Submissions and Reports

We recognize the Government's commitment to achieving carbon neutrality and achieving energy efficiency as part of its roadmap for consolidating Hong Kong’s competitiveness as a leading international city – with the District Cooling Services (DCS) mechanism and its proposed expansion to cover the Kwu Tung North New Development Area (KTN NDA) , Tung Chung New Town Extension (East) (TCNTE(E)), as well as additional new areas within the Kai Tak DCS, part and parcel of these objectives. At the same, we put forward several general recommendations regarding the proposals' design, user implications and cost recovery considerations. We also suggest that in implementing the legislative amendments, a comprehensive assessment of consumer and business needs, as well as evaluation of the commercial viability of the proposed expansions of the DCS, be conducted to maximize the scheme’s efficacy.

The Chamber commends the Government's ongoing efforts to advance the Northern Metropolis (NM) mega-project and have submitted our latest general recommendations to support its comprehensive development in the short and medium term. Specifically, we have conveyed our members' perspectives on the design and execution of the Pilot Large-Scale Land Disposal Scheme, emphasizing key considerations such as financial and investment aspects, as well as land supply and management challenges. These insights aim to encourage industry participation and foster effective collaboration with the Government in building this new metropolis.

The Chamber recognizes the objectives of present industry-led efforts to develop a Voluntary Code of Conduct for ESG ratings and data products providers (the Code), and regards this form of regulatory intervention as a proportionate measure, to foster the growth of a transparent and trusted market for the sector, and to facilitate companies due diligence in light of increasing sustainable investment awareness.
In relation to the design and implementation of the proposed Code, we suggest amongst others, that consideration be given to incorporating suitable flexibility and interoperability to facilitate voluntary adoption by the wider business community, in the light of potential resource and real data provision challenges.

The Chamber generally supports the Government’s proposals to transform Lau Fau Shan into a tech hub and eco-tourism hotspot, in line with its blueprint for the development of the Northern Metropolis. We recognize that such efforts would benefit businesses, particularly the tech sector, through creating opportunities for cross-border corporate synergies and development alongside Qianhai and Nanshan in Shenzhen.
At the same time, we highlight several conceptual and practical issues relating to these proposals, which we suggest that the Government take into consideration when taking forward the megaproject.

The Chamber welcomes the proposals to regulate such powerful greenhouse gases with high global warming potential and suggests that the Government takes into account the operational practicalities that businesses are faced with during the implementation. We propose that the Government defer the implementation of the ban on sale and supply, as well as on-product labeling requirements, to allow businesses more time to comply with minimal disruptions.

The Chamber supports global efforts to develop common standards for ESG reporting as they could provide a useful reference guide for investors and issuers. We venture to suggest a deferral of implementation of mandatory climate-related reporting standards to allow sufficient time for all market participants, especially smaller cap issuers, to comply. The proposed mandatory requirements should also consider such factors as practicability and proportionality to avoid listing rule violations.

The Chamber welcomes the Government’s initiative to update the Talent List to address Hong Kong’s acute talent shortage situation and sustain a competitive economy, and puts forward recommendations on the necessary high-skilled professions for inclusion in the same.

The Chamber welcomes the Environmental Protection Department’s consultation on the Specifications for Product Barcode and Designated Logo for Producer Responsibility Scheme on Plastic Beverage Containers (“PPRS”), and suggests that greater flexibility be afforded to the arrangements to avoid wastage or any unintended consequences of discouraging efforts to reduce plastic waste.

The Chamber welcomes and supports the ISSB’s initiative to formulate a comprehensive set of global sustainability disclosures to serve as performance guideposts for businesses, while providing consistent, comparable and high-quality ESG reporting designed to meet investor needs. However, questions over the approach to and with the proposed standards, such as the lack of clarity on when the ISSB will be fully quorate and the absence of the principle-based GRI standard, will have to be addressed before the new standards are introduced.

The Chamber supports the use of legislation to eliminate disposable plastic tableware from the waste stream, but suggests that consideration should also be given to viable substitutes as an interim means of transitioning away from plastics. Over the long term, there is the need for a holistic approach to eliminating the use of single-use items.