The Consumer Council (CC) is pleased to provide views on amendments on mercury-added products (MAPs) in the Mercury Control Ordinance proposed by the Environmental Protection Department (EPD):
CC supports the extension of control of MAPs by adding 16 new MAPs as one of the measures in minimizing the discharge of mercury and its compounds into the environment.
Mercury
- Mercury is a chemical that is highly toxic to humans and the environment. When released into the environment, it enters the food chain where it accumulates, mainly in fish. Exposure to high levels of mercury can cause harm to the brain, lungs, kidneys and immune system.
- According to the United States Environmental Protection Agency’s figures, approximately 6,500 metric tons of mercury are emitted globally each year. Of that amount, two-thirds come from industrial pollution while the remaining come from natural sources.
- Mercury has severe impacts on aquatic ecosystems, especially wetland areas. Some compounds of mercury (such as methylmercury) have the ability to bioaccumulate and bioconcentrate, contributing to its toxicity. Mercury levels can increase by 100 to 1,000 times or more through bioconcentration. For this reason, even relatively low concentration of mercury in water can contaminate an entire food chain and make fish unsafe for human consumption.
Insights from CC Previous Studies
- CC has not conducted heavy metal testing on electrical products covered in the proposed amendments before, therefore we have limited knowledge about the proposed regulation. However, CC had carried out research projects in the heavy metal content of some consumer products and the findings are summarized as below:
- CC conducted heavy metal testing on disposable batteries in 2010 and 2020. The results revealed that the battery samples did not contain mercury or mercury compounds.
- CC also conducted heavy metal testing on various cosmetic products, such as Vitamin C-containing whitening serum and natural hair dyes. Trace amount of mercury was found in one sample of henna type natural hair dyes while no sample of Vitamin C-containing whitening serums was detected with mercury.
Insights from Overseas Regulations
- The European Union (EU) has different directives and national laws on the control of mercury and its compounds in different products. It had phased out the use of dental amalgam and had banned its export by 1 January 2025. The use, manufacture and import of dental amalgam will only be permitted for specific medical needs and when deemed strictly necessary by a medical practitioner. Moreover, the manufacture, import and export of six types of mercury-containing lamps will be prohibited from 31 December 2025 or 31 December 2026, depending on the lamp type.
- The Restriction of Hazardous Substances (RoHS) Directive is a key regulation in EU that aims to limit the use of specific hazardous materials in electrical and electronic equipment. The directive currently restricts the use of ten substances, including mercury, to protect human health and the environment.
Conclusion
- Reducing the amount of heavy metals in different consumer products is important in safeguarding consumers’ health and could help minimize the leakage of heavy metals into the environment.
- CC looks forward to seeing more policies and measures to control and regulate different heavy metals from various sources in Hong Kong.
Consumer Council
February 2025
