Hong Kong-based Rambler Marketing (RM) sells 3C products such as computers, communications, and consumer electronics and accessories. In an interview with HKTDC Research, RM’s Director, Eddie Tsoi described how the company has made inroads into the ASEAN e-commerce retail market and discussed the pros and cons of selling through third-party marketplace.

On 12 June 2025, the European Commission published a draft implementing Regulation creating a common disclosure format for the discarding and destruction of unsold consumer products. The disclosure obligation focuses on the discarding of unsold consumer products for the purposes of any type of waste treatment operation including for reuse and recycling. Feedback on the draft implementing Regulation is invited until 10 July 2025.

The European Commission (“Commission”) has set up a new surveillance tool to prevent what is referred to as harmful trade diversion. The tool monitors customs data to track goods that have been subject to a “potentially harmful increase” in imports since January 2025. By identifying such import trends at an early stage, the Commission hopes to more efficiently protect EU industries from these allegedly injurious imports.

Hong Kong companies selling electronics to European customers should keep in mind that ecodesign requirements pursuant to Commission Regulation (EU) 2023/1670 will apply to smartphones, feature phones, cordless phones and slate tablets placed on the EU market from 20 June 2025 onwards. Energy Labelling requirements will apply from the same date for smartphones and slate tablets.

On 14 May 2025, the European Chemicals Agency (ECHA) announced that it had published a catalogue containing so-called borderline cases between articles and substances/mixtures in relation to the REACH Regulation. Hong Kong traders may recall that, while substances in articles have to only rarely be registered (based on very specific conditions), all substances, including those in mixtures, must be registered if they meet the yearly tonnage threshold requirements, unless they are expressly exempt. This new guidance from ECHA is aimed at helping manufacturers and importers, among others, to determine if an object is an article according to REACH.

On April 16, 2025, the European Commission approved the first working plan under the ESPR. This plan places a focus on sectors such as textiles, furniture, tyres, mattresses, iron, steel, aluminium, and incorporates overarching criteria like repairability and recyclability. It is crucial for Hong Kong traders to stay vigilant, keeping track of evolving regulations, delegated acts, and product requirements to guarantee compliance with EU directives for goods destined for the European market.

On 21 May 2025, the European Commission proposed a delay to the due diligence obligations under the EU Batteries Regulation (Regulation (EU) 2023/1542). More specifically, the Commission has proposed to (a) delay the implementation of the due diligence obligations for two years to 18 August 2027 (amending Article 48(1)); and (b) extend the deadline for the Commission to publish due diligence guidelines until 26 July 2026 (amending Article 48(5)).

In 2025, the global electronics sector is expected to continue to grow, a likelihood acknowledged by many of the respondents to the Hong Kong Electronics Fair (Spring 2025) survey. Such optimism comes regardless of the tariffs imposed by the Trump-led US government on products of China-origin (as well as those sourced from many other parts of the world), an undertaking that coincided with the date of the Fair and the period the survey was conducted (13-16 April, 2025).

The FDA announced on 22 May the seizure in Chicago of nearly two million units of unauthorised e-cigarette products with an estimated value of US$33.8 million. The vast majority of these products originated in Mainland China and were intended for shipment to various U.S. states.

The U.S. Federal Communications Commission announced on 22 May its approval of new rules designed to ensure that entities that test, review and certify wireless electronic devices for importation, marketing and sale in the U.S. do not have ownership interests that present national security risks, “including the risk that they would do the bidding of a foreign adversary.”