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# Hong Kong Producer Responsibility Scheme: WEEE Obligations for Electronics Suppliers

Electronics importers selling into Hong Kong face an advance recycling levy at the border and take-back obligations at the point of retail sale. This guide explains which products trigger the Producer Responsibility Scheme, what the levy amounts to, and how to stay compliant.

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At a glance

Law

Product Eco-Responsibility Ordinance (Cap. 603)

Administrator

Environmental Protection Department (EPD)

Covered products

5 regulated product categories (plus amendments)

Model

Advance recycling levy

## How Hong Kong's WEEE PRS works

### Hong Kong WEEE PRS structure

The Producer Responsibility Scheme (PRS) for electrical equipment requires importers to pay an advance recycling levy (ARL) when regulated products are imported for local sale. The levy is collected at the point of import and funds the collection and recycling infrastructure that handles end-of-life products across Hong Kong.

### Regulated product categories

The original five categories under Cap. 603 are: air conditioners, refrigerators, washing machines, televisions, and computers (including tablets and laptops). Amendments to the ordinance extended the scheme to printers and other IT equipment — always verify the current EPD regulated product list against your specific product type before import.

### Advance recycling levy (ARL)

Importers pay the ARL at the point of import, declared on the import entry. The rate varies by product category and, in some categories, by product size or weight. Levy revenue is directed to EPD-licensed recyclers and collection operators. The levy is not a tax on the consumer — it is an importer obligation triggered at the border.

### Retailer take-back obligation

Retailers of regulated products must take back end-of-life products on a one-for-one basis when a customer purchases a new product of the same type. The accepted items are routed to EPD-licensed collectors. Retailers may not charge customers for this take-back service. Failure to comply is a criminal offence under Cap. 603.

## Meeting your PRS obligations: step by step

01

Determine whether your product falls within the regulated product categories under Cap. 603 — check the EPD's regulated product list and confirm by product type and intended market (residential vs commercial), as some commercial-only categories have different treatment.

02

Register with the EPD as an importer of regulated products — registration is required before the first shipment is imported for local sale; the EPD registration portal is available online.

03

Pay the advance recycling levy at the time of import — the levy amount is declared on the import entry and collected by Customs and Excise on behalf of the EPD; ensure the correct levy rate is applied for the product category and size.

04

If operating retail in Hong Kong, establish a take-back arrangement — retailers must accept equivalent products for recycling when selling new ones; ensure front-line staff understand the obligation and the accepted items are routed to EPD-licensed collectors.

05

Maintain records of imports, levy payments, and take-back volumes — EPD may inspect records and conduct market surveillance to verify compliance; records should be retained for at least two years.

## Frequently asked questions

### Which electronics products are covered by Hong Kong's WEEE Producer Responsibility Scheme?

The original five categories under the Product Eco-Responsibility Ordinance (Cap. 603) are air conditioners, refrigerators, washing machines, televisions, and computers (including tablets and laptops). Amendments extended the scheme to printers and other IT equipment. The EPD publishes the current regulated product list — always verify your specific product type and model against the current list before importing for Hong Kong sale.

### Who pays the advance recycling levy — the manufacturer or the importer?

The advance recycling levy (ARL) is the obligation of the importer — the party who brings the regulated product into Hong Kong for local sale. It is paid at the time of import, declared on the import entry, and collected by Customs and Excise on behalf of the EPD. Manufacturers outside Hong Kong are not directly liable, but importers often factor the ARL cost into pricing and procurement agreements.

### Does the PRS apply to commercial electronics sold to businesses?

The PRS under Cap. 603 applies based on product type, not the identity of the end buyer. Products in the regulated categories that are imported for local sale are subject to the ARL regardless of whether they will be sold to residential or commercial customers. Some specific product categories and size thresholds may have different treatment — confirm with the EPD for your specific product.

### How does Hong Kong's PRS compare to EU WEEE?

Hong Kong's PRS uses an advance recycling levy model — importers pay a fee at the border that funds recycling infrastructure. The EU WEEE Directive uses a producer responsibility model where manufacturers and importers fund and report on the collection and treatment of their own brand's products. Hong Kong's model is simpler to administer but less directly tied to individual producer performance. Both systems include retailer take-back obligations.

**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.

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