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Hong Kong controls dual-use items under the Import and Export Ordinance (Cap. 60) and its corresponding subsidiary legislation, the Import and Export (Strategic Commodities) Regulations (Cap. 60G) (“IESCR”). On 17 September 2021, an order to amend the list of strategic commodities under relevant schedules to the IESCR came into effect.

The amendments aim to align Hong Kong’s control list with international non-proliferation regimes, including the Wassenaar Arrangement. The Trade and Industry Department has provided guidance on these amendments under Strategic Trade Controls Circular No. 8/2021, which also contains three updated lists of “Commonly Not-Controlled Items”. The lists include “Integrated Circuits, Electronic Components and Equipment”, “Computers, Computer Related Equipment and Software” and “Telecommunications Equipment, Computer Networking Equipment and Related Accessories” that are commonly not subject to control.

In response to these amendments, businesses should understand whether any technologies or items in their inventory are newly controlled or de-controlled by the amended control list and thresholds. Should there be changes, businesses should ensure that their inventory management systems are updated correspondingly.


Steven Sieker practices exclusively in the area of tax law, and is recognized as a leading individual in tax as well as private client and wealth management by Chambers Asia Pacific, Citywealth Leaders List and Guide to the World’s leading Tax Advisers. He has authored a wide range of key articles and publications, including the Hong Kong volume of the CCH series Tax Planning and Compliance in Asia. He is a member of the Society of Trust and Estate Practitioners (STEP), and was an executive director of STEP and the Canadian Chamber of Commerce in Hong Kong. Steven is admitted as a solicitor in Hong Kong, England and Wales (non-practising), and is qualified as a barrister and solicitor in Alberta, Canada.


Weng Keong Kok is an associate in Baker McKenzie Hong Kong office.

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