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# Hong Kong Packaging and Labeling Requirements: Bilingual Warnings, Origin Claims, Energy Labels and Recycling Rules

Hong Kong does not require full Chinese labels or a mandatory "Made in" line on most consumer goods. It does require every safety warning to appear in both English and Chinese, and every claim on the pack, including origin, to be true under the Trade Descriptions Ordinance (Cap. 362). Toys need a local name and address. Prescribed appliances need an EMSD energy label, and regulated electrical equipment falls under the WEEE producer responsibility scheme. This guide sets out what goes on the pack, which law requires it, and what changed in 2024 and 2025.

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At a glance

Main law

Trade Descriptions Ordinance (Cap. 362)

Warnings

English AND Chinese (Cap. 456A)

Origin marking

Not generally mandatory; must be true if used

Energy label

EMSD — for regulated appliances

## HK Labeling Obligations: Key Concepts and Legislation

### Trade Descriptions Ordinance (Cap. 362): every claim must be true

The Trade Descriptions Ordinance (Cap. 362), enforced by the Customs and Excise Department, makes it an offence to apply a false trade description to goods. A trade description is any indication of quantity, size, method of manufacture, composition, fitness for purpose, performance, place of origin, testing or approval, and similar. Amendments in force since July 2013 added offences for misleading omissions, aggressive practices, bait advertising and wrongly accepting payment. On packaging, the usual problems are origin claims, unsupported performance or certification claims, and inflated "original price" stickers. Customs can prosecute manufacturers, importers and retailers.

### Consumer Goods Safety Ordinance (Cap. 456): warnings must be in English and Chinese

The Consumer Goods Safety Ordinance (Cap. 456) sets a general safety requirement for consumer goods supplied in Hong Kong. Its Consumer Goods Safety Regulation (Cap. 456A) requires any warning or caution about the safe keeping, use, consumption or disposal of consumer goods to be in both English and Chinese. The warning must be legible and in a conspicuous position: on the goods, on the package, on a label securely fixed to the package, or in a document enclosed with it. This is the rule most often missed by suppliers who assume an English-only label is fine in Hong Kong.

### Language: English-only is allowed, except for warnings

Hong Kong has no general law requiring all label text to be in Chinese, unlike mainland China. Product names, marketing copy and specifications can be English-only. Safety warnings and cautions are the exception: they must be bilingual under Cap. 456A for general consumer goods, under the Toys and Children's Products Safety Ordinance (Cap. 424) for toys and children's products, and under the Electrical Products (Safety) Regulation (Cap. 406G) for household electrical products. Large retailers and marketplaces often ask for bilingual packaging anyway.

### Origin claims: the substantial-change test in Cap. 362

Hong Kong does not require a country of origin on consumer goods in general. If you do state one, the Trade Descriptions Ordinance applies. Goods are treated as made in the place where they last underwent a process that changed permanently and substantially their shape, nature, form or utility, unless the Director-General of Trade and Industry sets a different rule for that type of goods. Simple packing, labeling or minor assembly does not move origin. A false "Made in" claim is a false trade description. Exporters who need a certificate of origin get one from the Trade and Industry Department (TID) or a government-approved certification organisation.

### Identification marking for toys and children's products

Under the Toys and Children's Products Safety Ordinance (Cap. 424), toys and specified children's products must show the name, trade mark or other identification mark, and the local address of the manufacturer, importer or supplier, in English, Chinese or both. Their warnings must be in both languages. For other consumer goods, no general Hong Kong name-and-address rule applies. Even so, showing a responsible party makes recalls and enforcement enquiries easier and is commonly expected by retailers.

### Net quantity: Weights and Measures Ordinance (Cap. 68)

Where goods are sold by weight or measure, the Weights and Measures Ordinance (Cap. 68) protects buyers against short quantity, and Customs makes test purchases to check. Mark pre-packed goods sold by quantity with an accurate net quantity in metric units that excludes packaging. Prepackaged food has its own, more detailed labeling rules under the Food and Drugs (Composition and Labelling) Regulations (Cap. 132W).

### Energy labels: Mandatory Energy Efficiency Labelling Scheme (Cap. 598)

Under the Energy Efficiency (Labelling of Products) Ordinance (Cap. 598), administered by the Electrical and Mechanical Services Department (EMSD), prescribed products must be registered with EMSD and carry the Hong Kong energy label before supply. The scheme covers eleven product types: room air conditioners, refrigerating appliances, compact fluorescent lamps, washing machines, dehumidifiers, televisions, storage type electric water heaters, induction cookers, LED lamps, gas cookers and gas instantaneous water heaters. The fourth phase, which added LED lamps and the two gas appliances, took full effect on 1 December 2024.

### Producer responsibility: WEEE, and the 2025 recycling framework

Under the Product Eco-responsibility Ordinance (Cap. 603), suppliers of regulated electrical equipment must register with the Environmental Protection Department (EPD) and pay a recycling levy. The regulated categories are air conditioners, refrigerators, washing machines, televisions, computers, printers, scanners and monitors; since 1 July 2024 the scope also includes tumble dryers and dehumidifiers. From the same date, sellers no longer have to provide a recycling label, but receipts must still carry the prescribed levy wording. In July 2025 the Legislative Council passed the Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025. It creates a common legal framework for new producer responsibility schemes, starting with plastic beverage containers and beverage cartons. Hong Kong still has no general packaging EPR scheme or packaging recycling mark for consumer goods, so check EPD announcements for start dates if you sell beverages or other covered products.

## What goes on a Hong Kong label: quick reference

Item

Legal source

When required

Safety warnings and cautions

Cap. 456A; Cap. 424 (toys); Cap. 406G (electrical)

Yes, where warnings are needed: English AND Chinese

Name and local address of manufacturer/importer/supplier

Cap. 424 (toys and children's products)

Toys and children's products; good practice for other goods

Country or place of origin

Cap. 362 (if stated)

Not generally mandatory; must be accurate if stated

Net quantity in metric units

Cap. 68; Cap. 132W for food

Goods sold by weight or measure; prepackaged food

Energy label

Cap. 598 (EMSD)

11 prescribed product types

Certificate of safety compliance (not on label)

Cap. 406G (EMSD)

Household electrical products: keep on file

Levy wording on receipt (not on pack)

Cap. 603 WPRS

Regulated electrical equipment

## Common Hong Kong labeling mistakes

Assuming English-only is fine for warnings. The text can be English-only, but any warning or caution must also be in Chinese.

Shipping toys or children's products without a local name and address on the product, packaging or label.

Writing "Made in Hong Kong" on goods that were only repacked or lightly assembled in Hong Kong.

Using an energy label design from the EU or mainland China on a prescribed appliance instead of registering it with EMSD.

Still printing the old WPRS recycling label, or putting regulated electrical equipment on sale before registering with EPD as a supplier.

Related: [Hong Kong toy safety](/guides/hong-kong-toy-safety), [WEEE producer responsibility](/guides/hong-kong-weee-producer-responsibility) and [medical device listing (MDACS)](/guides/hong-kong-medical-device-listing).

## Label Compliance Process for HK Consumer Goods

01

Check every claim on the pack (performance, composition, certification, origin, price) against the Trade Descriptions Ordinance (Cap. 362). Each one must be accurate, supportable and not misleading by omission.

02

List every warning and caution on the product, packaging and manual, and provide each one in both English and Chinese under Cap. 456A. Place them where buyers will see them.

03

If you state an origin, confirm it against the substantial-change test (last process that permanently and substantially changed the goods) and keep the manufacturing records that support it.

04

For toys and children's products, add the name or trade mark and local Hong Kong address of the manufacturer, importer or supplier, and check the safety standards that apply under Cap. 424.

05

For household electrical products, hold a certificate of safety compliance under Cap. 406G. If the product is a prescribed appliance under Cap. 598, register it with EMSD and print the energy label.

06

For regulated electrical equipment, register with EPD as a supplier before distribution, set up the levy and receipt wording, and offer the free removal service when consumers ask for it.

07

For goods sold by weight or measure, mark an accurate metric net quantity. Before printing, have the final artwork reviewed against this list by someone who knows Hong Kong law.

## Frequently asked questions

### Is Chinese labeling mandatory for products in Hong Kong?

Not for the whole label. Hong Kong has no general rule that product names or descriptions must be in Chinese, so English-only packaging is legal for most goods. Warnings and cautions are different: under the Consumer Goods Safety Regulation (Cap. 456A), any warning or caution about safe keeping, use, consumption or disposal must appear in both English and Chinese. The same applies to toys and children's products under Cap. 424 and to household electrical products under Cap. 406G.

### What is the country of origin rule for labels in Hong Kong?

Origin marking is not generally required, but any origin claim you make is a trade description under Cap. 362 and must be true. Goods are treated as made in the place where they last underwent a process that permanently and substantially changed their shape, nature, form or utility, unless the Director-General of Trade and Industry sets a specific rule for that product type. Repacking, relabeling or simple assembly does not change origin. Misdescribing origin is an offence enforced by Customs.

### What must a consumer electronics label include in Hong Kong?

Any safety warnings, in English and Chinese. Household electrical products must also meet the Electrical Products (Safety) Regulation (Cap. 406G), which requires a certificate of safety compliance and bilingual warnings, and plugs must suit Hong Kong. Prescribed appliances need an EMSD energy label. Regulated electrical equipment such as TVs, computers, printers and monitors falls under the WEEE scheme: the supplier must register with EPD and the receipt must carry the levy wording. Radio products also need to comply with OFCA requirements.

### Does Hong Kong require energy labels on appliances?

Yes, for prescribed products. The Mandatory Energy Efficiency Labelling Scheme under Cap. 598 covers room air conditioners, refrigerating appliances, compact fluorescent lamps, washing machines, dehumidifiers, televisions, storage type electric water heaters, induction cookers, LED lamps, gas cookers and gas instantaneous water heaters. Each model must be registered with EMSD and carry the Hong Kong energy label. Supplying an unregistered or unlabeled prescribed product is an offence.

### Is there a packaging EPR or recycling label requirement in Hong Kong?

There is no general packaging EPR scheme or mandatory packaging recycling mark for consumer goods. In July 2025 the Legislative Council passed the Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025, which creates a framework for new producer responsibility schemes, starting with plastic beverage containers and beverage cartons. Start dates are set separately. For regulated electrical equipment, the WPRS recycling label was abolished from 1 July 2024, but supplier registration with EPD and the levy wording on receipts still apply.

### Do I need a Hong Kong address on the label?

For toys and children's products, yes: the name, trade mark or other identification mark and the local address of the manufacturer, importer or supplier must be shown, in English, Chinese or both. For other consumer goods, no general requirement applies. Still, a local importer or distributor on the pack helps with retailer onboarding, recalls and enforcement enquiries.

### Are medical devices covered by these labeling rules?

Medical devices sit outside most of this consumer goods framework. Hong Kong runs the Medical Device Administrative Control System (MDACS), a listing scheme operated by the Department of Health with its own labeling expectations for listed devices. See our Hong Kong medical device listing guide before designing labels for medical or IVD products.

**Disclaimer:** Educational resource only. Regulatory requirements change. Consult a qualified compliance specialist before making decisions.

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