Product Eco-responsibility Ordinance (Cap. 603), as amended by the Promotion of Recycling and Proper Disposal of Products (Miscellaneous Amendments) Bill 2025 (common PRS framework); Promotion of Recycling and Proper Disposal (Electrical Equipment and Electronic Equipment) (Amendment) Ordinance 2016; Plastic Shopping Bag Charging Scheme; Glass Beverage Container Producer Responsibility Scheme

HKICPA published HKFRS S1 and HKFRS S2 on 12 December 2024, fully aligned with IFRS S1 and S2. The Hong Kong SAR Government's December 2024 Roadmap sets out the phased path to mandatory adoption for publicly accountable entities.

Enforcement

Voluntary at HKICPA level. The Hong Kong SAR Government's roadmap (10 December 2024) sets out phased mandatory adoption for publicly accountable entities.

Effective date

Annual reporting periods beginning on or after 1 August 2025

Covered entities

Any Hong Kong entity (voluntary). Mandatory phased rollout per government roadmap.

HKEX listing rules require all Main Board issuers to disclose climate information aligned with IFRS S2 on a comply-or-explain basis from 1 January 2025, with mandatory application for Hang Seng Composite LargeCap constituents from 1 January 2026. Some elements differ from IFRS S2 (e.g., scope of consolidation, industry-based metrics).

Enforcement

Scope 1 and 2 GHG emissions mandatory for all listed issuers (Main Board and GEM) from FY2025. Other climate requirements (Part D of the ESG Code) on a comply-or-explain basis for all Main Board issuers from FY2025 and voluntary for GEM issuers. Mandatory for Hang Seng Composite LargeCap Index constituents from FY2026.

Effective date

Financial years commencing on or after 1 January 2025 (Scope 1 and 2 mandatory for all issuers; comply-or-explain for Main Board); financial years commencing on or after 1 January 2026 (mandatory for HSCI LargeCap constituents)

Covered entities

All HKEX-listed issuers (Scope 1 and 2); all Main Board issuers (comply-or-explain on other climate requirements); HSCI LargeCap constituents (mandatory); GEM issuers encouraged to report other climate requirements voluntarily

The EU runs product-specific EPR regimes for packaging, electrical and electronic equipment, batteries, vehicles and single-use plastics, putting collection, recycling and recycled-content obligations on producers placing goods on the single market. The Packaging Regulation has applied directly in all Member States since 12 August 2026, with recyclability, reuse and recycled-content rules phasing in. The new End-of-Life Vehicles Regulation sets vehicle design, recycled-content and EPR rules from 1 September 2028.

Enforcement

Mandatory

Effective date

PPWR entered into force 11 February 2025 and has applied since 12 August 2026 (Article 67(5) from 12 February 2029; other obligations phase in later). Battery Regulation entered into force 17 August 2023 with phased obligations through 2027. ELV Regulation (EU) 2026/1738 entered into force 13 August 2026 and applies from 1 September 2028, when Directive 2000/53/EC is repealed (some Directive provisions continue until 2032). WEEE Directive in force since 2012; SUP Directive transposition deadline 3 July 2021.

Covered entities

Producers, importers and distributors placing packaging, EEE, batteries, vehicles or single-use plastic products on the EU market, regardless of material or origin

The UK runs separate producer responsibility regimes for packaging, electrical equipment, batteries and end-of-life vehicles. Under the 2024 pEPR rules, large packaging producers pay PackUK disposal fees that cover the cost of managing household packaging waste, and from year 2 (2026-27) those fees vary with recyclability. Producers still meet recycling obligations by obtaining packaging recycling notes (PRNs and PERNs).

Enforcement

Mandatory

Effective date

pEPR Regulations made 11 December 2024, in force 1 January 2025; first assessment year 2025-26 (first notices of liability October 2025, based on 2024 packaging data); confirmed year 2 (2026-27) fees due later in 2026; WEEE Regs since 1 January 2014; Battery Regs since 5 May 2009

Covered entities

Packaging producers established in the UK with annual turnover of GBP 1 million or more that supplied or imported more than 25 tonnes of packaging in the previous year. Large producers (turnover above GBP 2 million and more than 50 tonnes) pay household packaging disposal fees and must meet recycling obligations with PRNs or PERNs; small producers have fewer duties. WEEE producers placing EEE on the UK market; battery and ELV producers.

Switzerland operates advance disposal fee (vRG) schemes for electrical and electronic equipment, batteries, glass bottles and PET, run by industry organizations (SENS, SWICO, Inobat, PET-Recycling Schweiz) under federal ordinances. The Packaging Ordinance adopted in June 2026 replaces the beverage container rules: packaging must be minimized, suitable for recycling and use recycled content where feasible (from 2030); sellers of beverage cartons and single-use plastic packaging above the thresholds must take them back unless they finance an industry scheme (from 2031); and recycling rates of at least 70% for beverage cartons and 55% for single-use plastic packaging apply from 2032, with possible mandatory deposits if missed. Until then, collection of plastic packaging remains largely industry-led and voluntary.

Enforcement

Mandatory

Effective date

VREG in force since 1 July 1998, revised scope effective 1 January 2022; VVEA effective 1 January 2016, amended 1 August 2026; VerpV in force 1 January 2027, with advance disposal fee for glass packaging (Art. 8) from 1 January 2028, general packaging requirements (Art. 3) from 1 January 2030, subsidiary take-back duty for beverage cartons and single-use plastic packaging (Art. 4) from 1 January 2031, and minimum recycling rates (Art. 7) from 1 January 2032; battery and glass advance disposal fees in place since the 1990s

Covered entities

Manufacturers, importers and retailers of electrical and electronic equipment, batteries, glass and PET beverage containers placing products on the Swiss market. Under the VerpV: manufacturers and importers of glass packaging (extended beyond beverage containers from 2028); retailers and manufacturers placing filled beverage cartons or single-use plastic packaging on the market that exceed CHF 1 million turnover and 500 kg of packaging in two consecutive years (take-back duty from 2031 unless met through an industry organization); all retailers and manufacturers supplying filled packaging (design requirements from 2030).

Norway implements EU-style EPR through Avfallsforskriften, requiring producers of packaging, EEE, batteries and vehicles to join a producer responsibility organization approved by the Environment Agency. Since July 2025 the previous 1,000 kg-per-material exemption for packaging has been abolished, so every importer or producer must register and report. Chapter 7A requires producers of certain single-use plastic products to join an approved scheme and cover municipal cleanup and collection costs from 2027, and Chapter 7B sets EPR for plastic-containing fishing and aquaculture gear.

Enforcement

Mandatory

Effective date

Avfallsforskriften in force since 2004 (latest amendment FOR-2025-12-18-2839, in force 1 January 2026); Chapter 7 packaging EPR revised effective 1 July 2025 (lower registration limit removed); Chapter 7A in force on adoption (FOR-2025-11-12-2278), with the duty to cover municipal costs applying to costs from 1 January 2027 and first payment due 1 October 2028; Chapter 7B in force 1 January 2026, with §§ 7B-4 to 7B-7 applying from 1 March 2027; WEEE provisions since 1999

Covered entities

Any company that professionally imports or manufactures packaging, packaged products, EEE, batteries or vehicles for the Norwegian market; from July 2025 all packaging producers regardless of volume. Also producers that first place certain single-use plastic products on the Norwegian market (food and beverage containers, cups, flexible food packaging, light carrier bags, wet wipes, tobacco filters, balloons) and producers of fishing, recreational fishing and aquaculture gear containing plastic.