Key Takeaways
- Businesses importing or exporting radio transmitting apparatus generally require either an OFCA permit for each shipment or a Radio Dealers Licence (Unrestricted).
- Radio transmitting apparatus includes complete products and component parts designed to transmit by radio waves.
- The annual licence fee is HK$1,500. An individual import or export permit costs HK$150 and covers one shipment.
- Genuine transhipment cargo may qualify for a free notification arrangement instead of the normal licence or permit requirements.
- A dealer licence does not automatically authorise the operation or testing of every type of radio equipment.
- Product specifications, shipment arrangements and the identity of the importer or exporter must all be checked before deciding what approval is required.
The Question Many Traders Ask Too Late
Businesses often investigate Hong Kong’s radio equipment rules only after Customs questions a shipment, a customer requests compliance documents or goods are delayed.
The legal principles are relatively concise. The difficult part is applying them to a particular product and trading arrangement.
A product may fall within the definition of radiocommunications transmitting apparatus, commonly called RTA, if it is designed to transmit by radio waves. The definition also extends to component parts of such apparatus. Common examples include mobile phones, Wi-Fi routers, Bluetooth equipment, wireless modules and certain walkie-talkies.
However, identifying a product as RTA does not, by itself, answer every licensing question. Businesses must separately consider:
- Whether the product is imported or exported;
- Whether it is possessed, used or sold in Hong Kong;
- Whether the apparatus falls within a licensing exemption;
- Whether the goods are ordinary stock, transit goods or genuine transhipment cargo; and
- Whether the business needs recurring shipment coverage or only a one-off permit.
Step 1: Conduct a Product and Activity Test
Begin by checking whether the product or any of its components transmits by radio waves.
Product category | Possible radio function |
Wireless earbuds and smart watches | Bluetooth |
Smart plugs, cameras and doorbells | Wi-Fi, Bluetooth or Zigbee |
Remote-controlled toys and drones | Radio control and telemetry |
Car key fobs and garage-door remotes | Short-range radio transmission |
Baby monitors and wireless intercoms | One-way or two-way radio transmission |
POS terminals and handheld scanners | Wi-Fi, Bluetooth or cellular connectivity |
RFID readers | Radio-frequency transmission |
Wi-Fi and Bluetooth modules | Component parts used for radio transmission |
This table is only an initial screening tool. For example, a passive RFID tag and an active RFID reader do not necessarily raise identical regulatory issues. Product specifications, frequencies, power levels and applicable exemptions should be checked before shipment.
OFCA’s guidance states that importing or exporting RTA generally requires a permit unless the person holds a Radio Dealers Licence (Unrestricted). A personal-use exemption may apply to reasonable quantities of qualifying apparatus imported or exported for an individual’s own use, but it should not be relied upon for commercial inventory.
Step 2: Find Your Business Among These Six Scenarios
Scenario 1: An e-commerce seller
“We import wireless earbuds from Shenzhen and sell them online to customers in Hong Kong.”
The commercial import of the earbuds generally requires an import permit for each shipment or a Radio Dealers Licence (Unrestricted).
The seller should also determine whether the particular earbuds comply with the specifications applicable in Hong Kong and whether their possession and sale are exempt from separate licensing requirements. Apparatus that is exempt for possession and use may still be subject to the commercial import rules.
For recurring shipments, the annual dealer licence may be more practical than obtaining individual permits.
Scenario 2: A re-export trading company
“We bring wireless products into Hong Kong from Mainland China and later export them to Southeast Asia.”
The result depends on how the goods move through Hong Kong.
If the company imports the products as ordinary stock and later exports them, it will generally need:
- an import permit and an export permit for each consignment; or
- a Radio Dealers Licence (Unrestricted) covering both import and export activities.
If the products enter Hong Kong solely for re-export and satisfy the conditions for transhipment cargo, the trader or freight forwarder may use OFCA’s transhipment notification arrangement instead.
A notification normally covers one shipment, must be submitted at least one clear working day before import and does not authorise the goods to be used or traded in Hong Kong.
Scenario 3: A one-off importer
“We are importing 50 walkie-talkies for one large event.”
For a single shipment, an import permit costing HK$150 may be more economical than obtaining the annual dealer licence.
Import approval does not necessarily authorise the equipment to be operated. The organiser must separately check whether the walkie-talkies satisfy an exemption or whether an operating licence is required.
The permit must be obtained before importation. OFCA does not issue retrospective permits after the goods have entered Hong Kong.
Scenario 4: An overseas brand testing the Hong Kong market
“We are sending commercial samples and a small first batch to Hong Kong.”
Commercial samples are not automatically covered by the reasonable personal-use exemption.
An overseas applicant may apply for an individual import permit. If the business intends to establish recurring operations and obtain a Radio Dealers Licence (Unrestricted), it will need an eligible Hong Kong business structure.
OFCA’s current application form accommodates Hong Kong sole proprietorships, partnerships and limited companies. Applicants must provide a valid Business Registration Certificate and the supporting documents applicable to their business structure.
Scenario 5: A hardware or IoT start-up
“We design connected devices in Hong Kong, import wireless modules and test prototypes.”
The company may require individual import permits or a Radio Dealers Licence (Unrestricted) for importing modules and dealing in completed products.
If it establishes and operates transmitting or receiving stations to test and develop radiocommunications apparatus, an Experimental Station Licence may also be relevant. This is a separate licence with a different purpose. It is normally location-specific, and outdoor testing requires prior authorisation and is permitted only in special circumstances. The current annual fee is HK$300.
A dealer licence alone does not authorise the business to operate all equipment for testing or communications.
Scenario 6: A freight forwarder handling transit or transhipment cargo
“Wireless products pass through Hong Kong but are not sold here.”
The precise logistics arrangement matters.
An article in transit is exempt where it is brought into Hong Kong solely to be taken out again and remains on the same vessel or aircraft. Air transhipment cargo remaining within the airport cargo transhipment area is also exempt.
For other genuine transhipment cargo, the permit requirement may be replaced by OFCA’s transhipment notification arrangement. The notification:
- is free of charge;
- must normally be submitted at least one working day before arrival;
- generally covers one shipment;
- must match the shipping documents; and
- must be presented to Customs for import and re-export.
If the freight forwarder is named as the importer or exporter on the relevant documents and the arrangement does not qualify for transit or transhipment treatment, the forwarder may be responsible for obtaining the permit.
Step 3: Compare the Licence and Permit Costs
The annual Radio Dealers Licence (Unrestricted) fee is HK$1,500. Each import or export permit costs HK$150 and covers one shipment.
Annual shipping pattern | Permits required | Permit fees | Annual licence fee |
One import shipment | 1 | HK$150 | HK$1,500 |
Four import shipments | 4 | HK$600 | HK$1,500 |
Twelve import shipments | 12 | HK$1,800 | HK$1,500 |
Six imports followed by six exports | 12 | HK$1,800 | HK$1,500 |
Twelve imports followed by twelve exports | 24 | HK$3,600 | HK$1,500 |
Weekly imports | 52 | HK$7,800 | HK$1,500 |
The mathematical break-even point is ten permits because ten permits cost HK$1,500. If every consignment involves both an import and a later export, five consignments may already generate ten permits.
Cost is not the only consideration. A recurring trader should also consider application time, shipment planning, record-keeping and the risk of goods arriving before a permit is ready.
Licence holders must comply with the licence conditions. These include operating from the licensed address, storing licensed apparatus at an approved address, displaying the licence and, where applicable, maintaining transaction records.
Four Common Compliance Mistakes
1. “It is only a component”
The statutory concept of RTA includes component parts of apparatus designed for transmission by radio waves. Wireless modules should not be ignored simply because they are incorporated into another product later.
2. “We only re-export”
Ordinary import followed by export may require two permits. Genuine transhipment cargo may instead qualify for the notification arrangement, but the required conditions and submission deadline must be observed.
3. “Consumers can use it without a licence”
An exemption allowing possession or use of compliant consumer equipment does not automatically remove the commercial import or export requirements.
4. “Our supplier already has a licence”
A Radio Dealers Licence (Unrestricted) is not transferable. The business acting as importer, exporter or dealer must establish whether it has its own required authorisation.
A Note About Radio Jammers
Radio jammers require special caution. OFCA states that their import or export is prohibited unless they are manufactured for export, imported for subsequent re-export or written consent has been obtained from the Communications Authority.
Accordingly, businesses should not advertise, import or sell jammers for ordinary Hong Kong use on the assumption that a dealer licence provides general approval.
Your Three-Question Decision Checklist
- Does the product or any component transmit by radio waves?
If no, the Radio Dealers Licence framework may not apply. If yes, continue to the next question. - Will your business import, export, possess or deal in the equipment in Hong Kong?
Identify each activity separately and check whether the apparatus or logistics arrangement qualifies for an exemption. - Will the business require ten or more import or export permits each year or deal in covered apparatus continuously?
If yes, the annual Radio Dealers Licence (Unrestricted) may be more economical and practical. If no, individual permits may be sufficient.
How Premia TNC Can Assist
Premia TNC helps businesses establish an appropriate Hong Kong entity and prepare applications for the Radio Dealers Licence (Unrestricted). We can also help traders review their intended products, shipment frequency and business model before beginning the application process.
Businesses should obtain product specifications and confirm their actual logistics arrangements before shipping. Where the regulatory treatment of a particular device remains uncertain, clarification should be sought from OFCA.
