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 focuses his practice on Hong Kong and Asian regional tax advisory work, tax and estate planning — especially for high-net worth individuals — and tax litigation. Steven frequently represents clients in tax disputes with the Inland Revenue Department in Hong Kong.