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ESG Guides › Circular Economy & Product Responsibility

Materials, waste, packaging and end-of-life responsibility

Circular Economy & Product Responsibility Guide

Turn waste data into decisions about material use, product design, procurement, recovery and customer responsibility.


How to use this guide

This page explains a proportionate management approach for Hong Kong organisations. It is general information, not a substitute for legal, engineering, labour or other specialist advice where those disciplines are required.

Why this matters in Hong Kong

Hong Kong’s Waste Blueprint for 2035 is organised around “Waste Reduction · Resources Circulation · Zero Landfill”. For companies, the management question is broader than recycling rates: it includes how materials are selected, used, recovered and designed out of the waste stream.

Producer-responsibility direction

Hong Kong uses producer responsibility schemes to share responsibility for collection, recycling, treatment and disposal of end-of-life products. A common legislative framework for producer responsibility schemes was passed in July 2025, while the operational requirements for individual regulated products are set through product-specific subsidiary legislation. Companies should therefore confirm which schemes and dates apply to their products rather than assuming one uniform obligation.

Define the material-flow boundary

Map significant inputs, packaging, operational waste, returned products, construction or renovation materials, food waste and hazardous or regulated streams. Record who controls each stage, where data comes from and whether the material is reused, recycled, treated, exported or disposed of.

Questions for a material-flow baseline
StageManagement questionEvidence
PurchaseCan material use, toxicity, virgin content or packaging be reduced?Specifications, bills of material, purchase data.
UseWhere do losses, damage, spoilage or avoidable disposables arise?Operational logs, waste audits, incident data.
RecoveryCan products or materials be repaired, reused, redistributed or recycled?Return data, recycler records, recovery contracts.
End of lifeAre legal, licence, traceability and treatment requirements understood?Manifests, licences, receipts and vendor due diligence.

Apply the circular hierarchy before choosing a target

  1. Avoid: remove unnecessary products, packaging and single-use items.
  2. Reduce: improve yields, durability, maintenance and inventory control.
  3. Reuse and repair: extend asset and product life through take-back, refurbishment or redistribution.
  4. Recycle: improve separation, material quality and traceability.
  5. Recover or treat: use appropriate approved routes for remaining streams.
  6. Dispose: treat disposal as the final option and retain evidence.

Manage product and packaging responsibility

Product-responsibility work may include design requirements, restricted substances, quality and safety, labelling, customer information, warranties, take-back, repairability and end-of-life arrangements. Procurement, product, legal, operations and marketing teams should agree claims and evidence before external communication.

Avoid unsupported circularity claims

Terms such as recyclable, compostable, recycled or circular can be misleading when collection infrastructure, actual recycled content, geography or treatment conditions are not stated. Define the claim, boundary and evidence.

Build decision-useful data

  • Use consistent units and conversion factors.
  • Separate generated, diverted, recycled and disposed quantities.
  • Identify hazardous, chemical and regulated streams.
  • Retain recycler and treatment evidence.
  • Track material intensity alongside absolute quantities.
  • Explain changes caused by acquisitions, closures, projects or methodology.

Create an implementation roadmap

Prioritise actions by material impact, regulatory relevance, cost, feasibility, customer demand and control. For each action define an owner, baseline, expected outcome, budget, dependency, evidence and review date.

Useful deliverables

  • Material-flow and waste baseline.
  • Legal and producer-responsibility applicability register.
  • Circularity opportunity assessment.
  • Product and packaging policy or design criteria.
  • Waste-contractor due-diligence checklist.
  • KPI definitions, data template and evidence register.
  • Prioritised circular-economy roadmap.

Questions to ask an adviser

  • Will the assessment distinguish legal obligations from voluntary ambition?
  • How will material quantities and treatment routes be verified?
  • Which actions reduce material use rather than only improving recycling?
  • How will product, procurement and operations teams be involved?
  • How will claims be reviewed for evidence and geographic limitations?

Official sources and useful references

Next step

Move from disposal reporting to material management.

A focused baseline can identify avoidable materials, priority waste streams, applicable product responsibilities and the actions most likely to reduce cost and impact.