Exporting Cosmetics to Hong Kong: Safety Rules, Labels and Re-export

No registration, but a general safety requirement

Hong Kong has no law written only for cosmetics. Ordinary cosmetics need no registration, notification, import licence or local responsible person before sale. They are consumer goods under the Consumer Goods Safety Ordinance (Cap. 456), which makes it an offence to manufacture, import or supply consumer goods in Hong Kong unless they meet the general safety requirement: the goods must be reasonably safe. The duty falls on manufacturers, importers and suppliers, so your Hong Kong buyer carries legal risk and will ask you for evidence.

Whether goods are reasonably safe depends on all the circumstances, including how they are presented and marketed, the instructions and warnings given, reasonable safety standards published by a standards institute, and whether there was a reasonable way to make them safer. There is no approved Hong Kong standard for cosmetics, so C&ED considers relevant standards, including those published by the European Union, the United States and the mainland, and buys products from the market for testing.

C&ED can serve notices requiring a supplier to publish a warning, to stop supplying the goods (a prohibition notice) or to withdraw them at once (a recall notice). An offence carries a fine of up to HK$100,000 and one year's imprisonment on first conviction, and HK$500,000 and two years on a later conviction. Pharmaceutical products, poisons, Chinese medicines, and toys and children's products are excluded from the ordinance because other laws cover them.

Labels: which text must be in English and Chinese

The Consumer Goods Safety Regulation (Cap. 456A) has one language rule: any warning or caution about the safe keeping, use, consumption or disposal of the goods must be in both English and Chinese, legible and in a conspicuous position on the goods, their package, a label securely fixed to the package or a document enclosed in it. If your pack has warnings only in another language, such as Korean or Japanese, add English and Chinese versions. The regulation does not name a script; Hong Kong normally uses traditional Chinese characters.

Hong Kong law does not prescribe other label content for ordinary cosmetics, such as a full ingredient list, an importer address or a country of origin. Many products carry them anyway: C&ED judges safety against EU, US and mainland standards, which require warnings for certain ingredients, and anything you do print, including quantity, composition, functions and place of manufacture, must be accurate under the Trade Descriptions Ordinance. Importers and retailers may ask for more, so agree the label with them.

Hair dyes containing phenylenediamines, toluenediamines or other alkylated benzenediamines, or their salts, are Part 2 poisons under the Pharmacy and Poisons Ordinance (Cap. 138). They may be sold only at the registered premises of Authorized Sellers of Poisons (pharmacies) or Listed Sellers of Poisons, and the container must show the name of the poison, its proportion and this caution: "Caution. This preparation may cause serious inflammation of the skin in certain persons and should be used only in accordance with expert advice."

Drug ingredients, medicinal claims and mercury

A product is a pharmaceutical product under Cap. 138 if it is presented as treating or preventing disease, or is used to restore, correct or modify physiological functions by a pharmacological, immunological or metabolic action. Pharmaceutical products must be registered with the Pharmacy and Poisons Board before they are sold, offered for sale or distributed, and carry a registration number in the form HK-XXXXX. Importing them needs a licence from the Department of Health, and traders need a wholesale dealer licence.

The Board's classification guidance (April 2026) says cosmetics, skin care, sunscreens, toothpastes, deodorants and antiperspirants, hair colourants and styling products are unlikely to be pharmaceutical products unless they contain medicinal ingredients, such as antibiotics, coal tar or substances on the Poisons List, or make medicinal claims. "Prevents acne" or "cures athlete's foot" are medicinal claims; "cleanses acne-prone skin", "skin whitening", "fades dark pigmented areas" and anti-dandruff without medicinal actives are not. Proprietary Chinese medicines are regulated under the Chinese Medicine Ordinance (Cap. 549) instead.

The Mercury Control Ordinance (Cap. 640) has banned the manufacture, import and export of cosmetics with more than 1 ppm of mercury since 1 December 2021, and their supply since 1 December 2024. Since 27 March 2026 the ban covers cosmetics with any intentionally added mercury. Only unintentional traces up to 1 ppm, and eye-area products that use mercury as a preservative, up to 70 ppm, where no effective and safe substitute exists, are allowed. Stock of the newly covered products may be supplied until 31 January 2029.

Claims: Trade Descriptions and Undesirable Medical Advertisements

The Trade Descriptions Ordinance (Cap. 362), enforced by C&ED, makes it an offence to apply a false trade description to goods or to supply goods that carry one. Trade descriptions include quantity, composition, fitness for purpose and performance, tests and approvals, the place of manufacture and the manufacturer. Since 19 July 2013 the ordinance also bans unfair trade practices: misleading omissions, aggressive practices, bait advertising, bait and switch, and wrongly accepting payment. The maximum penalty is a fine of HK$500,000 and five years' imprisonment. A government consultation on amendments opened in June 2026, but it concerns prepaid beauty and fitness services, not the sale of cosmetics.

The Undesirable Medical Advertisements Ordinance (Cap. 231), enforced by the Department of Health, bans advertisements likely to lead to the use of a medicine, surgical appliance or treatment for the diseases and conditions in Schedule 1, beyond the limited uses it permits, or for the purposes in Schedule 2. Schedule 1 includes skin conditions, so advertising a cosmetic as a treatment for a skin, hair or scalp disease can breach it. Penalties reach a fine of HK$50,000 and six months' imprisonment on first conviction, and HK$100,000 and one year on a later conviction.

Customs: free port and 14-day declarations (TDEC)

Hong Kong is a free port. It levies no customs tariff and no VAT, and excise duty applies only to liquor, tobacco, hydrocarbon oil and methyl alcohol, so cosmetics pay no duty or tax at import. Cosmetics fall mainly under HS headings 3303 to 3307 and are declared under 8-digit Hong Kong Harmonized System (HKHS) codes.

Under the Import and Export (Registration) Regulations (Cap. 60E), anyone who imports or exports goods lodges an accurate and complete import or export declaration (TDEC) within 14 days after the goods arrive or leave. It is lodged electronically through one of three Government Electronic Trading Services (GETS) providers: Brio Electronic Commerce, Global e-Trading Services or Tradelink. The charge is HK$0.20 to HK$200 per declaration. Late lodgement adds HK$20 to HK$200, depending on value and delay, and late or inaccurate declarations can be prosecuted. Transhipment cargo on a through bill of lading or air waybill, and postal packets worth less than HK$4,000, are exempt.

The Trade Single Window (TSW) is taking over these systems. It replaced the Road Cargo System (ROCARS) for advance road cargo information on 1 May 2026, and import and export declarations are planned to move to it in later batches in 2027. Keep product names, HS codes, quantities and values identical on the invoice, packing list and declaration; Triplicate's free generator makes the commercial invoice and packing list, and its HS code lookup is a quick first check.

Re-export to the mainland, and origin

Goods imported into Hong Kong and sent on need both an import and a re-export declaration. Clearing Hong Kong does not open the mainland market: cosmetics sold there through ordinary trade still need NMPA filing or registration through a domestic responsible person, Chinese labels and mainland customs inspection. Products whose last process touching the contents takes place in Hong Kong are managed as imported products (Measures for the Administration of Cosmetics Registration and Filing, Article 61). Cross-border e-commerce retail imports follow separate rules; see Triplicate's China cosmetics note.

If the mainland importer claims a preferential rate under an agreement such as RCEP or the China–Korea FTA, it must show the goods were not further processed in Hong Kong. C&ED says a single through bill of lading is enough, and containerised cargo with an unchanged seal needs no certificate; otherwise get a Certificate of Non-manipulation from C&ED, or from China Inspection Co. Ltd. where it inspects the goods. Zero tariff under CEPA is only for goods of Hong Kong origin shipped with a CO(CEPA), made in a factory registered with the Trade and Industry Department.

Hong Kong origin needs a manufacturing process in Hong Kong that changes permanently and substantially the shape, nature, form or utility of the materials; simple diluting, packing, bottling, sorting or decorating does not count. Do not mark refilled or relabelled goods "Made in Hong Kong": a false place of manufacture is an offence under the Trade Descriptions Ordinance. For goods made elsewhere, government-approved organisations such as the Hong Kong General Chamber of Commerce issue re-export certificates of origin showing the real origin. Goods made in Hong Kong and sent to the US must be marked "China" (see Triplicate's country of origin marking note).