|  Updated August 2026  |  Supersedes: Hong Kong – New Dangerous Goods Regulations (29 April 2012)

Kwai Tsing Container Terminals, Hong Kong. Photo: Baycrest, Wikimedia Commons, licensed under CC BY-SA 2.5.

For anyone loading, discharging, transiting or transhipping DG through the Kwai Tsing container terminals, the mid-stream anchorages or the Western Dangerous Goods Anchorage, the rules are not simply “follow the IMDG Code.” Hong Kong layers its own ordinance, its own vessel classification, its own anchorages and its own permit system on top of the Code. This reference sets out that layered system as it actually operates today, with the primary legislation and Marine Department sources cited throughout.

1. The legal framework

The parent statute is the Dangerous Goods Ordinance (Cap. 295), first enacted in 1956 — well before any international harmonised system existed. What has changed since our 2012 post is that the ordinance’s subsidiary legislation has since been substantially rebuilt to align with the IMDG Code, and the rebuilt regime fully commenced on 31 March 2022 (L.N. 6 of 2022), repealing the older shipping regulations that were still in force when we last wrote about this.

2. Who regulates what

3. Vessel types under Cap. 295F — the key that unlocks the rest

Almost every operative rule in the Shipping Regulation is keyed to one of three vessel categories. Get this right first and the rest of the regulation reads logically.

Note the consequence for mid-stream operations: cargo that moves from an anchored OGV (Type 1) onto a barge (Type 3) for onward delivery is not a single continuous regulatory event — the barge leg is separately subject to the Type 3 conveyance-permit and notification regime described in Section 8.

4. Manifest and notification requirements (load, discharge, transit)

For Type 1 vessels — the category covering essentially all container and general cargo tonnage — Cap. 295F, Part 2 sets out the manifest chain:

Two points worth flagging to shippers and NVOCCs preparing shipping instructions for a Hong Kong call: first, false or misleading particulars in any manifest is a standalone offence, independent of any offence for late or missing submission — so a manifest correction after the fact does not retroactively cure the original filing. Second, the “in transit” wording is explicit in the Marine Department’s own guidance: a vessel that is not landing cargo in Hong Kong but is merely passing through, or transhipping, still triggers the 48-hour manifest obligation for whatever DG remains on board.

Underpinning all of this is the general duty in Cap. 413H: every shipowner, employer of persons aboard, and master must ensure — so far as reasonably practicable — that DG carriage, stowage, loading and unloading create no risk to health or safety, and that shipments are properly classified, packaged, marked, labelled and accompanied by a signed DG declaration. This duty sits underneath the Marine Department’s procedural requirements and applies to Hong Kong ships wherever they trade, and to all other ships while in Hong Kong waters.

5. Class-specific requirements

6. Container terminal handling in practice

Cap. 295F, Schedule 2 lists the approved container terminals at which freight containers carrying DG (other than Class 1) may lawfully be loaded or unloaded from a Type 1 vessel. The schedule still names some legacy corporate holders, but maps onto the nine berths now operated by five groups in Kwai Tsing:

Loading or unloading DG containers anywhere other than an approved terminal (or a place the Director specifically directs) is an offence attaching to the vessel’s master — so a booking that routes a DG box through an unlisted facility is not a paperwork issue, it is a compliance failure at the point of discharge.

Operationally, terminal and carrier practice in Kwai Tsing (consistent with Fire Services Department and Marine Department policy) runs along these lines:

• Class 1 (explosives): delivered by lighter alongside the ship — not brought through the normal container yard and gate process, consistent with the WDGA confinement rule above.
• Classes 2, 3 and 3A: generally must be delivered to, or collected from, the terminal within 72 hours.
• Class 2.1 (flammable gas): an appointment with the carrier’s customer service team is typically required one working day before container gate-in.
• Class 7 (radioactive): carrier practice at Hong Kong terminals (per published carrier operational-restriction notices) generally excludes radioactive cargo from routine terminal handling. That said, this appears to be operational/commercial practice rather than a blanket statutory prohibition, and low-activity excepted packages (UN 2908–2911) carry substantially lighter Class 7 obligations under the IMDG Code than a full Type A/B consignment — do not assume a categorical “no Class 7 at the terminal” rule without confirming the specific terminal’s and carrier’s current acceptance policy and the package category involved.
• Locally prohibited at the terminals: Arsine (UN 2188) may not be loaded, discharged or transited through Hong Kong; motor fuel anti-knock mixtures (UN 1649) may not be handled or stored at the terminals under any circumstances.

7. Transhipment and transit specifics

Roughly a quarter of Hong Kong’s container throughput now moves through mid-stream operations, the River Trade Terminal and other wharves rather than the nine Kwai Tsing berths — a meaningful share of it transhipment cargo for South China. “Transit” and “transhipment” are treated differently across Hong Kong’s legislation, and the distinction matters for which obligations actually bite:

The same transit/transhipment distinction resurfaces, with a different statutory definition, for precursor chemicals under Cap. 145 — see Section 11.2.

8. Local craft, mid-stream and lightering (Type 3 vessels)

Where transhipment or delivery is effected by barge or lighter rather than through a container terminal, the Type 3 vessel rules in Part 4 of Cap. 295F apply — a materially different regime from the Type 1 rules above.

9. Anchorages and movement restrictions

The Western Dangerous Goods Anchorage (WDGA), fixed in the Seventh Schedule to the Shipping and Port Control Regulations (Cap. 313A), is the reference point for Class 1 handling across all three vessel types. Type 2 vessels carrying Class 2, 3 or 3A DG in bulk are additionally excluded from a defined central-harbour zone (bounded to the east by a line on a bearing of 333° True from 22°17.665’N, 114°11.977’E, and to the west via Green Island to a point on Stonecutters Island at 22°19.052’N, 114°07.768’E, WGS 84).

Tropical cyclone provisions are consistent across Types 1, 2 and 3: once a Hong Kong Observatory signal higher than No. 3 is hoisted, a vessel carrying Class 1 DG (or, for Type 2/3, Class 2/3/3A bulk DG) already in the harbour must leave without delay — or, where permitted, proceed to and remain at WDGA (Class 1) or a non-WDGA DG anchorage / private typhoon mooring (bulk Class 2/3/3A) until the signal is cancelled.

10. Prohibited and restricted goods

Two separate prohibition layers apply in Hong Kong waters:

IMDG Code Special Provision 900

The following are prohibited for carriage under SP 900 (see also SP 349–353 for related restrictions): ammonium hypochlorite; ammonium nitrate liable to self-heating sufficient to initiate decomposition; ammonium nitrites and mixtures of an inorganic nitrite with an ammonium salt; chloric acid solution above 10%; pure ethyl nitrite; hydrocyanic acid solution above 20% HCN; refrigerated liquid hydrogen chloride; hydrogen cyanide solution in alcohol above 45%; pure mercury oxycyanide; methyl nitrite; perchloric acid above 72% by mass; dry or under-30%-water silver picrate; and zinc ammonium nitrite.

Locally prohibited goods (Cap. 295E, s. 7)

No person may manufacture, or have in possession, custody or control, any goods designated as prohibited goods under the local regulations, independent of their IMDG status.

Terminal-level prohibitions

Arsine (Class 2.3, UN 2188) may not be loaded, discharged or transited at Hong Kong under any circumstances. Motor fuel anti-knock mixtures (Class 6.1, UN 1649) may not be handled or stored at the terminals.

11. Controlled precursor chemicals, dangerous drugs and ozone-depleting substances — regimes shippers must screen for separately

Everything above sits under the Marine Department’s dangerous-goods framework. There are, in addition, several entirely separate control regimes — administered by Customs and Excise, the Trade and Industry Department and the Environmental Protection Department, not the Marine Department — that catch ordinary commercial cargo with no IMDG dangerous-goods character at all, or that layer a second approval on top of cargo that is already IMDG-classified. A shipment can be fully IMDG-compliant, correctly manifested under Cap. 295F, and still be an offence to move through Hong Kong without the relevant licence, because the substance itself is controlled as a narcotics precursor, a dangerous drug, or a scheduled ozone-depleting substance. This is frequently missed precisely because none of it is flagged anywhere in the DG declaration chain — it has to be screened separately, by chemical identity, against three ordinances.

11.1 Control of Chemicals Ordinance (Cap. 145) — the one that catches routine chemical cargo

Cap. 145 exists to stop industrial and pharmaceutical chemicals being diverted into illicit drug manufacture, implementing Hong Kong’s obligation under the 1988 UN Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances. It currently controls 54 substances (counting salts separately where relevant) across three schedules, and — critically for freight forwarders — it regulates transhipment as a distinct licensable event, not just import and export.

Note the overlap with ordinary DG cargo: acetic anhydride, potassium permanganate, hydrochloric acid, sulphuric acid, toluene and acetone are themselves routine IMDG-classified dangerous goods (Class 8, 5.1 or 3). A shipment of these can therefore trigger two independent compliance chains at once — Marine Department DG manifesting under Cap. 295F, and a Customs and Excise chemical licence or transhipment permit under Cap. 145 — run by different agencies, on different forms, with different lead times.

11.2 “In transit” vs “transhipment” — the distinction that decides whether a permit is triggered

Cap. 145 draws a sharp line between these two states, and it is this line — not the commercial label on the booking — that decides whether the removal permit below is required. Section 2(4) of the Ordinance defines a controlled chemical as being in transhipment only if it (a) is brought into Hong Kong for the sole purpose of being taken out again, and (b) is actually removed from the vessel, aircraft or vehicle it arrived on, pending onward carriage on a different one. Cargo that stays on board the same inbound conveyance throughout its time in Hong Kong waters — never discharged — sits instead in the lighter “in transit” category referenced in section 6 for Schedule 1 substances, consistent with how “transit” is defined elsewhere in Hong Kong’s dangerous goods legislation (goods that “remain at all times in or on the vessel… in which it is brought into Hong Kong”).

In practical terms: a Schedule 1 or 2 chemical staying aboard the same mother vessel as it calls Hong Kong before continuing to its next port is “in transit” and does not trigger the removal permit. The moment that same chemical is discharged at Kwai Tsing for reloading onto a different vessel — the ordinary meaning of “transhipment” in container shipping — it becomes “in transhipment” for Cap. 145 purposes, and section 7’s removal permit requirement applies before it can lawfully come off the inbound ship at all.

11.3 What Cap. 145 actually requires of a shipper or forwarder

Trade Single Window is an electronic lodgement channel that routes to the same CED Controlled Chemicals and Support Division for adjudication — it is not a separate approving authority, and paper application direct to CED remains available for every permit and licence type above.

11.4 Dangerous Drugs Ordinance (Cap. 134) — the drugs themselves, and legitimate pharmaceutical transit

Separately again, Cap. 134 controls the drugs themselves — not the precursors. Its First Schedule is a long and frequently amended list (it now runs to roughly 48 pages) covering opiates and opioids (opium, morphine, heroin, oxycodone, tramadol, tapentadol), synthetic opioids including fentanyl analogues and nitazenes, cannabis and cannabis-derived cannabinoids (including CBD, added 2023, and hexahydrocannabinol/HHC, added 2025), cocaine, amphetamine-type stimulants, ketamine, benzodiazepines, GHB, LSD, and a continuously growing list of novel psychoactive substances — new entries are gazetted several times a year (most recently, in July 2025, all etomidate analogues plus six further synthetic opioid and cannabinoid substances).

This mostly concerns licensed pharmaceutical shippers (e.g. medicinal morphine, codeine, or ketamine APIs) rather than general cargo, but three points matter for freight documentation specifically:

• Genuine transhipment is lawful only if properly papered (s.14): the consignment must be moving from a country that may lawfully export it to one that may lawfully import it, and — if exported from a state party to the relevant UN Conventions — must be accompanied by a valid export authorization or diversion certificate. Get either limb wrong and the importer is liable to a fine at level 6 plus up to 10 years’ imprisonment (indictable) even with no intent to traffic.
• Shipping documents must name the drug accurately (s.13(2)(aa)): for licensed exports, all commercial and shipping documents must show the drug name, quantity, and the exporter’s and importer’s name and address.
• Removing or diverting in-transit drugs from the carrying conveyance requires a separate Director’s licence (removal licence under s.15; diversion licence under s.16) — an ordinary transhipment move (off one ship, onto another) is not self-authorising just because the original export paperwork was in order.

11.5 Ozone Layer Protection Ordinance (Cap. 403) — refrigerant gases and other ozone-depleting substances

A third, unrelated regime worth flagging specifically for reefer and refrigerant-gas cargo. Cap. 403 gives effect to Hong Kong’s obligations under the 1985 Vienna Convention and the 1987 Montreal Protocol on substances that deplete the ozone layer. Its Schedule lists the controlled “scheduled substances”: CFCs, HCFCs, halons, methyl chloroform, methyl bromide, carbon tetrachloride, hydrobromofluorocarbons (HBFCs) and bromochloromethane (BCM). Manufacture of any scheduled substance in Hong Kong is prohibited outright (s.3); import or export without a licence is a standalone offence.

This is one of the more recent changes in the whole Hong Kong DG-adjacent landscape. Following Hong Kong’s acceptance of the Kigali Amendment to the Montreal Protocol, the Ordinance was amended in April 2025 to bring 18 regulated hydrofluorocarbons (HFCs) — the refrigerants that largely replaced CFCs and HCFCs, including common reefer-container gases — under the same scheduled-substance control, with the import/export licensing and quota system taking effect on 1 December 2025. Hong Kong’s phase-down target under Kigali is an 85% cut in HFC consumption from baseline by 2036, so the quota available for import will keep tightening. The same 2025 amendment also raised the penalty for unlicensed import or export of a scheduled substance to a fine of $1,000,000 and imprisonment for 2 years.

The overlap with ordinary DG cargo is direct here, not incidental: CFCs, HCFCs and halons are IMDG Class 2 gases, and methyl bromide and carbon tetrachloride are IMDG Class 6.1 toxic substances — so a refrigerant or fumigant shipment can trigger Marine Department DG manifesting under Cap. 295F and a separate EPD/TID ozone-layer licence at the same time, exactly the same pattern as the Cap. 145 precursor chemicals above.

12. Offences and penalties

Cap. 295F attaches criminal liability — typically to the vessel’s owner and/or master — to most of the procedural breaches described above. Fine levels follow the standard Hong Kong scale under the Criminal Procedure Ordinance (Cap. 221).

A statutory “due diligence” defence is available for several of these offences where the contravention occurred without the accused’s consent or connivance and all reasonable diligence was exercised. This is not a blanket defence — it must be proven, not assumed.

13. Fees at a glance

14. Practical checklist

These are two genuinely separate clearance chains, run by different agencies on different forms — treat them as two checklists, not one, so that a Marine Department DG sign-off is never mistaken for trade-control clearance or vice versa.

14.1 Marine Department / IMDG port-safety checklist (Cap. 295F, Cap. 413H)

• Confirm which vessel type applies to your movement (Type 1 for the main-line call; Type 3 for any barge/lighter leg) — the rulebook differs materially between them.
• Build the 48-hour manifest lead time into shipping instructions as a hard cutoff, not a target — this applies even where the vessel is only transiting or transhipping.
• For Class 1 cargo, confirm the WDGA routing and NEQ position against the 50,000 kg cap before committing space — this limit applies per vessel, so it caps what any single ship may carry at one time, not a combined total across every vessel in Hong Kong waters.
• For Class 7, confirm current terminal and carrier acceptance policy for the specific package category before booking — import/export movements need the TID licence, Radiation Board/Labour Department permit, and IMO DG Declaration/Packaging Certificate assembled before the cargo moves; in-transit material stays in its stowed position on board throughout.
• Check the current approved container terminal for the intended DG class and confirm the 72-hour dwell window for Classes 2/3/3A before nominating a gate-in date — remembering that “3A” is Hong Kong’s own diesel/fuel-oil category, not an IMDG class.
• Where a mid-stream/lightering leg is involved, confirm the Type 3 vessel holds a current Conveyance Permit, has filed the DGNS notification at least 24 hours ahead, and carries a certificated DG supervisor.
• Cross-check any borderline substance against IMDG SP 900, the local prohibited goods list, and Hong Kong’s own terminal-level prohibitions (Arsine, motor fuel anti-knock mixtures) — a substance can be IMDG-compliant and still be locally prohibited.

14.2 Customs and Excise / Trade and Industry / trade-control checklist (Cap. 60G, Cap. 145, Cap. 134, Cap. 403) — independent of DG classification

• Screen every Hong Kong routing (including pure transhipment) against the strategic commodities, chemical weapon precursor and controlled chemical lists — licence lead times run 7–15 working days and are not shortened by transhipment status.
• Screen the commodity by CAS number against the current, gazetted Cap. 145 precursor-chemical schedules and, for pharmaceutical cargo, the current Cap. 134 dangerous-drugs schedule — check elegislation.gov.hk at the time of booking rather than a saved list, since both are amended by gazette order through the year.
• For refrigerant, propellant, solvent or fumigant gas cargo, screen against the current Cap. 403 Schedule of ozone-depleting substances, including the 18 HFCs now controlled from 1 December 2025 — confirm the shipper/consignee holds current EPD registration and that any HCFC/HFC consignment has quota available, not just a valid licence.
• Establish whether the movement is genuinely “in transit” (stays on the same inbound conveyance throughout) or “in transhipment” (discharged for reloading onto another vessel) under Cap. 145 s.2(4) — only the latter triggers the CED removal permit requirement, and getting this wrong risks the container being unable to lawfully leave the inbound vessel.
• For Schedule 1 or 2 chemicals moving as transhipment, apply for the CED Permit to Remove Controlled Chemicals in Transhipment (Form CED 347 or Trade Single Window) with enough lead time before the vessel’s arrival — this is a Customs and Excise approval, entirely separate from anything filed with the Marine Department, and a compliant DG manifest under Cap. 295F is not a substitute for it.
• For genuine Cap. 134 pharmaceutical transhipments, confirm the export authorization/diversion certificate accompanying the consignment is valid, and apply for the Director of Health’s removal or diversion licence before attempting to move the cargo off the inbound conveyance.
• For genuine Cap. 403 ozone-depleting-substance transhipments via a through bill of lading, apply for the combined Import and Export Licence for transhipment rather than assuming ordinary import/export licensing covers the movement.

15. Contacts