning, and community participation, food sharing can become a crucial infrastructure for urban governance.

"Regional food resource sharing" is a low-input, high-efficiency model originating from local practices and gradually maturing, capable of simultaneously addressing multiple policy objectives such as waste reduction, support for vulnerable groups, and community building.

We earnestly request the Government to recognize the professional value of this model in the 2026-27 Budget and support its continued and orderly development across districts through institutionalized funding, spatial planning, and inter-departmental collaboration, thus opening a new chapter for resource utilization and community mutual assistance in Hong Kong.

Food Commons Foundation

January 12, 2026

CC: Environment and Ecology Bureau

Labour and Welfare Bureau

Housing Bureau

Home and Youth Affairs Bureau