[Home](/)/[Resources](/resources)/Hong Kong Product Labeling Hong KongLabeling # Hong Kong Product Labeling Requirements: Trade Descriptions Ordinance and Mandatory Information Hong Kong's labeling landscape is simpler than many markets — there is no general Chinese-language requirement for hardware products, and no single unified labeling standard. But Cap. 362's country of origin obligation is absolute, and false trade descriptions carry criminal penalties. Understanding which ordinances layer onto your specific product type prevents the most common and costly labeling mistakes. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fhong-kong-product-labeling) At a glance Key law Trade Descriptions Ordinance (Cap. 362) Enforcer Customs and Excise Department Language No mandatory Chinese (except food) Country of origin Required on all goods ## Labeling obligations by ordinance ### Trade Descriptions Ordinance Cap. 362 and false trade description prohibition Cap. 362 makes it a criminal offence to apply a false trade description to goods or to supply goods with a false trade description applied. A trade description includes statements about quantity, size, method of manufacture, composition, fitness for purpose, performance, and country of origin. The Ordinance applies to any person who applies a description or supplies described goods in the course of trade or business in Hong Kong — including importers, distributors, and retailers. ### Country of origin labeling obligation for all goods imported into Hong Kong Country of origin marking is mandatory for all goods imported into Hong Kong under Cap. 362. The origin must be correctly stated on the product or its packaging. Using 'Made in China', 'Made in USA', or similar must accurately reflect where the product was substantially manufactured or transformed. Incorrect origin labeling — including inaccurate re-labeling to change origin — is a criminal offence. This is a hard requirement with no de minimis exemption based on product value or volume. ### Dangerous goods labeling under Cap. 295 (Dangerous Goods Ordinance) Products that contain or constitute dangerous goods — including flammable materials, oxidising agents, corrosives, and lithium batteries (Class 9) — must carry hazard labeling compliant with the Dangerous Goods Ordinance Cap. 295 and, where applicable, GHS (Globally Harmonised System) requirements. This applies to product packaging, transport documents, and any Storage Data Sheet provided to buyers or distributors in the supply chain. ### Electrical product labeling under Cap. 406 (Electricity Ordinance) and EMSD requirements Electrical products regulated under the Electricity Ordinance Cap. 406 must carry mandatory labeling including rated voltage, rated frequency, rated power consumption, and the EMSD approval marking where a Certificate of Approval has been obtained. Products in Schedule 1 (defined household electrical appliances) must display the approval certificate number on the product or packaging. EMSD may also specify font size and placement requirements for regulated appliances. ## Labeling compliance checklist for importers 01 Ensure country of origin is correctly stated on the product and outer packaging — this is a mandatory requirement under Cap. 362 for all imported goods, and non-compliance is a criminal offence regardless of the product category. 02 Review all product claims, on-pack marketing text, and promotional materials for potentially false or misleading trade descriptions under Cap. 362 — performance claims, specifications, and certifications cited must be accurate and verifiable. 03 Check if the product or its packaging contains dangerous goods requiring hazard labeling under Cap. 295 — this includes lithium batteries, flammable solvents in cleaning products, and aerosol propellants. 04 Confirm electrical product labeling includes required ratings (voltage, wattage, frequency) and, for Schedule 1 appliances, the EMSD Certificate of Approval number under Cap. 406. 05 Verify that labeling does not require Chinese text for your product category — Chinese is not generally mandatory for non-food hardware products in Hong Kong, but check category-specific rules (food labeling under Cap. 132W requires Chinese, and some consumer goods standards specify bilingual warnings). ## Frequently asked questions ### Is Chinese language required on product labels in Hong Kong? Chinese is not generally required on product labels for non-food hardware goods in Hong Kong. There is no blanket bilingual labeling requirement equivalent to Canada or some EU member states. However, specific categories have their own rules: food products must carry Chinese labeling under Cap. 132W, some toy safety warnings are expected in both English and Chinese in practice, and certain consumer goods standards may specify bilingual content. For general electronics and hardware, English-only labeling is legally sufficient in most cases. ### What constitutes a 'false trade description' under Cap. 362? A false trade description is any description applied to goods that is false to a material degree, covering: quantity, size, gauge, or weight; method of manufacture or production; composition; fitness for purpose; performance characteristics; testing or approval by any person; country of origin; and other characteristics designated by regulation. A description that is literally true but misleading in context can also constitute a false trade description. Customs enforces Cap. 362 and can prosecute without prior warning. ### What are the country of origin rules for assembled electronics? For assembled electronics, country of origin is determined by where substantial transformation occurred — generally the country where the last significant manufacturing process took place that gave the product its essential character. Assembly of imported components into a finished product may or may not constitute substantial transformation depending on the complexity of the assembly process and the value added. Simple operations such as testing, packing, or adding connectors to otherwise complete boards generally do not change the origin. The rule of origin for customs purposes in Hong Kong follows the substantial transformation standard. ### What penalties apply for incorrect trade descriptions? Conviction under Cap. 362 can result in fines and imprisonment. For summary conviction (Magistrates Court), penalties include fines per offence and imprisonment of up to 1 year. For conviction on indictment (District Court), fines are higher and imprisonment can extend to 5 years. Directors and officers of a company can be personally liable where an offence is committed with their consent, connivance, or attributable to their neglect. Goods may also be forfeited. **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? 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