( Main text and Annexes A, D to I updated on 30 April 2025 )
Strategic Trade Controls Circular No. 6/2009
Import and Export Control on
Non-fluorinated Polymeric Substances and Fibrous or Filamentary Materials
This circular reminds traders of the import and export control over non-fluorinated polymeric substances and fibrous or filamentary materials. It sets out the licensing requirements for the import and export of these products and supersedes the previous Strategic Trade Controls Circular No. 19/2004.
The Legal Basis
2. Under the Import and Export Ordinance ( Cap. 60, Laws of Hong Kong ) and its subsidiary legislation i.e. Import and Export ( Strategic Commodities ) Regulations ( Cap. 60G, Laws of Hong Kong ) ( "the Regulations" ), import or export of any article specified in the Schedules to the Regulations must be covered by valid licences issued by the Director-General of Trade and Industry. The products that are listed in Schedules 1, 2, 3 and 4 to the Regulations are regarded as strategic commodities and are subject to licensing requirements.
3. Non-fluorinated polymeric substances ( e.g. liquid crystal polymer or LCP ) and fibrous or filamentary materials ( e.g. carbon fibre prepregs ) are known to have wide industrial and military uses. For industrial applications, they are commonly used in the production of electronic and electrical parts, household electrical appliances, sporting goods and machine parts etc. Non-fluorinated polymeric substances may fall under Category 1C008, while fibrous or filamentary materials may fall under Category 1C010 under Schedule 1 to the Regulations, and are therefore subject to the import and export control under the Import and Export Ordinance. Detailed descriptions of non-fluorinated polymeric substances and fibrous or filamentary materials subject to control under the Regulations are set out at Annex A for reference. They can also be found at the Strategic Commodities Control System Website ( "SC Website" ) at https://www.stc.tid.gov.hk/english/checkprod/sc_control.html.
Licensing Procedures
( A ) Application Forms
4. Licence applications for the import and export of strategic commodities should be made on Import Licence ( Strategic Commodities ) Application Form [ TID 501 ] ( Annex B ) ( fillable pdf format ) or Export Licence ( Strategic Commodities ) Application Form [ TID 502 ] ( Annex C ) ( fillable pdf format ) respectively. These forms are available at the Integrated Customer Service Centre ( “ICSC” ) at Room 1324, 13/F, Trade and Industry Tower, 3 Concorde Road, Kowloon City, Hong Kong, or they can also be downloaded from the SC Website at https://www.stc.tid.gov.hk. Licence applications and supporting documents should be submitted to the ICSC. A numbered receipt will be issued for each licence application.
5. Import and export licence applications can also be made electronically. The E-Applications can be made through companies' E-Accounts on the SC Website ( Note 1 ) or through Trade Single Window ( TSW ) ( Note 2 ). The supporting documents can be uploaded and submitted together with the E-Application. Alternatively, they can be submitted by fax ( fax no. 2396 3070 ), by email ( email address: stc@tid.gov.hk ) or in person at the ICSC.
6. To submit E-Applications, companies are required to register an E-Account on the SC Website or become “Linked-up” TSW users.
( B ) Declaration and Supporting Documents
7. In addition to basic application particulars, the following information and documents are also required to support a licence application covering non-fluorinated polymeric substances and fibrous or filamentary materials:
- the name and full address of the ultimate consignee and end-user;
- the specific end-use of the goods concerned;
- supporting documents including -
- technical details/specifications and/or the completed questionnaire (Annex D (fillable pdf format) for non-fluorinated polymeric substances or Annex E (fillable pdf format) for fibrous or filamentary materials) of the product under application;
- an End-user Statement duly completed by the end-user (Annex F (fillable pdf format) for import licence application and Annex G (fillable pdf format) for export licence application). In case the submitted version is a softcopy, the original end-user statement should be provided to the applicant. The Trade and Industry Department and/or the Customs and Excise Department and/or other government departments will request the applicant to provide the original copy of the document, and / or contact the end-user for verification if necessary. Therefore, the applicant must keep the original copy of the document for checking;
- a copy of an export/re-export authorisation issued by the technology originating and/or exporting country/place of the goods giving explicit approval to the export/re-export concerned. If the licence/authorisation is issued in languages other than English or Chinese, the applicant should provide a translated version (either in English or Chinese); and/or
- a copy of the valid business registration certificate of the applicant and local end-user.
8. The Director-General of Trade and Industry at all times reserves the right to request additional information and further documentary proof to substantiate the licence applications. Applications that are not properly completed or not accompanied by all the necessary documentation will be deferred/rejected. Blank forms for Annexes B to G can be downloaded from the SC Website at https://www.stc.tid.gov.hk/english/download/by_formno.html.
Issuance of Licence
9. Under normal circumstances, licence applications duly completed and supported by the documents required will be processed within 2.5 clear working days after the date of receipt of the licence application.
- For paper application – Traders can collect the paper licence at the ICSC by presenting the receipt issued to them. Before collection, applicants are advised to check the application processing status on the SC website ( https://www.stc.tid.gov.hk/english/applytips/how_check.html ).
- For E-Application – Traders can:
- obtain and print out the licence (Note 3) online at TSW platform (exclusively provided to “linked-up” users); and/or
- collect the paper licence at the ICSC by presenting the receipt printed out from their E-Accounts.
10. For cases with complications or if additional document and/or information are necessary, longer time may be required to process the applications. Other government departments may also be consulted as and when necessary on a case-by-case basis. Applicants are advised to submit their applications well in advance of the shipments. Approved import and export licences are valid for six months and three months respectively.
Licence Conditions
11. On top of the standard licence conditions, the Director-General of Trade and Industry may, depending on the circumstances of individual cases, impose special and additional conditions on the approved licences. At the time of receiving the licences, applicants are advised to thoroughly read the section of “Conditions of Licence”, for the standard and special conditions being imposed on that licence.
12. For non-fluorinated polymeric substances and fibrous or filamentary materials, one special licence condition often imposed on import licences issued is "Any change of end-use or end-user, or further re-export, resale, transfer, or disposal of the goods requires prior notice to and approval from the Director-General of Trade and Industry". Licensees imposed with this condition should seek approval from the Director-General of Trade and Industry for any change in end-use or end-user and for resale/transfer/disposal of their products or lodge export licence applications for re-export. A designated form (SC047) (Annex H (fillable pdf format)) "Application for Resale/Transfer/Disposal of Products Under Approved Import Licence" may be used for cases of resale, transfer or disposal of the goods. Supporting documents such as the end-user statement completed by the proposed end-user, and valid export permit/authorisation issued by the technology originating and/or exporting country/place of the product giving approved to the proposed resale/transfer, must also be provided. Only after receipt of the Trade and Industry Department's approval should the licensee proceed with the re-export/resale/transfer/disposal of the goods or the change of end-use/end-user respectively. Otherwise, the licensee would have breached the above licence condition.
Pre-classification Service
13. For applicants who frequently import or export the same types of non-fluorinated polymeric substances and fibrous or filamentary materials, they are advised to make use of our pre-classification service. In brief, traders will be advised of the control status of a product through this service. Traders may download the pre-classification application form (SC013) (Annex I (fillable pdf format)) from the SC Website at https://www.stc.tid.gov.hk, and make application together with the technical specifications of the product concerned. After pre-classification, the Trade and Industry Department will assign a Pre-Classification Reference Number to the product concerned. By quoting this reference number on future licence applications covering the same goods, the requirement to provide the technical specification is waived. For details of the pre-classification procedures, please refer to Strategic Trade Controls Circular No. 11/2024 "Pre-classification Service on Strategic Commodities".
End-use Controls
14. In addition to the control imposed on specific items as set out in Schedules 1 and 2 to the Regulations, traders are reminded that end-use control are imposed under Schedules 3 and 4 to the Regulations. The Regulations impose licensing requirement on articles specified in Schedule 3 to the Regulations (Annex J) (pdf format), or any technological document containing information relating to any such article:
- if the importer/exporter knows that the article or document is intended or likely to be used in any activities related to nuclear, chemical or biological weapons or missiles capable of delivering them as specified in Schedule 4 to the Regulations (Annex K) (pdf format); or
- if the importer/exporter has grounds for suspecting that the article or document may be used in any activity specified in Schedule 4.
Reminder
15. Section 6A of the Import and Export Ordinance stipulates that no person shall import or export any article specified in the Schedules to the Regulations except under and in accordance with a licence issued by the Director-General of Trade and Industry. Any person who contravenes the provision commits an offence and is liable:
- on summary conviction to a fine of HK$500,000 and to imprisonment for two years; and
- on conviction on indictment to an unlimited fine and to imprisonment for seven years.
In addition to prosecution, the Trade and Industry Department may impose administrative actions against these persons. Such administrative actions may involve but shall not necessarily be confined to, suspension of a licence, refusal to issue a licence, debarment of all licensing facilities, etc.
Enquiry
16. If you have any enquiry concerning licensing requirements for non-fluorinated polymeric substances and fibrous or filamentary materials, please contact the Licensing Section of the Strategic Trade Controls Branch at 2398 5575. For specific technical questions or matters concerning classification of the goods and the pre-classification service, please call the Classification Section of the Strategic Trade Controls Branch at 2398 5587. Enquiry could also be sent by fax to 2396 3070 (Licensing Section) or 3525 1526 (Classification Section) or by email to stc@tid.gov.hk.
Strategic Trade Controls Branch
Trade and Industry Department
Note 1: |
Details of E-Accounts can be found on the SC Website: https://www.stc.tid.gov.hk/english/eaccount/how_open.html. |
Note 2: |
Details of TSW can be found in Strategic Trade Controls Circular No. 2/2024 < https://www.stc.tid.gov.hk/english/circular_pub/2024_stc02.html >. |
Note 3: |
For authenticity verification sake, a QR code is inserted at the lower right-hand corner of the approved document. By scanning the QR code, the departmental copy of the licences will be retrieved and shown. If any irregularity is found, traders should notify the Trade and Industry Department as soon as possible. |