[Home](/)/[Resources](/resources)/Hong Kong Chemical Safety Hong KongChemical Safety # Hong Kong Chemical Safety: Dangerous Goods Ordinance and Hazardous Substances for Electronics For electronics importers, chemical safety in Hong Kong means one thing above all others: lithium batteries are Class 9 dangerous goods, and every transport link in the supply chain must reflect that. Cap. 295 and Cap. 595 create a layered framework covering storage, transport, and controlled chemicals — while Hong Kong has no domestic RoHS equivalent, the transport and storage obligations for battery-containing products are unambiguous and actively enforced. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fhong-kong-chemical-safety) At a glance Key laws Cap. 295 (DGO), Cap. 595 (HCCO) Administrator Fire Services Department / EPD Scope Hazardous substances in products and packaging Lithium batteries Classified as dangerous goods (Class 9) ## Chemical safety framework for electronics in Hong Kong ### Dangerous Goods Ordinance Cap. 295 and its class structure (Class 1–9) Cap. 295 regulates the keeping, conveyance, and use of dangerous goods in Hong Kong using the UN Globally Harmonised System classification structure. The nine classes cover: Class 1 explosives, Class 2 gases, Class 3 flammable liquids, Class 4 flammable solids, Class 5 oxidising substances, Class 6 toxic substances, Class 7 radioactive material, Class 8 corrosives, and Class 9 miscellaneous dangerous goods (which includes lithium batteries). The Fire Services Department administers the Ordinance and issues licences for storage and handling. ### Hazardous Chemicals Control Ordinance Cap. 595 and the controlled chemicals schedule Cap. 595 regulates the import, export, manufacture, and use of specified hazardous chemicals that are scheduled under the Ordinance. The Environmental Protection Department administers Cap. 595. The scheduled chemicals list is based on international conventions including the Rotterdam Convention on Prior Informed Consent. Electronics manufacturers need to check whether any process chemicals, cleaning agents, or materials used in their products or packaging supply chains appear on the Cap. 595 schedule — controlled chemicals require notification or permits for import and use. ### Lithium battery classification as Class 9 dangerous goods and transport implications Lithium-ion and lithium metal batteries are classified as Class 9 miscellaneous dangerous goods under Cap. 295 and internationally under IATA Dangerous Goods Regulations and IMDG Code. This classification has direct implications for air freight (IATA DGR packing instructions PI 965–970 depending on battery state and packaging format), sea freight (IMDG special provisions), and courier shipments (carrier-specific limits on watt-hours and state of charge). Consumer electronics shipped with integrated lithium batteries must comply with these transport requirements at every stage of the supply chain from factory to Hong Kong retailer. ### REACH/RoHS-equivalent chemical restrictions in Hong Kong electronics Hong Kong does not have a domestic equivalent to the EU's RoHS Directive or REACH Regulation. There is no local restriction on lead, mercury, cadmium, hexavalent chromium, PBBs, or PBDEs in electronic products equivalent to EU RoHS 2. However, products carrying CE marking with RoHS compliance are de facto treated as meeting the absence-of-hazardous-substance expectations of Hong Kong buyers and distributors. Exporters should note that EU RoHS test reports, while not legally required in Hong Kong, provide the practical market assurance that local customers and retailers expect. ## Compliance steps for electronics importers 01 Identify which dangerous goods classes apply to your product — batteries are Class 9, flammable electrolytes are Class 3, and some cleaning or process chemicals may fall under Class 6 or Class 8 — and document the classification basis using UN GHS criteria. 02 Check whether the product or any component requires a Dangerous Goods licence for storage or use in Hong Kong under Cap. 295 — the licence is issued by the Fire Services Department and covers the quantities and classes stored at a specific premises. 03 Review the Cap. 595 controlled chemicals schedule maintained by the Environmental Protection Department to determine whether any substance in the product, packaging, or associated chemicals requires a permit or pre-export notification for import into Hong Kong. 04 Ensure all transport documents for air, sea, and courier shipments correctly classify and declare dangerous goods in accordance with IATA DGR, IMDG, and relevant carrier policies — lithium battery state of charge, watt-hour rating, and packing format must be accurately declared. 05 Prepare a Safety Data Sheet (SDS) aligned with GHS (UN Globally Harmonised System) for any product supplied in a B2B context or that contains hazardous substances — even if not required for consumer retail, an SDS is expected by distributors and warehousing partners handling your product in Hong Kong. ## Frequently asked questions ### Are lithium batteries in consumer electronics classified as dangerous goods in Hong Kong? Yes. Lithium-ion and lithium metal batteries are classified as Class 9 miscellaneous dangerous goods under Cap. 295. This classification applies whether the battery is shipped standalone, as a component, or integrated into a finished product. The practical consequences are mainly for transport: IATA Dangerous Goods Regulations impose strict packing, labeling, and quantity limits on air shipments of lithium batteries. Consumer electronics shipped by air to Hong Kong distributors must comply with IATA packing instructions PI 965 (lithium-ion cells/batteries) or PI 966/967 (cells/batteries packed with or in equipment). ### When does a Dangerous Goods licence become required? A Dangerous Goods licence under Cap. 295 is required for anyone who keeps dangerous goods in quantities exceeding the prescribed exemption threshold at a specific location — warehouse, retail store, or service facility. The threshold varies by class: for Class 9 (lithium batteries), the quantities held in a warehouse or distribution centre above the exemption limit require a licence from the Fire Services Department. Retail quantities of consumer electronics with integrated batteries typically fall within exemption limits, but a large distribution centre holding significant battery stock should conduct a threshold assessment. ### Are there RoHS-equivalent restrictions in Hong Kong? No. Hong Kong does not have a domestic RoHS Directive equivalent restricting lead, mercury, cadmium, hexavalent chromium, PBBs, or PBDEs in electronic products. Products lawfully placed on the EU market with CE/RoHS compliance can be sold in Hong Kong without additional substance restriction testing. However, international buyers and Hong Kong distributors supplying EU or UK markets expect RoHS-compliant products as a commercial requirement, regardless of the lack of a local legal mandate. ### How does Cap. 595 (HCCO) affect electronics importers? Cap. 595 controls specific hazardous chemicals listed in its schedule — primarily industrial chemicals tied to international conventions rather than substances embedded in finished consumer electronics. Most finished electronic products are not directly affected by Cap. 595 at the import stage. However, manufacturers who import process chemicals for electronics assembly or repair in Hong Kong (e.g. certain solvents, flux compounds, or industrial cleaners containing scheduled substances) must check the Cap. 595 schedule and obtain the necessary EPD permit or comply with prior informed consent notification requirements before import. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. 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