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By the Strategic Control Circular No. 6/2025 released on July 4, 2025, the Trade and Industry Department (TID) of Hong Kong invited operators of relevant facilities to report the anticipated activities in 2026 involving chemicals controlled under the Chemical Weapons (Convention) Ordinance (Cap. 578). Individual operators who had received this circular from the TID shall fulfill the Reply Slip and sent it to TID before July 28, 2025.
Controlled chemicals and activities
Hong Kong has implemented the Chemical Weapons Convention through the CWC Ordinance (Cap. 578) since June 18, 2004. The controlled chemicals are listed in Schedules 1~3 to the Ordinance, which are toxic chemicals and their precursors regulated under the Convention. Activities and quantity thresholds that trigger the permit and annual reporting requirements are as follows.
Schedule 1 chemicals (other than excluded chemicals) are likely to be produced, acquired, retained or used at, or transferred from, the facility during the year. Schedule 1 chemicals are excluded chemicals in relation to a facility and to a year if –
the total amount of those chemicals likely to be acquired, retained or used at, or transferred from, the facility during the year does not exceed 100 grams; and
those chemicals will not be produced at the facility during that year; and
those chemicals are intended only to be put to research, medical or pharmaceutical purposes; OR
An amount of a Schedule 2 chemical exceeding, in the aggregate, the Schedule 2 permit threshold for that chemical is likely to be produced, processed or consumed at a plant comprising, or comprising part of, the facility during the year. The threshold is –
1 kg for a chemical listed in Part A of Schedule 2 and designated with an "*”; or
100 kg for a chemical listed in Part A of Schedule 2 but is not designated with an "*”; or
1 tonne for a chemical listed in Part B of Schedule 2; or
An amount of a Schedule 3 chemical exceeding, in the aggregate, 30 tonnes of that chemical is likely to be produced at a plant comprising, or comprising part of, the facility during the year.
Source: Permit Requirement under the Chemical Weapons (Convention) Ordinance
The list of controlled chemicals is available here.
Permit and annual reporting requirements
As per the Ordinance, operators of facilities are required to obtain permits if their facilities are engaged in activities involving controlled chemicals exceeding the specified thresholds. Permits holders shall also submit the annual reports, detailing both anticipated activities for the upcoming year and past activities. This information is vital for compiling annual declarations to the Organisation for the Prohibition of Chemical Weapons (OPCW).
Operators engaged in such activities, who had received this circular from TID shall return the completed Reply Slip in the following ways on or before 18 July 2025:
By fax (fax no. 2396 3070),
By email (email address: [email protected]),
By post, or
In person to the Integrated Customer Service Centre, Room 1324, 13/F, Trade and Industry Tower, 3 Concorde Road, Kowloon City.
For operators who do not receive this circular but may be engaged in specified activities involving the controlled chemicals in 2025 are encouraged to provide detailed information via the Reply Slip in the same ways. After assessing the submitted reply slips, TID will contact and assist operators to complete and return the designated report forms on anticipated activities on or before July 25, 2025.
Warning
Facilities that are involved in controlled chemicals and activities shall comply with the checks and inspections by the Customs and Excide Department (C&ED). Operators shall provide all the requisite records for the checks and inspections. Operators must ensure the provided information concerning the permits and annual reports is accurate, as inaccuracies can lead to severe penalties.
Operating without a required permit can result in fines up to HK$500,000 and imprisonment for up to five years.
Failing to comply with information requests may incur fines of HK$100,000 and up to one year in prison.
Administrative actions may include refusal of permits or licenses, or suspension of current permits.
Operators engaged in activities involving controlled chemicals must take immediate action to ensure compliance with the requirements outlined in Strategic Control Circular No. 6/2025. Staying informed and proactive will not only facilitate smoother operations but also uphold Hong Kong's commitment to international standards in chemical safety and regulation.
