
Hong Kong is a free port: no customs tariff is charged on the import or the export of goods. The Trade and Industry Department puts it directly: “Hong Kong is a free port. We pursue a free trade policy and do not maintain barriers on trade. No tariff is charged on import or export of goods.” The absence of a tariff is not the absence of obligation: almost every import and export requires a declaration within 14 days, four categories of goods bear excise duty, and dozens of categories require a licence.
The key risk. “Free port” is often read as “nothing to file”. That reading is wrong and expensive. The duty to lodge a declaration under the Import and Export (Registration) Regulations (Cap. 60E) does not depend on whether the goods bear duty. Late lodgement costs between HK$20 and HK$200 per declaration, an inaccurate declaration is a criminal offence, and importing an article that requires a licence without one carries, under sections 6C and 6D of Cap. 60, up to HK$2,000,000 and seven years’ imprisonment.
|
Item |
Value |
Basis |
|
Customs tariff on general imports and exports |
None |
Free port policy; TID |
|
Deadline for lodging a declaration |
14 days after importation or exportation |
Cap. 60E; C&ED and C&SD |
|
Declaration charge, non-food goods |
20 cents on the first HK$46,000 of value, then 12.5 cents per HK$1,000 or part thereof |
Cap. 60E; C&ED and C&SD |
|
Food items |
20 cents per declaration irrespective of value |
Cap. 60E; C&SD |
|
Maximum declaration charge |
HK$200 since 1 August 2018 |
2018 amendment to Cap. 60E |
|
Clothing Industry Training Levy |
30 cents per HK$1,000 of value or part thereof |
Section 21, Cap. 318 |
|
Late lodgement penalty |
HK$20 to HK$200 depending on value and delay |
C&ED and C&SD |
|
Inaccurate declaration |
A criminal offence; no fine amount is published by the regulators |
C&ED and C&SD |
|
Dutiable commodities |
Four: liquor, tobacco, certain hydrocarbon oil, methyl alcohol |
Schedule 1, Cap. 109 |
|
Liquor above 30 % alcohol by volume |
100 % on the first HK$200 of value, 10 % on the remainder |
From 16 October 2024 |
|
Cigarettes |
HK$3,306 per 1,000 |
C&ED |
|
Dutiable commodities import and export licence |
HK$1,320 a year |
C&ED |
|
Dutiable commodities permits |
Free of charge |
C&ED |
|
Strategic commodities licence |
Free; normally no more than 2.5 clear working days |
TID |
|
Re-exports as a share of total exports, 2025 |
98.7 % |
Author’s calculation from TID and C&SD data |
Free port status in Hong Kong means the absence of a customs tariff on the import and export of goods, not the absence of customs regulation. The Trade and Industry Department states the principle and its limit in a single passage: “Although licensing is required for the import and export of some goods, this is only to fulfil obligations undertaken by Hong Kong to our trading partners, or to meet public health, safety or internal security needs.”
No customs tariff. There is no ad valorem or specific duty on general imports and exports. Tariff lines, quotas and tariff preferences in the ordinary sense do not feature in Hong Kong practice.
No value added tax and no sales tax. Importing goods triggers no import VAT, and exporting triggers no refund entitlement — because there is nothing to refund.
No export duties. The Customs and Excise Department puts it plainly: there is no tax or excise duty on exports from Hong Kong.
A declaration obligation. It reaches every import and export other than the expressly exempted categories, and it does not depend on whether the goods bear excise duty.
Excise duty on four commodities. Liquor, tobacco, certain hydrocarbon oil and methyl alcohol bear duty under Schedule 1 to the Dutiable Commodities Ordinance (Cap. 109). That duty falls equally on imported and on Hong Kong-manufactured goods, which is why it is not a tariff in the GATT sense.
Licensing by schedule. The mechanism is built not as a tariff grid but as lists of “prohibited articles” in Schedules 1 and 2 to the Import and Export (General) Regulations (Cap. 60A).
A first registration tax on motor vehicles. The Motor Vehicles (First Registration Tax) Ordinance (Cap. 330) is administered by Customs, but it is a registration tax, not a customs duty.
The absence of a tariff does not take a Hong Kong company outside profits tax. Trading profits are charged on the territorial basis, and the question of source is decided independently of any customs question; the mechanics are covered in our piece on territorial taxation and offshore status in Hong Kong.
Nor does the absence of a tariff displace the rules of origin. Goods passing through Hong Kong do not acquire Hong Kong origin automatically, and that is a separate subject dealt with below.
Hong Kong’s import and export regime rests on one principal ordinance with five sets of subsidiary regulations, a separate ordinance on dutiable commodities, and three special-purpose ordinances. There is no tariff legislation in the system, because there is no tariff.
|
Instrument |
What it governs |
Status |
|
Import and Export Ordinance (Cap. 60) |
The definitions of import and export, the “prohibited article” category, sections 6A, 6C, 6D and 6E, and the regulation-making power in section 31 |
In force; amended by the Import and Export (Amendment) Ordinance 2025, gazetted 11 July 2025 |
|
Dutiable Commodities Ordinance (Cap. 109) |
The four dutiable commodities, licences and permits, Schedule 1 rates |
In force |
|
Industrial Training (Clothing Industry) Ordinance (Cap. 318) |
The Clothing Industry Training Levy, section 21 |
In force |
|
Reserved Commodities Ordinance (Cap. 296) |
Reserved commodities; in practice, rice |
In force |
|
Motor Vehicles (First Registration Tax) Ordinance (Cap. 330) |
First registration tax on motor vehicles |
In force; administered by Customs |
|
Instrument |
Subject matter |
|
Import and Export (General) Regulations (Cap. 60A) |
Schedules 1 and 2 — the lists of licensable imports and exports; Schedule 3 — personal baggage and stores exemptions; Schedule 6 — meat and poultry in personal baggage; Schedule 7 — the Kimberley Process; Schedule 9 — optical disc mastering and replication equipment |
|
Import and Export (Registration) Regulations (Cap. 60E) |
The declaration duty, the exemptions, the charges and the penalties |
|
Import and Export (Strategic Commodities) Regulations (Cap. 60G) |
The Strategic Commodities Control List, Schedules 1 to 4 |
|
Import (Radiation) (Prohibition) Regulations (Cap. 60K) |
Radioactive substances |
|
Import and Export (Electronic Cargo Information) Regulation |
The legal basis of the ROCARS system |
An exhaustive list of the subsidiary legislation under Cap. 60 could not be confirmed from accessible official sources: the e-Legislation portal is closed to automated access. The five instruments above are confirmed by TID and C&ED publications and by Hong Kong’s own notifications to the World Trade Organization; this article asserts nothing about the existence or otherwise of any other instrument.
• 11 July 2025 — the Import and Export (Amendment) Ordinance 2025 was gazetted and mainly commenced: technical amendments to Cap. 60 and related legislation for the move from GETS to the Trade Single Window, with the provisions deleting the GETS legal framework to commence on a day appointed by notice of the Commissioner of Customs and Excise in the Gazette.
• 17 January 2025 — the Import and Export (Strategic Commodities) Regulations (Amendment of Schedule 1) Order 2025, L.N. 6 of 2025, was gazetted; it took effect on 30 May 2025.
• 19 September 2025 — the Tobacco Control Legislation (Amendment) Ordinance 2025 came into force, raising the Cap. 109 penalties for duty-not-paid tobacco and increasing the compoundable penalty for a passenger’s failure to declare dutiable goods from HK$2,000 to HK$5,000.
• 14 November 2025 — an amended Hong Kong Imports and Exports Classification List was gazetted, effective 1 January 2026, revising chemical products, telephone sets and fishing rods.
• 1 May 2026 — the first batch of Phase 3 services of the Trade Single Window went live, and ROCARS ceased operation the same night.
• Neither the 2025-26 nor the 2026-27 Budget changed any duty rate or the declaration charge — verified against the full text of both Budget Speeches.
The Legal Notice numbers and dates of three instruments could not be established (the strategic commodities order, by contrast, has been identified and is given above): the permanent instrument carrying the liquor duty rate applicable from 16 October 2024; the Dutiable Commodities (Amendment) Regulation 2025 exempting methyl alcohol; and the 2018 amendment that capped the declaration charge. The e-Legislation portal, the Legislative Council website and the electronic Gazette are all closed to automated reading, and this article prints no number for any of them.
Every person who imports or exports any article other than an exempted article must lodge with the Commissioner of Customs and Excise an accurate and complete import or export declaration within 14 days after the importation or exportation. The basis is the Import and Export (Registration) Regulations (Cap. 60E). The regulators do not cite specific regulation numbers in their publications: both the Customs and Excise Department and the Census and Statistics Department refer to Cap. 60E as a whole, and the only number published expressly is regulation 3(f), on the personal baggage exemption. What is set out here is therefore the rule itself rather than its numbering.
The Customs and Excise Department: “Any persons who import or export any articles, other than exempted articles, are required to lodge accurate and complete import / export declarations within 14 days after the importation / exportation of the article.”
The Census and Statistics Department’s notice on the lodgement of an import or export declaration reproduces the same rule, citing Cap. 60E and the Industrial Training (Clothing Industry) Ordinance (Cap. 318), and adds the requirement of accuracy and completeness.
First, the obligation has nothing to do with duty. Goods that bear no excise and need no licence are still declared. Free port status relieves you of the tariff, not of the reporting.
Second, the clock runs from the fact of importation or exportation, not from the invoice date, the bill of lading or customs clearance. The fourteen days are calendar days.
Third, a re-export is declared as an export. In a jurisdiction where re-exports are the overwhelming share of external trade, that means the declaration burden falls on both legs of the transaction.
The Customs and Excise Department states expressly that lodging a declaration in the wrong form counts as not having lodged it at all — “Lodging declaration in an inappropriate form shall be deemed not to have been lodged the declaration of the articles.”
The practical consequence is that choosing the wrong form is not curable after the event as a technicality: it starts the late-lodgement clock from the beginning.
An amended Hong Kong Imports and Exports Classification List has applied since 1 January 2026, having been gazetted on 14 November 2025. The revisions reach chemical products, telephone sets and fishing rods. Declarations for shipments on or after 1 January 2026 must be completed in accordance with the amended list.
Declarations are lodged electronically, either through one of the three service providers appointed by the Government or through their paper-to-electronic conversion service. The three providers have been appointed since 2010: Brio Electronic Commerce Limited, Global e-Trading Services Limited and Tradelink Electronic Commerce Limited.
The service provider bills the declarant for the government charge and the Clothing Industry Training Levy together with its own service fee, and remits the government portion. So the amount actually payable always exceeds the published government charge by the provider’s commercial fee, which the Government does not set.
The articles exempted from declaration are listed in regulation 3 of the Import and Export (Registration) Regulations (Cap. 60E), and the Census and Statistics Department publishes them as an official list of sixteen categories. The exemption operates automatically and requires no application.
1. Transhipment cargo consigned on a through bill of lading or a through air waybill from a place outside Hong Kong to another place outside Hong Kong.
2. Transit cargo destined for a place outside Hong Kong and passing through on the same ship or aircraft without transhipment.
3. Articles imported or exported by the Government or the Chinese People’s Liberation Army.
4. Ships’ stores, including bunker fuel, for use by or consumption on board the vessel.
5. Aircraft stores, including aviation fuel, for use by or consumption on board the aircraft.
6. Personal baggage, excluding motor vehicles.
7. Any postal packet the contents of which are valued at less than HK$4,000.
8. Advertising material supplied free of charge; samples valued at less than HK$1,000, or articles marked clearly as samples and distributed free of charge; exhibition goods to be re-exported or re-imported; A.T.A. Carnet goods; and sports-competition equipment to be re-exported or re-imported.
9. Marine fish, including edible crustaceans and molluscs, taken by Hong Kong-registered fishing craft.
10. Gifts of a personal nature where no payment is or is to be made by the consignee.
11. Used empty freight containers regularly imported and exported.
12. Aircraft parts imported and exported by international air transport undertakings.
13. Equipment for freight-container maintenance used by international transport operators.
14. Banknotes and coins in circulation.
15. Radio and television production equipment temporarily imported for use and then exported.
16. Means of transport used as conveyances in the course of the import or export itself.
The postal threshold is HK$4,000 and the sample threshold is HK$1,000 — different thresholds for different situations. A packet worth exactly HK$4,000 is not exempt: the provision says “less than”.
The personal baggage exemption expressly excludes motor vehicles. A car brought in with a relocating owner is declared and, on top of that, falls within the charge to first registration tax under Cap. 330.
Transhipment and transit are exempt only where their defining features are present. Transit cargo must remain on the same ship or aircraft; transhipment cargo must move on a through transport document from outside Hong Kong to outside Hong Kong. Cargo landed into a Hong Kong warehouse and forwarded under a fresh contract of carriage meets neither definition and is declared both as an import and as an export.
None of the sixteen categories displaces the licensing requirements in Schedules 1 and 2 to the Import and Export (General) Regulations (Cap. 60A) or under the Strategic Commodities Regulations (Cap. 60G). Personal baggage containing a controlled article needs a licence even though it needs no declaration.
The declaration charge on non-food goods is 20 cents on the first HK$46,000 of the value of the goods plus 12.5 cents for each additional HK$1,000 or part thereof, rounded up to the nearest 10 cents, and it may not exceed HK$200 per declaration. The basis is the Import and Export (Registration) Regulations (Cap. 60E). The regulators do not publish the number of the regulation that sets the formula itself: regulations 8(3) and 8(4) appear in the Census and Statistics Department’s lodgement notice in a footnote to the charge table, in relation to articles exempted from the charge, and that citation cannot be carried across to the formula.
The 20 cents is the charge for the whole first tranche of HK$46,000, not a rate per thousand within it. The Census and Statistics Department’s official wording is “20 cents in respect of the first $46,000 of the value of the goods and 12.5 cents in respect of each additional $1,000”.
The practical result is that the charge is small in absolute terms and reaches its ceiling fairly quickly. The figures below are the author’s arithmetic on the official formula.
|
Value of the goods |
Charge before rounding |
Charge payable |
|
HK$46,000 |
HK$0.20 |
HK$0.20 |
|
HK$100,000 |
0.20 + 54 × 0.125 = 6.95 |
HK$7.00 |
|
HK$500,000 |
0.20 + 454 × 0.125 = 56.95 |
HK$57.00 |
|
HK$1,000,000 |
0.20 + 954 × 0.125 = 119.45 |
HK$119.50 |
|
HK$1,646,000 |
0.20 + 1,600 × 0.125 = 200.20 |
HK$200 (capped) |
|
HK$10,000,000 |
0.20 + 9,954 × 0.125 = 1,244.45 |
HK$200 (capped) |
The HK$200 cap has applied since 1 August 2018. It was introduced by an amendment to Cap. 60E passed by the Legislative Council on 20 June 2018; the Legal Notice number of that amendment could not be established from accessible official sources and is not printed here.
On food items the charge is 20 cents per declaration irrespective of the value.
This is not a concession in the ordinary sense but a separate flat rate: a HK$20,000,000 consignment of food costs the same 20 cents as a HK$5,000 one.
Exports and re-exports attract the same formula as non-food imports: 20 cents on the first HK$46,000 and 12.5 cents for each additional thousand or part, with the same HK$200 ceiling. There is no separate flat food rate on the export side.
The government charge is not the whole cost of lodging. The electronic service provider charges its own message fee, which the Government does not set and does not publish in any official tariff. That is the component on which provider offers are worth comparing, because the government component is identical across all three.
The declaration charge is not automatically deductible as a “customs payment” — it is an ordinary operating expense. The general rules on deducting trading expenses are covered in our piece on the Hong Kong profits tax return.
The Clothing Industry Training Levy is 30 cents for each HK$1,000 of value or part thereof, charged in addition to the declaration charge on exports of Hong Kong-manufactured clothing and footwear items listed in Schedule 1 to the Industrial Training (Clothing Industry) Ordinance (Cap. 318). The levy is imposed by section 21 of that ordinance.
First, exports only. The levy is charged neither on imports nor on re-exports.
Second, Hong Kong-manufactured goods only. An article made outside Hong Kong and forwarded onward falls outside it — which, in an economy where re-exports are almost the whole of exports, leaves the levy a very narrow field.
Third, Schedule 1 items only. The schedule covers clothing and footwear by product category, from articles of plastics and rubber through knitted and crocheted goods to footwear and headgear.
The HK$200 ceiling set for the declaration charge does not apply to the Clothing Industry Training Levy. No official publication says so in terms; the conclusion follows from the fact that the Customs and Excise Department attaches the HK$200 ceiling expressly and only to the declaration charge, and describes the levy on a separate line as payable “in addition to” it.
The consequence is that on a large export consignment of Hong Kong manufacture the levy can be a multiple of the declaration charge itself. The author’s arithmetic: on a consignment worth HK$10,000,000 the declaration charge is capped at HK$200 while the levy is 10,000 × 0.3 = HK$3,000.
No official source publishes a value threshold below which the levy is not charged. The words “or part thereof” mean that a consignment of any value attracts at least 30 cents; the existence of a minimum threshold cannot be asserted without official confirmation, and none is asserted here.
The Customs and Excise Department collects the levy; the recipient of the money is the Clothing Industry Training Authority, for whose benefit Cap. 318 imposes it. The precise remittance mechanism sits in Cap. 318 itself, whose text is available only on the e-Legislation portal, which is closed to automated reading, and it is not reproduced here.
Underpayment of the levy is penalised separately from underpayment of the declaration charge. In the Customs and Excise Department’s own words, section 25 of Cap. 318 allows the Commissioner to impose a surcharge of not more than 20 times the short-paid amount, subject to a maximum of HK$10,000 for each export declaration lodged, payable within 14 days from the date of issue of the notice.
The objection procedure is set out in section 28 of Cap. 318, and an unsuccessful objector may appeal to the District Court under section 29.
The construction mirrors regulation 10 of Cap. 60E exactly — the same twenty-times multiplier and the same HK$10,000 ceiling apply where the declaration charge itself is short-paid. The practical consequence is that a single error in the value of a Hong Kong-manufactured export consignment can generate two surcharges, one on the charge and one on the levy.
Yes. The Customs and Excise Department’s live pages, current as at September 2026, continue to state the levy as payable. No abolition, suspension or rate change appears in any government publication of 2024 to 2026.
Late lodgement attracts a fixed penalty of between HK$20 and HK$200 depending on the value of the goods and the length of the delay. The scale is published identically by the Customs and Excise Department and by the Census and Statistics Department.
|
Total value of the articles |
After 14 days but within 1 month 14 days |
Within 2 months 14 days |
After 2 months 14 days |
|
Not exceeding HK$20,000 |
HK$20 |
HK$40 |
HK$100 |
|
Exceeding HK$20,000 |
HK$40 |
HK$80 |
HK$200 |
Note how the time bands are built: they run not from the date of lodgement but from the expiry of the fourteen-day period. “After 2 months 14 days” is in substance “two months after the default began”, and the scale rises no further: the maximum fixed penalty is HK$200.
The regulation of Cap. 60E that imposes this penalty could not be established from accessible official sources. Both government publications state the amounts without citing a regulation number; no number is printed here.
Regulation 10 of Cap. 60E governs short-paid declaration charges: the Commissioner may impose a surcharge of up to 20 times the amount short-paid, subject to a maximum of HK$10,000 per declaration.
The Census and Statistics Department states expressly that the HK$200 ceiling applicable to the charge itself does not apply to the computation of that penalty.
The practical consequence is that understating the value of a consignment costs incomparably more than being late. A HK$60 shortfall at the twenty-times multiplier produces HK$1,200 — six times the maximum late-lodgement penalty.
The offence is committed by a person who “knowingly or recklessly lodges any declaration with the Commissioner that is inaccurate in any material particulars”, and it renders that person liable to prosecution.
Neither the Customs and Excise Department nor the Census and Statistics Department publishes a fine for this offence: both pages state only that the person is liable to prosecution. The figure of HK$10,000 appears only in earlier Government publications that carry declaration charge rates long since superseded, and it is not stated here as current.
The number of the provision creating that offence is likewise published on no official page, and none is given here.The practical conclusion is unchanged: an inaccurate declaration is a free-standing offence rather than a technical slip, and its consequences are heavier than those of lodging late.
A demand note for a penalty or a short-paid charge is payable within 14 days from the date it is issued.
Section 36 of Cap. 60, “Offences in respect of licences, production notifications, etc.”, exists, but its text and its penalty could not be read: the e-Legislation portal is closed to automated access. No figure is given here for the section 36 penalty.
Only four categories of goods bear duty in Hong Kong: liquor, tobacco (other than smokeless tobacco and alternative smoking products), certain hydrocarbon oil, and methyl alcohol. The rates sit in Schedule 1 to the Dutiable Commodities Ordinance (Cap. 109); section 4(1) requires duty to be assessed and paid “at the rates and in the manner set out in Schedule 1”.
Hydrocarbon oil does not mean all of it. The Customs and Excise Department and its dutiable commodities guidebook narrow the category to motor spirit, aircraft spirit and light diesel oil.
Tobacco carries two exclusions. Smokeless tobacco and alternative smoking products are outside the category; the latter nevertheless remain controlled on import under Cap. 60 and the Smoking (Public Health) Ordinance (Cap. 371).
Liquor is bounded by strength. In practice the duty reaches only beverages exceeding 30 per cent alcohol by volume; wine and beverages at 30 per cent or below are charged at 0 per cent.
Duty under Cap. 109 falls equally on goods imported into Hong Kong and on goods manufactured in Hong Kong.That is precisely why it raises no tariff barrier and is consistent with free port status.
The practical confirmation is section 17(3AB) of Cap. 109, which prohibits the manufacture of liquor, methyl alcohol, tobacco and hydrocarbon oil without a licence. It is not only importation that is licensed but domestic production too.
The Customs and Excise Department states it directly: “No duty is levied on dutiable goods being removed to a bonded warehouse, for export or use as ships’ stores on board ships, aircraft or trains.”
This is the key to Hong Kong’s whole logistics model for dutiable goods. Imported liquor or tobacco placed in a bonded warehouse and then exported bears no duty; duty arises only when the goods are released for home consumption.
The dutiable commodities guidebook lists the grounds for refunding duty already paid. They include export of duty-paid goods with the Commissioner’s written consent; destruction or return of non-conforming or damaged goods; use of duty-paid goods in manufacturing dutiable products; consular use; samples for analysis by the Government Chemist; a reasonable quantity of duty-paid fuel placed in the fuel tank of a pleasure vessel of more than 60 tons net register; and duty-paid light diesel oil used in franchised buses.
From 19 September 2025 the Tobacco Control Legislation (Amendment) Ordinance 2025 split the penalties for dealing in duty-not-paid goods: for tobacco the maximum is now a fine of HK$2,000,000 and 7 years’ imprisonment, while for the other dutiable commodities it remains HK$1,000,000 and 2 years.
The same Ordinance raised the compoundable penalty for a passenger’s failure to declare dutiable goods from HK$2,000 to HK$5,000. The practical consequence for a trader is that tobacco is now punished on the same scale as importing licensable goods without a licence, whereas liquor and fuel are not.
First registration tax under the Motor Vehicles (First Registration Tax) Ordinance (Cap. 330) is administered by Customs but is not one of the four dutiable commodities. It is a tax on registration rather than a duty on importation, and importing a vehicle does not by itself trigger it.
Since 16 October 2024, duty on liquor exceeding 30 per cent alcohol by volume in containers of one litre or less is 100 per cent on the first HK$200 of value and 10 per cent on the remainder. Before that date the rate was 100 per cent on the whole value.
The Government’s press release of 16 October 2024 puts it this way: “the duty rate for liquor with import price over $200 will be reduced from 100 per cent to 10 per cent for the portion above $200, while the duty rate for the portion of $200 and below as well as liquor with import price of $200 or below will remain at 100 per cent.”
The threshold applies per bottle, not per consignment. A consignment of two hundred bottles at HK$190 each is charged at 100 per cent throughout; a single bottle at HK$38,000 produces HK$200 at 100 per cent plus HK$3,780 at 10 per cent — the author’s arithmetic.
For bottles of more than one litre, the value per litre is calculated first, the same two tiers are applied to it, and the resulting duty per litre is multiplied by the volume.
Two technical reservations published by the Customs and Excise Department change the outcome: where two or more bottles are packaged as a single item of goods they are regarded as a single bottle and the total volume is taken as the subject volume; and “bottle” includes a barrel and any other container.
|
Category |
Rate |
|
Liquor exceeding 30 % alcohol by volume |
100 % on the first HK$200, 10 % on the remainder |
|
Liquor other than wine at 30 % or below |
0 % |
|
Wine |
0 % |
The fallback assessment where valuation information is insufficient: for a consignment of less than 12 litres on which the information is inadequate, the Commissioner may assess duty at HK$160 per litre.
Immediate effect was given by the Public Revenue Protection (Duty on Liquor) Order 2024 of 16 October 2024, which gave the force of law to a proposed resolution moved by the Secretary for Commerce and Economic Development under section 4(2) of Cap. 109.
An order of that kind has a limited life, and the permanent instrument is a resolution of the Legislative Council amending Schedule 1 to Cap. 109. A Legislative Council subcommittee reported on that resolution to the House Committee on 22 November 2024.
The Legal Notice number, the date of passage and the commencement of the permanent instrument could not be confirmed from permitted sources, because the e-Legislation portal, the Legislative Council website and the electronic Gazette are all closed to automated reading. The operative authority for the rate should be taken to be Schedule 1 to Cap. 109 as amended; the Customs and Excise Department publishes the rate as current, with no reservation as to its temporary character.
According to the Government’s written reply in the Legislative Council of 23 July 2025, in the roughly eight and a half months after 16 October 2024 the volume of imports of liquor above 30 per cent rose by more than 20 per cent and their value by nearly 90 per cent. In the same reply the Government stated that it has no plan to adjust the liquor duty rate further.
The three remaining categories of dutiable commodity are charged not on value but on physical measures: tobacco by the stick or by weight, hydrocarbon oil and methyl alcohol by volume. That makes them structurally different from liquor: a change in the price of the goods does not move the duty.
|
Category of tobacco product |
Rate |
|
Cigarettes |
HK$3,306 per 1,000 sticks |
|
Cigars |
HK$4,258 per kilogram |
|
Chinese prepared tobacco |
HK$811 per kilogram |
|
Other manufactured tobacco, except that intended for the manufacture of cigarettes |
HK$4,005 per kilogram |
The length rule: a cigarette more than 90 millimetres long, excluding any filter or mouthpiece, counts as more than one cigarette — one additional stick for each additional 90 millimetres or part of it. The practical effect is that extended formats produce no duty saving.
The HK$3,306 per 1,000 figure is the product of two successive increases: the 2023-24 Budget raised the duty by 60 cents per stick, and the 2024-25 Budget raised it by a further 80 cents, to HK$3.306 per stick. Both figures appear in the Government’s reply in the Legislative Council (LCQ16) of 12 February 2025. The percentage equivalents of those increases — 31.48 per cent and 31.92 per cent — appear in the text of the question put to the Government rather than in the reply itself, and are stated here with that reservation.
The names and numbers of the legal instruments that gave effect to the two increases could not be established from permitted sources and are therefore not stated here. The operative rate is the figure published by the Customs and Excise Department.
|
Type of fuel |
Rate per litre |
|
Aircraft spirit |
HK$6.51 |
|
Leaded motor spirit |
HK$6.82 |
|
Unleaded motor spirit |
HK$6.06 |
|
Light diesel oil |
HK$2.89 |
|
Ultra low sulphur diesel |
HK$2.89 |
|
Euro V diesel |
HK$0.00 |
The zero rate on Euro V diesel is not an exit from the dutiable commodities regime but a zero rate inside it: the goods remain dutiable, and therefore still require an import licence, removal permits and warehousing treatment on the same terms as the rest.
Neither the date of the last change to hydrocarbon oil rates nor the instrument that made it could be established from permitted sources. Neither the 2025-26 Budget nor the 2026-27 Budget altered any duty rate — the full text of both Budget Speeches was checked.
The rate on methyl alcohol is HK$840 per hectolitre measured at 20°C, plus HK$28.10 per hectolitre for every 1 per cent by which the strength exceeds 30 per cent.
On 26 September 2025 a proposal was published to exempt from duty methyl alcohol placed in the fuel tank of an outbound vessel for use as fuel — the Dutiable Commodities (Amendment) Regulation 2025. On the wording of the proposal the exemption covers both green methyl alcohol produced sustainably and conventional methyl alcohol. The motion was moved by the Secretary for Transport and Logistics at the Legislative Council meeting of 15 October 2025, and the Transport and Logistics Bureau’s blog of 22 November 2025 confirms that the exemption was introduced by an amendment to the Dutiable Commodities Ordinance. The publications describe the instrument differently: the September 2025 proposal is called a Regulation, while the Bureau’s blog speaks of an amendment to the Ordinance itself.
The Legal Notice number and the commencement date could not be confirmed, and the Customs and Excise Department’s duty rate page as at September 2026 carries no note of the exemption, while the current edition of its dutiable commodities user guidebook is dated October 2024 and predates the amendment.
The mechanics of the exemption are, however, confirmed by the Department’s live form CED 429, “Confirmation of Receipt of Methyl Alcohol”, revision 12/2025, and that form shows the exemption to be claimed rather than automatic, and to carry conditions:
• the removal is made under a permit, not automatically;
• the master of the vessel confirms receipt of the methyl alcohol for the vessel’s fuel use only;
• the permit holder confirms the transfer of the alcohol into the vessel’s fuel tank;
• the completed confirmation must reach the Department’s Licence and Permit Division within 14 working days after the transfer operation;
• the form warns expressly that a false statement carries a fine of HK$1,000,000 and 2 years’ imprisonment.
The practical conclusion: the exemption operates, but it is obtained on paper, and the 14-working-day gap between bunkering and confirmation is a deadline whose breach turns an exempt consignment into a contested one.
Exemption from duty and exemption from the licensing regime are not the same thing. Wine and beer are charged at zero, but they remain dutiable commodities, and importing a consignment of wine requires the same set of documents as importing a consignment of spirits.
Section 17(3) of Cap. 109 prohibits the import of dutiable commodities without an import and export licence or an applicable exemption.
Section 17(3AB) prohibits manufacture without the corresponding manufacturer’s licence — for liquor (except in the cases covered by section 64A), methyl alcohol, tobacco and hydrocarbon oil.
Section 23(1) permits the removal of dutiable commodities only by the holder of a general bonded warehouse licence or by the holder of a removal permit. In other words, goods do not move freely between the control point, the warehouse and the buyer; each movement is authorised individually.
Licences and permits are granted by the Commissioner of Customs and Excise under section 7(1); the fees are set by subsidiary legislation made under section 6(1)(g).
|
Type of licence |
Annual fee |
|
Import and Export Licence |
HK$1,320 |
|
Special Import Licence (hydrocarbon oil) |
HK$1,320 |
|
General Bonded Warehouse Licence |
HK$26,800 |
|
Public Bonded Warehouse Licence |
HK$26,800 |
|
Licensed Warehouse Licence |
HK$26,800 |
|
Hydrocarbon Oil Manufacturer’s Licence |
HK$24,650 |
|
Tobacco Manufacturer’s Licence |
HK$22,700 |
|
Liquor Manufacturer’s Licence |
HK$22,700 |
|
Distillery Licence |
HK$22,700 |
|
Still for an approved educational, scientific or charitable institution |
free |
|
Amendment to licence conditions |
HK$620 per modification |
Every licence is issued for one year.
Removal permits, unlike licences, attract no fee. Four principal types are in use: First and Referral Removal Permits — issued separately for duty-not-paid and for duty-paid goods; Export Permits; and Ships’ Stores Permits.
The normal processing time for a permit application is half a working day. Applications are made through the Dutiable Commodities System, the Customs and Excise Department’s dedicated electronic platform.
The Department’s own formulation: “No duty is levied on dutiable goods being removed to a bonded warehouse, for export or use as ships’ stores on board ships, aircraft or trains.” This is the mechanism that makes re-export trade work: a consignment of spirits that passes through Hong Kong in a bonded warehouse and leaves again generates no duty — provided every movement is covered by a permit.
Grounds for refund of duty already paid include, among others, duty-paid fuel in a pleasure vessel of more than 60 tons net register and light diesel oil used in franchised buses.
Hong Kong law has no separate category of “goods requiring a licence”: a licensable good is a species of prohibited article. The point matters in practice, because importing a licensable good without its licence is not treated as a declaration irregularity but as the import of a prohibited article.
The term “prohibited article” in section 2 of the Import and Export Ordinance (Cap. 60) has three limbs: (a) an article the import or export of which is prohibited by the Ordinance itself; (b) an article the import or export of which is permitted subject to the terms and conditions of a licence; and (c) an article prohibited or controlled under any other law.
It is limb (b) that turns every licensable good into a prohibited article. Both the burden of proof and the size of the penalty follow from that.
The same section supplies two definitions that dispose of most transit questions: an “article in transit” is one brought into Hong Kong solely to be taken out again, remaining on the same vessel or aircraft; “transhipment cargo” is cargo moving on a through bill of lading from a place outside Hong Kong to a place outside Hong Kong.
|
Section of Cap. 60 |
What it prohibits |
|
6A |
Import and export of strategic commodities without a licence |
|
6C |
Import of articles listed in Schedule 1 to Cap. 60A |
|
6D |
Export of articles listed in Schedule 2 to Cap. 60A |
|
6E |
Carriage of prohibited articles in the waters of Hong Kong |
|
2AA |
Defines the airport cargo transhipment area |
Regulation 3 of the Import and Export (General) Regulations (Cap. 60A) points to Schedule 1 for the purposes of section 6C(1), and regulation 4 points to Schedule 2 for the purposes of section 6D(1). The list of licensable goods therefore sits not in the Ordinance but in subsidiary legislation, and changes without any amendment to the Ordinance itself.
|
Schedule |
Subject matter |
|
1 |
Goods whose import requires a licence |
|
2 |
Goods whose export requires a licence |
|
3 |
Personal baggage and ships’ stores |
|
4 |
Textiles traders |
|
5 |
Textile production notifications |
|
6 |
Frozen and chilled meat and poultry in personal baggage |
|
7 |
The Kimberley Process (rough diamonds) |
|
9 |
Optical disc mastering and replication equipment |
For articles falling within Part 1 of the relevant Schedule, the maximum penalty is a fine of HK$500,000 and 2 years’ imprisonment.
For articles in Part 2 the penalty depends on the mode of trial: on summary conviction, a fine of HK$500,000 and 2 years’ imprisonment; on indictment, a fine of HK$2,000,000 and 7 years’ imprisonment.
Section 36 of Cap. 60 creates a separate offence headed “Offences in respect of licences, production notifications, etc.”, but its text and penalty could not be read from permitted sources, and no figure for it is stated here.
Three supporting provisions also matter: section 18 on unmanifested cargo, section 33 on evidentiary presumptions, and section 34, which places the burden of proof on the person asserting that a licence was held or that an exemption applied. The last of these means that in a dispute with Customs it is the importer who must prove the lawfulness of the import.
The official text of Cap. 60 used in preparing this article is the version of 6 February 2015 as notified by Hong Kong to the World Trade Organization. That is an official but dated text rather than the current consolidation; before acting on a particular shipment the version should be checked against the e-Legislation portal.
A strategic commodities licence is required for every individual shipment — on import, export, re-export and transhipment, irrespective of the destination. That is the fundamental difference from every other licensable category: there are no “friendly” directions, and the origin or destination of the cargo does not by itself release it from licensing.
Licences are issued by the Director-General of Trade and Industry under the Import and Export (Strategic Commodities) Regulations (Cap. 60G), made under section 6A of Cap. 60.
Goods in transit are, as a rule, exempt from licensing — with two exceptions: the sensitive items listed in Schedule 2, and goods related to weapons of mass destruction. The transit exemption is therefore not unconditional and cannot be assumed.
The control list sits in Schedule 1 to Cap. 60G and has two parts: the Munitions List and the Dual-use Goods List, which is divided into ten categories numbered 0 to 9, with category 5 split into two parts.
|
Category |
Title |
|
0 |
Nuclear materials, facilities and equipment |
|
1 |
Special materials |
|
2 |
Materials processing |
|
3 |
Electronics |
|
4 |
Computers |
|
5, part 1 |
Telecommunications |
|
5, part 2 |
Information security |
|
6 |
Sensors and lasers |
|
7 |
Navigation and avionics |
|
8 |
Marine |
|
9 |
Aerospace and propulsion |
Schedules 2, 3 and 4 do different work: Schedule 2 lists articles in transit connected with chemical weapons uses; Schedule 3 contains end-use restrictions; Schedule 4 lists the activities controlled by reference to Schedule 3.
The most recent update to the control list is the Amendment of Schedule 1 Order 2025, gazetted on 17 January 2025 and in effect from 30 May 2025. It reflected changes in the lists of the Wassenaar Arrangement, the Nuclear Suppliers Group, the Missile Technology Control Regime, the Australia Group, the Chemical Weapons Convention and the Arms Trade Treaty. The instrument is L.N. 6 of 2025, published in Legal Supplement No. 2 to the Gazette of 17 January 2025 (No. 3, Vol. 29); those particulars are given by the Trade and Industry Department in Strategic Trade Controls Circular No. 5/2025 of 9 May 2025. No 2026 amendment to the control list was found: the Department’s 2026 circular index lists only three circulars, none of which touches Schedule 1.
|
Parameter |
Value |
|
Processing of a straightforward application |
no more than 2.5 clear working days |
|
Pre-classification of goods |
two working days |
|
Licence fee |
free of charge |
|
Validity of an import licence |
6 months, part-shipment permitted |
|
Validity of an export licence |
3 months, consignment-based |
|
Temporary import and export arrangements |
3 months |
|
Return of the endorsed licence by the carrier to the Department |
within 14 days, with the manifest |
|
International Import Certificate (IIC) |
HK$115 (Department’s fee schedule effective 31 March 2026) |
|
Delivery Verification Certificate (DVC) |
HK$345 |
The licence itself is free, but the supporting certificates are not — and it is precisely those certificates that a counterparty or a supplying country’s regulator most often demands.
On summary conviction the penalty is a fine of HK$500,000 and 2 years’ imprisonment; on indictment, an unlimited fine and 7 years’ imprisonment. In addition the Trade and Industry Department may take administrative action which, in its own words, “may involve, but not necessarily be confined to, suspension of a licence, refusal to issue a licence, debarment of all licensing facilities”. Mandatory forfeiture of the goods is not stated in the Department’s published material and is not asserted here.
The scale of the regime is visible in the Department’s 2026 Estimates: 187,000 strategic commodities licences are planned for the year. That is an order of magnitude more than any other licensable category, and shows that the regime reaches ordinary electronics and telecommunications trade, not only defence trade.
Rice is the only commodity classified in Hong Kong as reserved, and its import and export are licensed regardless of the size of the consignment. The regime rests on the Reserved Commodities Ordinance (Cap. 296) and the Reserved Commodities (Control of Imports, Exports and Reserve Stocks) Regulations (Cap. 296A), and is administered by the Trade and Industry Department.
Exempt from licensing is rice in personal baggage brought in or taken out solely for the traveller’s own consumption or as a gift, in an amount not exceeding 15 kilograms.
The second exemption covers transhipment and transit cargo, but on conditions: air-to-air transhipment is exempt where the rice remained at all times in the cargo transhipment area of Hong Kong International Airport; other transhipment modes only where there is a valid registration under the Transhipment Cargo Exemption Scheme and its conditions are met; and cargo in transit only where it remained at all times in or on the vessel or aircraft that brought it in. Invoking “transhipment” without satisfying those conditions does not produce an exemption. Everything else — including small commercial consignments and samples — requires a licence.
Registration as a registered rice stockholder is free of charge, and applications are accepted throughout the year.
The mandatory reserve stock corresponds to fifteen days’ consumption and is computed as 17 per cent of the import quantity undertaken or of the offtake in the preceding period.
The reserve stock must be imported in full before the registration period begins, rather than accumulated during it. That requirement is the usual barrier to entry: working capital is locked up before the first licence is ever issued.
|
Date of application |
Registration period granted |
|
1 June to 30 November |
2 years |
|
1 December to 31 May |
1.5 years |
The difference exists because registration periods are aligned to a common calendar rather than counted from the filing date. An application filed on 2 December costs the same as one filed on 30 November but runs six months shorter.
|
Type of licence |
Validity |
Coverage |
|
Rice import licence |
8 weeks |
one shipment |
|
Rice export licence |
28 days |
one shipment |
Both licences cover a single shipment: part-shipment against one licence is not allowed.
The processing target for a rice licence in the Department’s 2026 Estimates is one working day, and 9,160 such licences are planned for the year.
The Trade and Industry Department’s e-Form service ceased operation on 31 January 2024. Applications are now made through the Trade Single Window or through the Department’s Integrated Customer Service Centre. Links and bookmarks to the former e-Form service no longer work, and an attempt to file through them produces a missed deadline rather than a rejection that can be corrected.
Cap. 60 and Cap. 60A are not the only sources of licensing requirements: more than twenty separate ordinances impose their own controls, and ten different authorities issue the licences and permits. Choosing the wrong authority costs more than a delay: the cargo sits at the terminal while the application sits in the wrong department.
|
Category of goods |
Principal ordinance |
Issuing authority |
|
Live mammals, birds and reptiles |
Cap. 139 and Cap. 421 |
AFCD |
|
Plants and plant pests |
Cap. 207 |
AFCD |
|
Endangered species |
Cap. 586 |
AFCD |
|
Animal carcasses |
Cap. 421 |
AFCD |
|
Controlled chemicals |
Cap. 145 |
Customs and Excise |
|
Dangerous drugs |
Cap. 134 |
Department of Health |
|
Dutiable commodities |
Cap. 109 (rates) and Cap. 60 (licensing control) |
Customs and Excise |
|
Explosives |
Cap. 60G, Cap. 295 and Cap. 560 |
Trade and Industry Department; Mines Division, CEDD; Create Hong Kong |
|
Firearms |
Cap. 238 and Cap. 60G |
Police; Trade and Industry Department |
|
Food items |
Cap. 132 |
FEHD |
|
Infectious goods |
Cap. 599A |
Department of Health |
|
Motor vehicles |
Cap. 330 |
Customs and Excise |
|
Optical disc equipment |
Cap. 60A |
Customs and Excise |
|
Hydrofluorocarbons and ozone depleting substances |
Cap. 403, Cap. 133 and Cap. 60 |
EPD; AFCD |
|
Pesticides |
Cap. 60, Cap. 133 and Cap. 403 |
AFCD; EPD |
|
Pharmaceutical products |
Cap. 60A and Cap. 586 |
Department of Health; AFCD |
|
Prescribed articles |
Cap. 60 |
Customs and Excise |
|
Radioactive substances |
Cap. 60K |
Department of Health |
|
Radio transmitting equipment |
Cap. 106 |
Communications Authority |
|
Frozen and chilled meat and poultry |
Cap. 60A |
FEHD |
|
Game, meat, poultry and eggs |
Cap. 132AK |
FEHD |
|
Sand |
Cap. 147 |
CEDD |
|
Strategic commodities |
Cap. 60 and Cap. 60G |
Trade and Industry Department |
|
Rough diamonds |
Cap. 60 and Schedule 7 to Cap. 60A |
Trade and Industry Department |
|
Waste, including hazardous waste |
Cap. 354 |
EPD |
|
Hazardous chemicals |
Cap. 595 |
EPD |
|
Prohibited weapons |
Cap. 217 |
Police |
|
Toothfish |
Cap. 635A |
AFCD |
|
Mercury |
Cap. 640 |
EPD |
|
Alternative smoking products |
Cap. 60 and Cap. 371 |
Customs and Excise |
|
Smokeless tobacco products |
Cap. 132BW |
FEHD |
|
Powdered formula (export) |
Cap. 60A |
Trade and Industry Department |
|
Chinese herbal medicines |
Cap. 60A |
Department of Health |
|
Rice |
Cap. 296A |
Trade and Industry Department |
The import and export licence for pharmaceutical products is issued under Cap. 60A, not under the Pharmacy and Poisons Ordinance (Cap. 138). Registration of a product and permission to bring it in are separate procedures resting on separate authority.
The licence for frozen and chilled meat and poultry is likewise issued under Cap. 60A, not under the Public Health and Municipal Services Ordinance (Cap. 132). Cap. 132 governs food safety, but the licensing requirement on import lives in subsidiary legislation made under Cap. 60.
Control of rough diamonds rests on Cap. 60 and Schedule 7 to Cap. 60A, not on “Cap. 508”. The Cap. 508 citation appears in secondary publications in this context and is wrong.
A single consignment can fall under several licensing regimes at once, and a licence under one does not substitute for a licence under another. A consignment of prepared food with an alcohol content above 30 per cent requires both a Cap. 109 licence and FEHD clearance; a consignment of encryption equipment requires a strategic commodities licence regardless of the fact that the same goods may also be caught by the controls on radio transmitting equipment.
Since 1 May 2026, road cargo information is submitted through the Trade Single Window: ROCARS ceased operation at midnight on 1 May 2026, with no parallel run. This is the most significant operational change in Hong Kong trade practice in recent years, and it has already happened.
Government Electronic Trading Services is the platform through which the principal trade documents, including import and export declarations, are lodged.
Three service providers have been appointed since 2010: Brio Electronic Commerce Limited, Global e-Trading Services Limited (Ge-TS) and Tradelink Electronic Commerce Limited.
A declaration is lodged electronically — either directly through a provider or through the provider’s paper-to-electronic conversion service. The provider invoices the trader for the government declaration charge, the industry levy and its own service fee, and then remits the government portion. The practical consequence: the provider’s invoice is larger than the government charge, and the difference is a service fee, not a tax.
|
Phase |
Launch |
Coverage |
|
Phase 1 |
28 December 2018, in full service from 2020 |
14 document types |
|
Phase 2 |
15 May 2023, fully implemented on 30 December 2023 |
28 document types |
|
Phase 3, batch 1 |
1 May 2026 |
cargo information, replacing ROCARS |
|
Phase 3, batches 2 and 3 |
from mid-2027 |
replacing GETS |
Phases 1 and 2 together cover 42 document types: 14 under Phase 1 and 28 under Phase 2. Phase 2 launched on 15 May 2023 with 14 types and was extended progressively to 28; full implementation was announced on 30 December 2023, ahead of schedule.
Registration for and subscription to the Trade Single Window’s online services are free, and document fees are identical for paper and online filing. The portal is www.tradesinglewindow.hk.
Phase 3 covers import and export declarations, road, air and sea cargo information, certificate of origin applications and dutiable commodities permits.
The Road Cargo System ran from 17 May 2010, was mandatory from 17 November 2011, and rested on the Import and Export (Electronic Cargo Information) Regulation.
The shipper, or a freight forwarder acting as shipper, submitted the data; it could be lodged up to 14 days in advance and no later than 30 minutes before the consignment was imported or exported by truck. The shipper received a Customs Cargo Reference Number, and the driver bundled that number with the vehicle registration mark not less than 30 minutes before passing a land boundary control point.
The system ceased operation from midnight on 1 May 2026. Users already registered with the Trade Single Window did not have to register again.
The Import and Export (Amendment) Ordinance 2025 was gazetted and largely commenced on 11 July 2025; it replaces GETS with the Trade Single Window and contains transitional provisions allowing Phase 3 and GETS to run in parallel.
The provisions deleting GETS commence on a day to be appointed by the Commissioner of Customs and Excise by notice in the Gazette, and the length of the parallel run has not been published. Its end cannot be planned to a fixed date; the Gazette notices have to be monitored.
The amended Hong Kong Imports and Exports Classification List was gazetted on 14 November 2025 and took effect on 1 January 2026, revising chemical products, telephone sets and fishing rods. Declarations for shipments on or after 1 January 2026 must follow the new edition.
On 29 December 2025 the Commerce and Economic Development Bureau opened an industry consultation on legislative amendments to facilitate the digitalisation of business-to-business trade documents. This is the next step after the Trade Single Window and, as at September 2026, it is at the consultation stage rather than in force.
Hong Kong issues non-preferential certificates of origin, five preferential forms, and a separate document confirming that goods were not manipulated during transhipment. They are frequently confused, and the consequences of the confusion arise not in Hong Kong but at destination, when preference is refused.
A Certificate of Hong Kong Origin (CHKO) certifies that the goods originate in Hong Kong.
A Certificate of Origin — Processing (COP) certifies that the goods underwent certain manufacturing operations in Hong Kong, but not enough to confer Hong Kong origin on them. These are fundamentally different documents, and using a COP where a CHKO is required results in rejection by the importer.
None of these certificates has a pre-set validity period; amendments to an issued certificate are made within 30 days of the date of issue.
Beyond the CHKO and the COP, the Government Approved Certification Organisations listed below issue two further non-preferential documents — the Certificate of Origin — Re-export and the Certificate of Origin — Re-export (Movement Confirmation), used for goods that were not produced in Hong Kong and are being exported onward.
Five forms are in use: CO (CEPA) for the Mainland of China, CO (New Zealand), CO (Georgia), CO (Peru) and Form AHK for ASEAN.
Certificates are issued by the Trade and Industry Department and by five Government Approved Certification Organisations: the Hong Kong General Chamber of Commerce; the Federation of Hong Kong Industries; the Chinese General Chamber of Commerce; the Chinese Manufacturers’ Association of Hong Kong; and the Indian Chamber of Commerce, Hong Kong.
Applications must be submitted at least 2 clear working days before the goods depart.
|
Document or registration |
Fee |
|
Electronic CHKO or COP |
HK$110 per certificate, excluding the service provider’s message fee |
|
Department’s fee schedule |
in the edition of 31 March 2026 |
|
Annual factory registration |
HK$3,003 |
|
Certified true copy of an import or export licence |
HK$135 |
|
Rough Diamond Trader Registration |
HK$645 for two years, renewal HK$430 |
|
Kimberley Process Certificates |
HK$175–180 |
Processing targets in the Department’s 2026 Estimates: a certificate of origin within 1.5 working days; pre-classification of goods within two working days; a Kimberley Process Import Certificate within 20 minutes and an Export Certificate on the following working day. For 2026, 2,610 certificates of origin and 1,290 Kimberley Process certificates are planned.
The Certificate of Non-Manipulation is issued by the Customs and Excise Department under the FTA Transhipment Facilitation Scheme and confirms that goods from a free trade agreement partner which passed through Hong Kong were not manipulated here and retain their entitlement to preference at destination.
Applications are made by email or through the Trade Single Window at least one calendar day before the cargo arrives. The Department issues a demand note and then the certificate.
|
Category |
Fee |
|
Category D — documentary processing |
HK$184 |
|
Categories A–C — where consolidation or repacking takes place in Hong Kong |
HK$675–1,600 |
It is the trader who must supply the certificate to the importing country: the Hong Kong side does not forward it anywhere.
Where a Hong Kong company sits as the trading link between a supplier and a warehouse in a third jurisdiction, the choice of certificate determines where the buyer’s duty arises; the combination of a Hong Kong and a Middle East element is examined in our piece on the Hong Kong–UAE dual structure.
Goods produced in Hong Kong and imported into the United States must be marked as originating in China rather than in Hong Kong. The requirement has applied since 2020, was challenged by Hong Kong at the World Trade Organization, was won at panel level — and nonetheless continues to apply.
US Customs and Border Protection announced the requirement on 11 August 2020. The original date of application, 25 September 2020, was postponed to 9 November 2020.
The wording of the requirement: goods produced in Hong Kong entering the United States “may no longer be marked to indicate ‘Hong Kong’ as their origin, but must be marked to indicate ‘China’”.
The Trade and Industry Department’s page on the requirement was last updated on 31 December 2025 and still describes it as operative.
|
Stage |
Date |
|
Request for consultations |
30 October 2020 |
|
Panel established |
22 February 2021 |
|
Panel report circulated |
21 December 2022 |
|
United States appealed |
26 January 2023 |
The panel found the measure inconsistent with Article IX:1 of the GATT and rejected the United States’ reliance on the security exception in Article XXI(b)(iii), holding that it is not wholly self-judging.
The United States appealed on 26 January 2023 to the Appellate Body, which is not functioning for want of a quorum. The consequence: the panel report has not been adopted and has not become legally binding.
No repeal of the requirement and no step towards compliance could be found. As at September 2026 the marking requirement applies.
Marking a Hong Kong-origin product “China” for export to the United States changes neither its origin under Hong Kong law nor the content of a Certificate of Hong Kong Origin issued in Hong Kong. It is a destination-country requirement about physical marking, not a redefinition of origin.
The practical risk runs the other way: a mismatch between the marking on the packaging and the certificate of origin in the document set is a recurring reason for US Customs to detain a shipment. The documents and the physical marking should be reconciled in advance rather than on arrival.
For sales to a United States buyer this is a further reason to record in the contract which party is responsible for marking and for the consequences of its non-compliance with the importing country’s requirements.
Hong Kong’s total merchandise exports in 2025 were HK$5,240.3 billion — a historical high and an increase of 15.4 per cent on 2024. The figures matter for a reason beyond their size: they show that the free port regime serves a flow in which re-exports have almost entirely displaced domestic production.
|
Indicator |
2025 value |
|
Total merchandise exports |
HK$5,240.3 billion, +15.4 % |
|
Merchandise imports |
+15.5 % |
|
Trade deficit |
HK$446.6 billion, 7.9 % of imports |
|
Total merchandise trade |
HK$10,927.1 billion |
|
Re-exports |
HK$5,174.2 billion |
|
Domestic exports |
HK$66.0 billion |
Imports for 2025 are published by the Census and Statistics Department directly: HK$5,686,833 million, that is HK$5,686.8 billion. Only one figure here is derived: re-exports as a share of total exports, 98.7 per cent.
The Department’s rounded figures do not add to the tenth: 5,174.2 + 66.0 = 5,240.2 against a published 5,240.3, while 5,240.3 + 5,686.8 = 10,927.1 matches the published total trade. The gap is rounding rather than error: the Department computes its aggregates on unrounded data.
The 2025 totals were released by the Census and Statistics Department on 27 January 2026.
In 2025 Hong Kong was the world’s fifth largest merchandise trading entity, two places up from 2024. That ranking does not come from the Department’s own statistics but from the World Trade Organization’s Global Trade Outlook and Statistics; the Government reported it on 2 April 2026, giving merchandise trade of US$1,585 billion, up 17.5 per cent year on year and about 3 per cent of world trade. That figure does not reconcile with the Hong Kong aggregate: HK$10,927.1 billion at the pegged rate is about US$1,401 billion, and the 17.5 per cent growth differs from the published 15.4 and 15.5 per cent. The World Trade Organization compiles its series on its own basis and it cannot be compared directly with the Department’s; both figures are given here as published, with no attempt to reconcile them.
|
Direction |
2025 value |
|
Re-exports to the Mainland of China |
HK$3,103.0 billion |
|
Imports from the Mainland of China |
HK$2,491.8 billion |
|
Domestic exports to the Mainland of China |
HK$25.5 billion |
|
Merchandise trade with the United States |
US$68.5 billion, +6.5 % |
|
Exports to the United States |
US$41.6 billion |
|
Imports from the United States |
US$27.0 billion |
|
Rounding note |
41.6 + 27.0 = 68.6 against a published 68.5 |
In June 2026 exports were HK$641.1 billion (+53.4 per cent on June 2025), imports HK$693.0 billion (+45.4 per cent), and the deficit HK$52.0 billion. The data were released on 27 July 2026; the difference between the rounded export and import figures is 51.9, the discrepancy arising because the deficit is computed on unrounded data.
In the first half of 2026 exports rose 39.1 per cent and imports 40.6 per cent, with a deficit of HK$294.6 billion, or 7.9 per cent of imports. The Government identifies AI-related electronic products as the principal driver.
In July 2026 exports were HK$672.5 billion (+50.7 per cent year on year), imports HK$677.4 billion (+41.0 per cent), and the deficit HK$4.9 billion, or 0.7 per cent of imports. The figures were released by the Census and Statistics Department on 2 September 2026 and are the most recent at the date of writing.
The Customs and Excise Department’s year-end review for 2025, published on 12 February 2026, records 38,869 cases — an increase of 24 per cent on 2024.
|
Area |
2025 result |
|
Smuggling |
286 cases, +22 %, seizure value HK$4.217 billion |
|
Illicit cigarettes |
29,037 cases, 604 million cigarettes, 28,580 persons arrested |
|
Alternative smoking products |
2,600 cases, about 9.35 million items |
|
Illegal filling stations |
39 cases, 96,211 litres of illicit motor spirit |
|
Dangerous drugs |
961 cases, about 7.5 tonnes |
|
Endangered species |
573 cases, 84.5 tonnes |
|
Money laundering |
12 cases, HK$12.8 billion |
|
Intellectual property rights |
723 cases, about 970,000 articles |
No separate statistics are published for false trade declarations or for breaches of the strategic commodities regime. That is a limitation of the source, not evidence that such cases do not occur.
According to the Hong Kong Fact Sheet, September 2025 edition, total seizures in 2024 were HK$9.132 billion, and 2,278 persons and firms were prosecuted. The Fact Sheet separately records 158 cases of unlawful commercial malpractice — a count of cases, not of persons — including breaches of licensing controls over powdered formula, strategic commodities and reserved commodities, together with contraventions of consumer protection legislation and of the regulatory requirements for money service operators.
The conclusion a trader should draw from these figures is direct: enforcement concentrates on the dutiable and licensable categories, and it is there that a documentary error turns from an administrative matter into a criminal one.
The sequence for a Hong Kong company importing or exporting its first consignment runs to nine steps, and the first four are completed before shipment. The expensive mistakes are almost always made at steps 1 to 3 and discovered at step 7.
The test is the four categories in Cap. 109: liquor, tobacco (other than smokeless tobacco and alternative smoking products), certain hydrocarbon oil and methyl alcohol. If the goods are dutiable, an import and export licence, a permit for each movement and, as a rule, a bonded warehouse will all be required.
Two lists must be checked at once: the Schedules to Cap. 60A, and the consolidated table of controlled goods with its issuing authorities. One consignment can require licences from several different departments, and they are not interchangeable.
Strategic control is checked in every case — regardless of the outcome of steps 1 and 2, and regardless of destination. Electronics, encryption products, sensors, navigation equipment and special materials fall within the control list more often than traders expect.
|
Document |
Lead time |
|
Strategic commodities licence |
processing target for an ordinary application — no more than 2.5 clear working days |
|
Certificate of origin |
at least 2 clear working days before departure |
|
Certificate of Non-Manipulation |
at least one calendar day before the cargo arrives |
|
Removal permit for dutiable commodities |
normally half a working day |
|
Rice import licence |
target one working day |
Since 1 May 2026 the information goes through the Trade Single Window; the former ROCARS is no longer operating. The shipper submits, and the driver links the reference number received to the vehicle registration mark before passing the control point.
No customs duty is paid at this step unless the goods are dutiable: there is no tariff. The only payments are charges — the declaration charge, the industry levy where it applies, and certificate fees.
The declaration is lodged with the Commissioner of Customs and Excise within 14 days after the goods are imported or exported, except for exempted articles. Lodging on the wrong form counts as not lodging at all, rather than as an error in a lodged declaration.
A demand note is payable within 14 days of its issue. Late lodgement of the declaration and underpayment of the charge are two separate breaches with different consequences, and the second is the more expensive.
The transaction file serves not only a customs audit but a tax one: evidence of where the contract was concluded, where the decisions were taken and how the goods moved is what the question of the source of trading profits is built on. The mechanics are covered in our piece on the offshore profits claim in Hong Kong.
Settlement of trade transactions requires a bank account opened on terms that match the actual trade flow; what banks expect from non-resident structures is covered in our piece on corporate bank accounts in Hong Kong for non-residents.
The eight mistakes below recur constantly, and each has a measurable price — from a fine of a few tens of Hong Kong dollars to criminal liability.
The absence of a tariff does not remove the obligation to lodge a declaration within 14 days of import or export. On a consignment valued above HK$20,000 the cost is HK$40 if lodged within one month and 14 days, HK$80 within two months and 14 days, and HK$200 thereafter. The sums are small, but they accrue per declaration, and on regular shipments they accumulate into a pattern of default that Customs can see.
20 cents is the charge for the whole of the first tranche of value up to HK$46,000, not a rate per thousand.Misreading it produces an underpayment. Regulation 10 of Cap. 60E allows a surcharge of up to twenty times the short-paid amount, subject to a maximum of HK$10,000 per declaration, and the HK$200 ceiling does not apply to that computation.
The Clothing Industry Training Levy is charged in addition to the declaration charge and is not subject to the HK$200 ceiling. On an export consignment of Hong Kong-manufactured goods valued at HK$10,000,000, the declaration charge is HK$200 and the levy is HK$3,000 — fifteen times as much.
Wine and beer are charged at 0 per cent but remain dutiable commodities under Cap. 109. Importing a consignment of wine without an import and export licence breaches section 17(3); it is not a technical irregularity. The cost is not the duty, which is nil, but the penalty for unlicensed import and the seizure of the consignment.
The two-tier rate applies to each bottle separately. A consignment of two hundred bottles at HK$190 each yields not a single Hong Kong dollar at the 10 per cent tier — the whole value is charged at 100 per cent. The error in the pricing model surfaces only after the duty has been paid.
A strategic commodities licence is required irrespective of destination. The cost here is the highest on this list: on indictment, an unlimited fine and 7 years’ imprisonment, plus possible debarment from applying for licences.
The Trade and Industry Department’s e-Form service closed on 31 January 2024, and ROCARS ceased operation at midnight on 1 May 2026 with no parallel run. Filing through a closed channel does not produce a rejection that can be corrected — it produces a missed deadline and cargo stuck at the terminal.
In 2025 the Customs and Excise Department brought 723 intellectual property cases and seized about 970,000 articles. The importer answers for the consignment even where it was bought in good faith from a supplier, and seizure happens before, not after, the question of fault is resolved. The logic of trade mark protection in Hong Kong is set out in our piece on trade mark registration in Hong Kong.
• Re-export and transit structures: goods that pass through Hong Kong in a bonded warehouse or on a through bill of lading generate no duty and, in the case of transhipment cargo, no declaration.
• Distributors of consumer goods with no dutiable or licensable element: the only fiscal burden is the declaration charge, capped at HK$200.
• Importers of wine and low-strength alcoholic products: the rate is 0 per cent, even though the licensing requirements remain.
• Companies that need predictable timing: processing targets are published and measured in working days rather than months.
• Traders dealing with free trade agreement partners: the Certificate of Non-Manipulation preserves preference where cargo is transhipped through Hong Kong.
• Anyone expecting no reporting because there is no tariff: the declaration is compulsory, and its absence is visible to Customs shipment by shipment.
• Traders in dutiable goods who are not ready for a warehousing regime: licences, a permit for every movement and a warehouse are a standing operational load, not a one-off procedure.
• Exporters of Hong Kong-manufactured clothing and footwear who are sensitive to charges: the industry levy is not capped.
• Suppliers of electronics and encryption products who are not ready for export control: a licence is required for every shipment regardless of direction.
• Anyone planning to ship to the United States marked “Made in Hong Kong”: the “China” marking requirement applies notwithstanding the WTO ruling in Hong Kong’s favour.
• Where the goods may fall within the strategic commodities control list — the cost of error here is criminal, and self-classification is unreliable.
• Where the methyl alcohol exemption for marine fuel is to be relied on — the legal instrument is not published in an accessible form, and availability should be confirmed in writing.
• Where a single shipment falls under several licensing regimes and the lead times of different departments have to be reconciled.
• Where the structure invoices through a Hong Kong company without the goods physically entering Hong Kong — the customs and the tax analysis diverge at that point.
• Where a declaration containing an error has already been lodged — the correction route and the exposure under regulation 10 depend on exactly what was stated wrongly.
If a Hong Kong company is only now being set up for the trade flow, start with the structure — the procedure and requirements are set out in our piece on company registration in Hong Kong.
Does Hong Kong charge customs duty on imports?
No. Hong Kong is a free port and levies no tariff on imports or exports. Duty is charged only on the four categories of dutiable commodities under Cap. 109 — liquor, tobacco, certain hydrocarbon oil and methyl alcohol — and does not depend on the country of origin.
Is a declaration required if there is no duty?
Yes. A declaration is lodged with the Commissioner of Customs and Excise within 14 days after the import or export of any article other than an exempted article. The absence of a tariff does not remove the obligation.
How much does it cost to lodge an import declaration in Hong Kong?
20 cents in respect of the first HK$46,000 of the value of the goods and 12.5 cents for each additional HK$1,000 or part of it, rounded up to the nearest 10 cents, subject to a maximum of HK$200 per declaration. Food items attract a flat 20 cents irrespective of value.
Which goods are exempt from declaration?
The Census and Statistics Department publishes sixteen categories, including transhipment cargo on a through bill of lading, transit on the same vessel, ships’ and aircraft stores, personal baggage other than motor vehicles, postal packets valued at less than HK$4,000 and samples valued at less than HK$1,000.
What is the duty on liquor in Hong Kong in 2026?
For liquor above 30 per cent alcohol by volume in containers of one litre or less, 100 per cent on the first HK$200 of the value of the bottle and 10 per cent on the remainder. Wine and liquor at 30 per cent or below are charged at 0 per cent but remain dutiable commodities and still require a licence.
Which goods require an import licence in Hong Kong?
The lists sit in Schedules 1 and 2 to Cap. 60A, and beyond them more than twenty ordinances impose sectoral regimes — from endangered species and pharmaceuticals to waste and radio transmitting equipment. Ten different authorities issue the licences and permits.
What are strategic commodities, and when is a licence required?
Strategic commodities are the items on the control list in Schedule 1 to Cap. 60G, which comprises a Munitions List and ten categories of dual-use goods numbered 0 to 9. A Trade and Industry Department licence is required for every shipment irrespective of destination.
Is ROCARS still operating?
No. The system ceased operation at midnight on 1 May 2026; road cargo information is now submitted through the Trade Single Window. There was no parallel run.
What happens if a declaration is lodged late?
The penalty depends on the value of the consignment and the length of the delay: for a value not exceeding HK$20,000, HK$20, HK$40 or HK$100; above that value, HK$40, HK$80 or HK$200. Underpayment of the charge is dealt with separately — regulation 10 of Cap. 60E allows up to twenty times the short-paid amount, subject to HK$10,000 per declaration.
Does a Hong Kong company need a certificate of origin?
Only where the destination country or a preferential regime requires one. A Certificate of Hong Kong Origin certifies Hong Kong origin; a Certificate of Origin — Processing certifies only that processing took place, and one cannot stand in for the other.
Must Hong Kong goods be marked “Made in China” for shipment to the United States?
Yes, the US requirement applies. Hong Kong won dispute DS597 at panel level on 21 December 2022, but the United States appealed on 26 January 2023 into a non-functioning Appellate Body, and the report has not been adopted.
Are a Hong Kong company’s trading profits taxed if there is no duty?
Yes. The absence of a customs tariff has nothing to do with profits tax: trading profits are charged on the territorial basis, and the question of source is decided under separate rules.
1. Hong Kong levies no customs duty on imports or exports and has no VAT or sales tax.
2. Duty is charged only on the four categories under Cap. 109, and it does not depend on the country of origin.
3. The declaration is lodged within 14 days of import or export; lodging on the wrong form counts as not lodging at all.
4. The declaration charge is capped at HK$200, but the Clothing Industry Training Levy is not.
5. 20 cents is the charge for the whole first tranche up to HK$46,000, not a rate per thousand; misreading it produces an underpayment.
6. A licensable good is, in the Hong Kong construction, a “prohibited article” under limb (b) of section 2 of Cap. 60 — which is where the size of the penalty comes from.
7. The maximum under sections 6C and 6D for Part 2 articles is a fine of HK$2,000,000 and 7 years’ imprisonment on indictment.
8. A strategic commodities licence is required for every shipment irrespective of direction; on indictment the penalty is an unlimited fine and 7 years.
9. A zero rate does not take goods out of the licensing regime: wine and beer remain dutiable.
10. ROCARS ceased operation on 1 May 2026, and the Trade and Industry Department’s e-Form service closed on 31 January 2024.
11. The Certificate of Non-Manipulation is issued by Customs, not by the Trade and Industry Department.
12. The “China” marking requirement for shipments to the United States applies despite the WTO panel ruling in Hong Kong’s favour.
13. Some particulars were confirmed (the strategic commodities order is L.N. 6 of 2025) and some were not: the permanent liquor duty instrument, the methyl alcohol exemption and the number of the 2018 amendment that capped the charge could not be confirmed from permitted sources and are not asserted here.
Hong Kong is a free port: no customs duty is levied on imports or exports, there is no VAT or sales tax, and there are no export duties. Duty is charged only on the four categories of dutiable commodities under the Dutiable Commodities Ordinance (Cap. 109) — liquor, tobacco other than smokeless tobacco and alternative smoking products, certain hydrocarbon oil and methyl alcohol — irrespective of the country of origin. The obligation to lodge an import or export declaration is imposed by the Import and Export (Registration) Regulations (Cap. 60E) and must be discharged within 14 days after the import or export; sixteen categories of article are exempt. The charge is 20 cents in respect of the first HK$46,000 of value and 12.5 cents for each additional HK$1,000 or part of it, subject to a maximum of HK$200 since 1 August 2018; food items attract a flat 20 cents. A Clothing Industry Training Levy of 30 cents per HK$1,000 of value is charged in addition on exports of Hong Kong-manufactured clothing and footwear and is not subject to that cap. Licensable goods are defined as “prohibited articles” under section 2 of the Import and Export Ordinance (Cap. 60), with the specific lists in Schedules 1 and 2 to the Import and Export (General) Regulations (Cap. 60A); penalties under sections 6C and 6D reach HK$2,000,000 and 7 years’ imprisonment. Strategic commodities are controlled by the Import and Export (Strategic Commodities) Regulations (Cap. 60G) and require a Trade and Industry Department licence for every shipment irrespective of direction. Rice is the only reserved commodity, under Cap. 296 and Cap. 296A. Since 1 May 2026 road cargo information is submitted through the Trade Single Window, which replaced ROCARS; the Import and Export (Amendment) Ordinance 2025 largely commenced on 11 July 2025 and provides for the Trade Single Window to replace GETS. The United States requirement to mark Hong Kong goods as originating in China continues to apply notwithstanding the WTO panel report in dispute DS597 of 21 December 2022 in Hong Kong’s favour, which remains unadopted following the United States’ appeal of 26 January 2023.
1. Import and Export Declaration — the obligation, deadlines, charges and industry levy — Customs and Excise Department
2. Types and Duty Rates — categories of dutiable commodities and the rates — Customs and Excise Department
3. About Licences — dutiable commodities licences and fees — Customs and Excise Department
4. User Guidebook for Dutiable Commodities, October 2024 edition — Customs and Excise Department
5. Controlled Imports — controlled goods, ordinances and authorities — Customs and Excise Department
6. Trade Single Window — integration of ROCARS from 1 May 2026 — Customs and Excise Department
7. The FTA Transhipment Facilitation Scheme and the Certificate of Non-Manipulation — Customs and Excise Department
8. “Forge advancement through connectivity and visionary innovation” — the 2025 year-end review, 12 February 2026 — Customs and Excise Department
9. Hong Kong Fact Sheet, September 2025 edition — Customs and Excise Department
10. Strategic Commodities Control List — Trade and Industry Department
11. Import and Export Licensing System for strategic commodities — Trade and Industry Department
12. Rice: import and export licensing requirements — Trade and Industry Department
13. Certificate of Hong Kong Origin and Certificate of Origin — Processing — Trade and Industry Department
14. The United States requirement on origin marking of Hong Kong products — Trade and Industry Department
15. DS597: United States — Origin Marking Requirement — World Trade Organization
16. Reduction of duty on liquor with alcoholic strength of more than 30 per cent, 16 October 2024 — Government of the HKSAR
17. LCQ5: Liquor duty, 23 July 2025 — Government of the HKSAR
18. LCQ16: Tobacco duty, 12 February 2025 — Government of the HKSAR
19. External merchandise trade statistics for December 2025 and the year as a whole, 27 January 2026 — Census and Statistics Department
20. External merchandise trade statistics for June 2026, 27 July 2026 — Census and Statistics Department
21. Transport and Logistics Bureau blog, 22 November 2025 — the methyl alcohol exemption — Transport and Logistics Bureau
22. The 2026-27 Budget — Government of the HKSAR
23. Trade Single Window portal — Government of the HKSAR
24. Controlled Exports — controlled export goods, ordinances and authorities — Customs and Excise Department
25. Hong Kong rises to the world’s fifth largest merchandise trading entity, 2 April 2026 — Government of the HKSAR
26. Notice on the lodgement of an import or export declaration — Census and Statistics Department
27. Schedule of fees, last revised 31 March 2026 — Trade and Industry Department
28. Charges and compoundable penalties at passenger clearance — Customs and Excise Department
29. Rice licence exemptions — Trade and Industry Department
30. Enforcement in respect of strategic commodities — Trade and Industry Department
31. Strategic Trade Controls Circular No. 5/2025 — the particulars of L.N. 6 of 2025 and its commencement — Trade and Industry Department
32. Form CED 429, “Confirmation of Receipt of Methyl Alcohol”, revision 12/2025 — Customs and Excise Department
The texts of Cap. 60, Cap. 60A, Cap. 60E, Cap. 60G, Cap. 109, Cap. 296 and Cap. 296A are published on the official Hong Kong e-Legislation portal (www.elegislation.gov.hk). The portal is closed to automated reading, so this article was prepared using the official texts of Cap. 60, Cap. 60A and Cap. 109 as notified by Hong Kong to the World Trade Organization, together with the current publications of the Customs and Excise Department and the Trade and Industry Department. Those are dated official texts rather than current consolidations, and the version should be checked on the portal before decisions are taken.
This material is provided for information purposes only and does not constitute legal, tax, financial, investment or consulting advice. Before taking any decision, individual professional advice should be obtained that takes account of the specific situation, jurisdiction, company status and the current requirements of the regulators.
Date of publication: September 2026.
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