VOC Compliance in Hong Kong: How Global Standards Shape Local Actions

Background

Hong Kong’s Environmental Protection Department (EPD) first introduced the Air Pollution Control (Volatile Organic Compounds) Regulation in 2007, covering products such as architectural paints, printing inks, adhesives, sealants, and consumer products like air fresheners and hairsprays.  Updates in 2009 and 2017 expanded the scope to vehicle coatings, marine paints, fountain solutions, and cleaning agents.

Recent Developments

In October 2025, the EPD issued updated guidance to ensure compliance across different products and industries. Enforcement remains active, with routine prosecutions under the Air Pollution Control Ordinance, including a June 2024 conviction for importing a regulated consumer product exceeding such limits, resulting in an HKD $8,000 fine.

How is Hong Kong refining its Regulatory Framework?

Hong Kong’s VOC regulations have evolved significantly following reviews of requirements set by other major international markets.

1. Benchmarking Against California & SCAQMD Standards:
   • Hong Kong referenced California Air Resources Board (CARB) and South Coast Air Quality Management District (SCAQMD) standards when setting VOC limits for architectural paints. These benchmarks are among the strictest globally, and Hong Kong aligned its proposed limits with these standards to ensure global competitiveness and environmental integrity
2. U.S. Consumer Product Controls Inform Expansion
   • Hong Kong’s decision to regulate cleaning products was influenced by California’s Consumer Products Regulation. Studies showed that adopting similar standards could reduce VOC emissions from cleaning products by up to 80%, prompting the EPD to expand its regulatory scope in late 2023
3.  EU Paints Directive as a Structural Model
   • Hong Kong’s phased approach to VOC regulation mirrors the EU’s Directive 2004/42/EC (Decopaint Directive). This includes category-based VOC limits, mandatory notifications, and labeling requirements, ensuring consistency with international best practices
4. Alignment with Clean Air Plan 2035 and Global Best Practices
   • The Clean Air Plan 2035 emphasizes progressive VOC control measures inspired by global standards. Hong Kong integrates the polluter-pays principle and phased implementation strategies similar to those in the EU and US frameworks

What This Means for Consumers & Businesses in Hong Kong

1. For Consumers:
   • Health & Safety: Lower VOC levels mean cleaner indoor air and reduced risk of respiratory issues
   • Smart Shopping: Look for EPD-compliant labels and avoid products with strong chemical odors
   • Eco-Conscious Choices: Supporting low-VOC products helps Hong Kong meet its Clean Air Plan 2035 goals
2. For Businesses:
   • Compliance Is Non-Negotiable: Product-level infringements can lead to fines and legal exposure
   • Brand Advantage: Marketing low-VOC products can differentiate your brand in a health-conscious market
   • Supply Chain Review: Audit suppliers and formulations now—especially for paints, adhesives, and cleaning products
   • Future-Proofing: VOC limits are expanding. Prepare for stricter standards and possible inclusion of more product categories.

How to stay compliant?

At SGS, our experts can provide assistance on volatile organic compounds (VOC) testing for emissions, aromatic compounds, and aromatic hydrocarbons in products.   More details on such services are available here.

Please subscribe and contact us at TIC Mall for more details.

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