[Home](/)/[Resources](/resources)/Hong Kong Air Pollution VOC Hong KongEnvironmental # Hong Kong Air Pollution Control Ordinance: VOC Restrictions Affecting Electronics Coatings Conformal coatings, PCB adhesives, and assembly solvents can fall within Hong Kong's VOC content limits under Cap. 311P. Electronics manufacturers and importers need to verify VOC compliance before products reach the Hong Kong market — and ensure labeling reflects the regulated content declaration. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fhong-kong-air-pollution-voc) At a glance Regulation Air Pollution Control (VOC) Regulation (Cap. 311P) Administrator Environmental Protection Department (EPD) VOC limits By product category (g/L) Applies to Manufacturers, importers, suppliers ## VOC regulation and electronics products ### VOC Regulation scope Cap. 311P sets maximum VOC content limits for specific product categories sold in Hong Kong: architectural coatings, printing inks, adhesives, and other surface coatings. Electronics manufacturing solvents and conformal coatings may fall within regulated categories, making the regulation relevant to electronics manufacturers, importers, and assembly operations with a Hong Kong presence. ### Electronics-relevant categories Conformal coatings applied to PCBs, adhesives used in electronics assembly, and cleaning solvents used in manufacturing may fall under specific categories with defined VOC limits. The limit is expressed in grams of VOC per litre of product (g/L), calculated after subtracting water and any exempt compounds. The applicable category determines which limit applies. ### Label requirements Products subject to VOC limits must display the VOC content on the product label. The label must state the VOC content in g/L and reference the applicable product category as defined in the regulation. Labels in both English and Chinese are expected for products sold through Hong Kong retail and distribution channels. ### EPD enforcement The Environmental Protection Department conducts market surveillance and can require product testing at an approved laboratory. Suppliers, importers, and manufacturers must retain technical documentation demonstrating VOC content compliance — including VOC calculation worksheets, raw material compositions, and supplier safety data sheets. Non-compliant products can be recalled and the responsible party prosecuted. ## How to verify and document VOC compliance 01 Identify whether the coatings, adhesives, or solvents associated with your electronics product or manufacturing process are in a regulated VOC product category under Cap. 311P — the regulation's schedules list specific product types with their corresponding VOC limits. 02 Obtain VOC content data from your material supplier — request the VOC content in g/L calculated according to Cap. 311P's formula, which accounts for water content and exempt compounds; supplier safety data sheets alone may not contain the correct calculated value. 03 Confirm the measured VOC content is below the applicable limit for the product category — if it exceeds the limit, work with the supplier to identify a compliant reformulation before the product is imported or sold in Hong Kong. 04 Prepare compliant product labels with the VOC content declared in g/L and the product category name as specified in the regulation; include labels in both English and Chinese for products sold in Hong Kong. 05 Maintain technical records including VOC calculation worksheets, raw material composition data, and supplier safety data sheets — EPD inspectors may request these during market surveillance visits; a minimum two-year retention period is advisable. ## Frequently asked questions ### Which electronics-related products fall under Hong Kong's VOC regulation? The regulation under Cap. 311P covers specific product categories including adhesives, surface coatings, and cleaning solvents. For electronics, the most commonly affected products are conformal coatings applied to PCBs, electronics assembly adhesives, and solvent-based cleaning agents used in manufacturing. The key question is whether your specific product matches a category defined in the regulation's schedules — if it does, the VOC limit and labeling requirements apply. ### How is VOC content measured and what compounds are exempt? VOC content under Cap. 311P is calculated in g/L, accounting for water and exempt compounds. Exempt compounds — typically including acetone and certain other low-reactivity solvents — are subtracted from the total VOC content before comparing against the limit. Suppliers should provide VOC content data calculated according to the regulation's formula, not just a generic VOC percentage from the safety data sheet. ### Are VOC labels required in both English and Chinese? The regulation requires VOC content to be labeled on the product. For products distributed through Hong Kong retail and commercial channels, labels in both English and Traditional Chinese are standard practice and expected by enforcement authorities. Products sold purely in export markets or through free zone re-export may have different labeling considerations, but any product sold locally in Hong Kong should carry bilingual labeling. ### What penalties apply for exceeding VOC limits? Under the Air Pollution Control Ordinance (Cap. 311), selling a product that exceeds the prescribed VOC limit is a criminal offence. Penalties can include fines and, for repeat offences, imprisonment. The EPD can also require the product to be withdrawn from sale and can publicise enforcement actions. Importers and manufacturers are both potentially liable, making supply chain documentation critical. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇭🇰 Hong Kong roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇭🇰 Hong Kong compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/62-hong-kong-ofca-radio-equipment-certification)[Prefer to read? 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