Provisions under Waste Disposal Ordinance (WDO) relevant to Waste Disposal Licence and Waste Import / Export Permit for e-Waste

Waste Disposal Licence (WDL)

Disposal of all regulated e-waste (viz. air conditioners, refrigerators, washing machines, television sets, computers, printers, scanners and monitors) has been subject to the licensing control under s.16 and s.21 to s.23 of the WDO since 31 December 2018.  Any person who is engaged in the storage, treatment, reprocessing or recycling of regulated e-waste must first obtain a WDL, save for certain exclusions. Apart from other requirements, the waste disposal operation has to achieve all the limits, and requirements, and quality standards and quality objectives prescribed in the Air Pollution Control Ordinance, Water Pollution Control Ordinance, and Noise Control Ordinance. Its emission or discharge arising from the disposal operation would not be or would not be likely to be a danger to public health, a source of pollution to the environment or a source of nuisance to the neighbouring area. For EPD’s assessment, applicants need to specify his treatment processes involved (dismantling, shredding, means of material separation, etc.), and the recycling rate. These requirements are elaborated in EPD’s “Guidelines for Application of Waste Disposal Licence for E-waste” and “A Guide for Writing Operation Plan”, as well as the materials presented to the trade in 2017.

Please click here for details on e-WDL applications.


Import / Export Permit

The provisions on waste import and export permit control under s.20A to 20I of WDO, which are consistent with the Basel Convention, has also been extended to cover the import and export of regulated e-waste since 31 December 2018. The enhanced import control will guard against international dumping and prevent regulated e-waste intended for re-export ending up in Hong Kong.  The key criteria include managing the imported waste in Hong Kong in accordance with the laws of Hong Kong and in an environmentally sound manner. As a pre-requisite for granting an import permit, there shall be a licensed local recycler undertaking the proper treatment of the relevant import shipments. According to WDO, “waste is managed or disposed of in an environmentally sound manner if it is managed or disposed of in a manner which will, as far as is practicable, protect human health and the environment against any adverse effects which may result from such waste”.  These requirements are elaborated in “A Guide to the Control on Import and Export of Waste” and a Report of the Bills Committee in 2016.

Handling imported e-waste with relatively low technology operation (i.e. pre-processing and dismantling only) will not be regarded as proper treatment with respect to import operation as it would have limited environmental gains, but will still generate potential pollution nuisance and disposal burden to the local environment (e.g. with more overseas waste getting into the local landfills); therefore cannot be considered as being managed in an environmentally sound manner. Furthermore, transboundary waste movements should be minimized and e-waste undergoing low technology operation which could easily be conducted in the country or state of export, should not be imported into Hong Kong. On the other hand, import of e-waste for treatment in facilities licensed for more sophisticated process (i.e. e-waste treatment involving advanced resource recovery processes) and can achieve at least a recycling rate of 90% may be considered.  In any case, purposes for the import and detailed operation in handling the imported e-waste must be provided and fully justified by the applicant as required.

For export of e-waste, a permit will not be issued, unless among other things, the competent authority of the state of import and of each state of transit have consented to the import or transit of such e-waste. Moreover, the applicant should demonstrate that the e-waste requires treatment overseas through sophisticated processes not otherwise available in Hong Kong.

Please click here for details on Waste Import / Export Permit applications.

Typical e-waste treatment operations

  Low technology operation - pre-processing and dismantling More sophisticated process - advanced resource recovery processes
  • Sorting of e-waste into different types by nature, year, refrigerant involved

  • Dismantling of e-waste

  • De-wiring

  • Disassembling of different components from e-waste

  • Removal of hazardous components like batteries, PCBs for subsequent on-site or off-site treatment


  • Separation and recovery of non-metals, ferrous metals and non-ferrous metals by electromagnetic and eddy current, vibratory table, and density separator

  • Thermal separation processes for material recovery

  • Converting the recovered materials into raw materials