Frequently Asked Questions
Main Content
V. Dangerous Goods in
Consumer Packs
The DGO regulates a great variety of DG of different properties and hazards. Some of them have been widely used by the public as consumer goods in their daily lives (such as disinfectant alcohol, bleach and perfume), and in different industries. Therefore, the Authority has introduced a set of regulations specific to DG in consumer packs (“DGCP”), which will address the needs of the general public and the trades without compromising fire safety, and is different from those for general DG -- As long as the size of the package does not exceed the "maximum package size”, the DG concerned will be classified as DGCP, which can then be exempted not only from the requirements in relation to packing, marking and labelling, but also those of licence for conveyance. For instance, for an uninhabited compartment, the maximum exempt quantity is 1 000 litre / kilogram; while for a warehouse of industrial premises, the maximum exempt quantity is 5 000 litre / kilogram.
Schedule 2 of the Dangerous Goods (Application and Exemption) Regulation 2012 (Cap. 295E) has set out the dangerous goods ("DG') that are entitled to maximum package size - if the package size of the DG does not exceed the specified maximum package size (for instance, alcohol-based handrub solution for daily use), the DG will be classified as DGCP.
Consumer pack exempt quantity is not applicable to habited places. Thus compliance with general exempt quantity regulation is required for the DG used at home. That said, as the necessary quantity used by household in general does not exceed the exempt quantity, licence for storage of DG is usually not required. Nonetheless, it is not encouraged to store DG in a large amount at home for the sake of public safety.
Regarding the licence for storage, DGCP are entitled to “consumer pack exempt quantity”, which maximum volume allowed is higher than the general exempt quantity. For instance, for an uninhabited compartment, the maximum exempt quantity is 1 000 litre / kilogram; while for a warehouse of industrial premises, the maximum exempt quantity is 5 000 litre / kilogram.
DGCP can be exempted from packing, marking and labelling requirements as well as licensing requirements for conveyance under DGO. However, these DG are still regulated by other ordinances. For instance, related ordinances are in place to regulate insecticides or general consumer goods.
Common DGCP |
EQ under old legislation (L) |
EQ under amended legislation (Non-DGCP) |
EQ of DGCP (new) |
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General EQ (L) |
Industrial EQ (L) |
Maximum Package Size (L) |
General EQ (L) |
Warehouse EQ (L) |
||
Alcohol-based handrub solution |
20 |
25 |
150 |
1 |
Packing Group II: 300
Packing Group III: 1 000 |
Packing Group II: 1 500
Packing Group III: 5 000 |
Perfume/ essential oil |
20 |
25 |
150 |
|||
Paint |
250 |
250 |
250 |
|||
Bleach |
250 |
250 |
250 |
Packing Group II: 1 Packing Group III: 5 |
1 000 |
5 000 |
Remark: Packing Group I DG are not classified as DGCP
In order to strike a balance between public safety and trade facilitation, the authorities, upon due risk assessment and consultation, have come to a consensus that DGCP, as consumer goods, pose lower potential risk than general DG. As such, packing, marking and labelling of DG, as long as the size of their packages does not exceed the specified Maximum Package Size, would not be subject to the governance of DGO, though some of their components are DG and are otherwise regulated by DGO.
In general, the safety of consumer goods sold in Hong Kong for private use or consumption is regulated under the Consumer Goods Safety Ordinance (Cap. 456) and its subsidiary Consumer Goods Safety Regulation (Cap. 456A). However, goods specified in the Schedule of Cap. 456 and any other goods which safety is controlled by specific legislation are not subject to the regulation of Cap. 456.
According to the Consumer Goods Safety Ordinance, general consumer goods supplied in Hong Kong shall meet the “general safety requirements”. Therefore, if the DGCP fall into the definition of consumer goods in the Ordinance, it is the responsibility of their manufacturers, importers and suppliers to ensure that they are adequately safe, having regard to the following circumstances:
(a) the manner and purpose the consumer goods are sold;
(b) the use of any marks in relation to the consumer goods, as well as instructions or warnings given for the keeping, use or consumption of the goods;
(c) compliance with the reasonable safety standards published by a standards institute for the consumer goods; and
(d) the availability of any reasonable means to make the consumer goods safer.
Furthermore, the Consumer Goods Safety Regulation provides that where consumer goods or their packages are marked with warnings or cautions with respect to their safe keeping, use, consumption or disposal, such warnings or cautions shall be in both English and Chinese, and the expressions shall be legible and placed in conspicuous positions on the consumer goods or packages.
No, it depends on the kinds and natures of substances contained in the aerosols. For instance, aerosols with liquefied petroleum gas as propellants are not subject to the control of the DGO.
The regulation of DGCP is formulated through a balancing mechanism between public safety and necessary social needs, and is achieved through due risk assessments, referencing to the legislations, consultations of professional opinions from the government laboratory and discussion with different stakeholders. In general, except bleach in packing group III which has a maximum package size of 5L, other DGCP have the maximum package size of 1L. On the other hand, paint as non-DGCP has an exempt quantity of 250L.