Frequently Asked Questions

Q1: How does a supplier register as a registered supplier?

A supplier needs to apply to be a registered supplier to the Environmental Protection Department. The application is free of charge. There are two types of registered suppliers, namely an ordinary registered supplier and a short-term registered supplier. Please click here for the application methods.

Q2: What is a short-term registered supplier?

Suppliers who only operate business of distributing regulated electrical equipment in Hong Kong for not more than 30 days and pay a recycling levy not exceeding $20,000 can register as a short-term registered supplier Note with the Environmental Protection Department.  However, if the same short-term registered supplier has one or more than one recent short-term registration approved, the total amount of recycling levy to be paid should not exceed $20,000 either when he/she applies to be a short-term registered supplier again.

Note:A short-term registration is a recent short-term registration if its ending date or cancellation date falls within 12 months before the date of the application for the intended short-term registration.

Q3: When must a supplier submit returns to the Environmental Protection Department (EPD)? What returns are to be submitted?

A registered supplier must periodically submit returns to EPD. The reporting period is within 28 days after the last day of each quarter (i.e. 31 March, 30 June, 30 September and 31 December). The returns must set out the information that is necessary for the computation of the recycling fees payable. This includes the quantity of REE distributed by the supplier in the quarter, the quantity of REE which are used by the supplier for the first time, and the use of recycling labels (e.g. the number of labels obtained from EPD, the number of labels distributed, the number of labels cancelled and the remaining stock quantity of labels).

Registered suppliers who have completed the registration at the Regulated Electrical Equipment Information Management System (REEIMS) can submit direct the returns through REEIMS.

Q4: How does a supplier obtain the recycling labels?

The supplier will apply to the Environmental Protection Department (EPD) with the specified form (REE-4) to obtain free recycling labels first, and then provide EPD with the quantity of regulated electrical equipment distributed as set out in the returns to facilitate the setting and charging of the recycling levy.

Registered suppliers who have completed the registration at the Regulated Electrical Equipment Information Management System (REEIMS) can apply direct through REEIMS to obtain recycling labels.

Q5: I sell regulated electrical equipment (REE) on the internet; am I qualified as a "supplier"?

Any person who in the course of his/her business, imports and distributes regulated electrical equipment in Hong Kong, no matter through shops, internet, telephone, etc. is regarded as a supplier. In addition, if the distribution target is consumer, the person is also regarded as a "seller" at the same time. For details of the statutory obligation of a "seller", please click here.

Q6: Are suppliers required to pay recycling levy for regulated electrical equipment (REE) that has been re-exported?

Suppliers are required by law to pay a recycling levy for the REE that they distribute or use for the first time, excluding REE exported out of Hong Kong. Therefore, REE imported for re-export or REE manufactured locally for export is not subject to recycling levy, and registered suppliers need not include such REE imported for re-export or manufactured locally for export when submitting returns to the Environmental Protection Department.

Q7: If a supplier distributing regulated electrical equipment (REE) to a wholesaler has paid the relevant recycling levy to the Government, and the wholesaler subsequently exports the equipment out of Hong Kong, can the paid levy be refunded?

Suppliers are required by law to pay a recycling levy for the REE they distribute or use for the first time, excluding REE exported out of Hong Kong. If the supplier concerned is satisfied that the wholesaler has exported the equipment out of Hong Kong (e.g. the wholesaler has provided relevant cargo documents), the supplier may submit an application to the Environmental Protection Department for refund of the paid levy and provide relevant documentary evidence for review. Relevant arrangements between the supplier and the wholesaler should be handled between themselves.

Q8: Can the recycling levy be listed on the receipts and collected from consumers?

Under the Producer Responsibility Scheme on Waste Electrical and Electronic Equipment, suppliers of regulated electrical equipment are required by law to pay a recycling levy to the Government.  In addition, it is a statutory requirement that the receipts issued to consumers by the sellers must contain the prescribed wording.

However, the law does not regulate how the suppliers may recover all or part of the recycling levy from other stakeholders through the supply chain, which should be determined by the relevant stakeholders according to the operation of the free market.  As for how the price should be presented, such as whether all or part of the recycling levy should be separately listed on the invoice or receipt, or whether to show as a single price, the trade may decide themselves.

Q9: Are local online shopping, cross-boundary online shopping for local use and sale outside the territory with equipment collected in Hong Kong regulated under the Producer Responsibility Scheme on waste electrical and electronic equipment?

Suppliers are required by law to pay a recycling levy fore regulated electrical equipment (REE) they distribute or use for the first time, while sellers should arrange a free statutory removal service for the distributed REE and provide a recycling label and a receipt with prescribed wording for the consumers. Irrespective of whether the suppliers and sellers distribute REE in Hong Kong through physical stores or online sales platforms, they are subject to statutory regulation.

As for the so-called "sale outside the territory with equipment collected in Hong Kong", it is understood that this involves distribution of REE in local market by the supplier, so the supplier should pay the corresponding recycling levy.

Q10: Are suppliers required to pay a levy for regulated electrical equipment (REE) used as an exhibit?

Suppliers are required to pay a recycling levy for REE they distribute or use for the first time, and the definition of "use" includes "exhibit the equipment for business purposes". The supplier should pay a recycling levy for such REE.

Q11: Are suppliers required to pay a levy for regulated electrical equipment (REE) used for charitable donation?

Suppliers are required to pay a recycling levy for the REE they distribute or use for the first time, and the definition of "use" includes "give the equipment to another person as a prize or gift".  Therefore, suppliers are required to pay a recycling levy for the REE used for charitable donation.

Q12: In "works contracts" or supply contracts for enterprises, suppliers of regulated electrical equipment (REE) have signed the relevant sales/supply contracts with customers before 1 August 2018, whilst the actual delivery will take place after 1 August 2018. Is recycling levy payable for such equipment? What if the documents signed are "letters of intent"?

According to the understanding of the Environmental Protection Department (EPD), in the relevant business operation, it is the trade's usual practice to sign a "sales/supply contract" for REE whereas the delivery of equipment will take place after some reasonable time.  Insofar as these cases are concerned, if the relevant contracts have been duly signed prior to the implementation of the Producer Responsibility Scheme on waste electrical and electronic equipment (WPRS), and only involves delivery of the equipment in accordance with the contract after the implementation of the WPRS, we are of the view that recycling levy is generally not payable in respect of such equipment.

"Letter of intent" is generally not binding to the signatories, hence we would not consider that recycling levy is not payable solely on the fact that a letter of intent was signed prior to the implementation of the WPRS.

Q13: If the regulated electrical equipment (REE) distributed by a supplier is later returned to the supplier, will there be a refund of the recycling levy paid?

As the situations involving return of goods, we cannot make a generalization, and the circumstances of individual cases should be looked into. However, according to the requirements of the legislation, payment of recycling levy is required only once for any REE distributed in Hong Kong.

Example:

Reasons for return of goods Are submission of return and payment of levy required?
The goods are not damaged and have not been used by the consumer but are returned because they are not suitable (e.g. the size of the equipment distributed does not meet the requirements) As the equipment has not been used by the consumer, if it is returned to the supplier, it would not be regarded as “distributed” and so payment of levy is not required. However, if the supplier re-distributes the equipment to other customers later, payment of levy is required
The goods have been distributed to the consumer for use but are returned due to damage The electrical equipment has been "distributed" and used by the consumer, so payment of levy is required despite return
Equipment  distributed to the consumer for use but returned due to damage, and is re-distributed after repair A levy has been paid for the equipment. "Overhauled/refurbished equipment" are not REE in nature, so payment of levy is not required during re-distribution