Hong Kong Announces Effective Dates for Ban on 8 New Categories of Mercury-Added Products Under Minamata Convention COP5 
On March 26, 2026, the Hong Kong Government published the Mercury Control Ordinance (Amendment of Schedule 3) Order 2025 (Commencement) Notice. This notice establishes the commencement dates for the regulation of eight categories of mercury-added products recently added to the scope following the COP5 amendments to the Minamata Convention.
The effective dates are staggered: March 27, 2026, for button cells, switches/relays, and cosmetics; December 31, 2027, for fluorescent lamps using triband phosphors; and December 31, 2026, for the remaining product categories. After these dates, the manufacture, import, and export of these products in Hong Kong will be prohibited. However, to allow for the depletion of existing stocks, a grace period for the supply (sale) of these products has been granted until January 31, 2029.
Overview of the Mercury Control Ordinance
Enacted on June 30, 2021, to implement the Minamata Convention, this Ordinance regulates the export, import, keeping, and use of mercury, mercury mixtures, and mercury compounds. It also prohibits the manufacture, export, import, and supply of specific mercury-added products.
- Schedule 1: Lists regulated mercury, mixtures, and compounds.
- Schedule 3: Lists prohibited mercury-added products.
Commencement Dates for Newly Regulated Products
The details for the eight newly added categories and their respective effective dates are as follows:
| Regulated Product Category | Effective Date |
|---|---|
| Button zinc silver oxide batteries and button zinc air batteries with a mercury content < 2 wt%. | March 27, 2026 |
| • High-accuracy capacitors and loss measurement bridges (mercury content ≤ 20 mg).
• High-frequency radio frequency switches and relays in monitoring and control instruments (mercury content ≤ 20 mg). (Excluding those used for research and development purposes). |
|
| Cosmetics (e.g., skin lightening soaps and creams), excluding:
1. Those with unintentional trace amounts (< 1 ppm). 2. Eye-area cosmetics with mercury as a preservative, where no safe alternative exists and content is ≤ 70 ppm. |
|
| Compact fluorescent lamps (CFLs) for general lighting purposes > 30 W. | December 31, 2026 |
| Non-integrated CFLs for general lighting purposes ≤ 30 W with mercury content ≤ 5 mg per burner. | |
| Linear fluorescent lamps (LFLs) for general lighting purposes:
• Using halophosphate phosphors, ≤ 40 W with mercury content ≤ 10 mg. • Using halophosphate phosphors, > 40 W. |
|
| Non-linear fluorescent lamps (NFLs) (e.g., U-shaped, circular) using halophosphate phosphors. | |
| Non-linear fluorescent lamps (NFLs) (e.g., U-shaped, circular) using triband phosphors. | December 31, 2027 |
| Linear fluorescent lamps (LFLs) for general lighting purposes using triband phosphors:
• < 60 W with mercury content ≤ 5 mg. • ≥ 60 W with mercury content ≤ 5 mg. • ≥ 60 W with mercury content > 5 mg. |
Enforcement and Penalties
From the specified commencement dates, any person who manufactures, imports, or exports the regulated products commits an offense. Upon conviction, offenders may face a maximum fine of HK$50,000 and imprisonment for one year.
Note on “Supply”:
Recognizing the need for market transition, the “supply” (including selling or offering for sale) of these products is permitted until January 31, 2029. This means that while new stock cannot be manufactured or brought into Hong Kong after the effective dates, existing stock already in the territory can be legally sold for nearly three more years.
Original Texts (Traditional Chinese):
- Government Press Release:
https://www.info.gov.hk/gia/general/202603/26/P2026032600294.htm - Legislative Council Brief (Commencement Notice):
https://www.legco.gov.hk/yr2026/chinese/brief/eeb202603_20260327-c.pdf - Mercury Control Ordinance (Cap. 640):
https://www.elegislation.gov.hk/hk/cap640!zh-Hant-HK?INDEX_CS=N
