Policy Statement & Submission

17 November 2009


Mr David T W Wong
Principal Environmental Protection Officer
(Cross-Boundary & International)
Environmental Protection Department
33/F, Revenue Tower
5 Gloucester Road, Wanchai
Hong Kong


Dear David,

HKGCC Suggestions on “CEPA V” for Environmental Service Sector

On behalf of the Hong Kong General Chamber of Commerce, I would like to submit to you with pleasure our suggestions of the possible liberalization measures for the environmental services sector with CEPA.

Expanding the Hong Kong brands promotion

The Chamber has joined other trade associations to engage with the Commerce and Economic Development Bureau in discussing the promotion of “Brand HK” in the Mainland. Besides the past submissions and recommendations on this issue, we would like to reiterate the need to focus attention on promoting Hong Kong's brand in the environmental services sector.

In the wake of the global financial tsunami, governments around the world have been looking for economic drivers for developing sustainable business, so as to stimulate growth and employment. Amongst all business sectors, the environmental industry, particularly in the fields of energy efficiency and renewable energy, has been a priority area of many countries. There is a vital need for the Central Government and HSAR Government to accelerate the joint efforts of Hong Kong and Mainland enterprises in research, development, manufacturing, application, sales and distribution of solutions and products of advanced energy efficiency and environmental improvement technologies. During this process, Hong Kong could build up related brands rather than play the “bridge” roles. Accordingly, we believe that CEPA VII needs to cover this issue.


About the mutual licenses recognition

In recent years, many wholly-owned Hong Kong enterprises have expressed interest in the environmental service industry in the Mainland, but there exist many obstacles at the operational level. For examples, an environmental permit system (環保企業許可證制度) is used in the Mainland to evaluate investment of environmental enterprises, but Hong Kong environmental practitioners' qualified certificates (環保從業稱職證書) are not recognized by the Chinese authorities. It would be definitely beneficial to Hong Kong service providers if market entry barriers can be eliminated by mutual recognition of environmental qualifications.

Besides, we suggest that practicing licenses (and professional memberships of accredited bodies) obtained in Hong Kong, for examples, for carrying out environmental impact assessments, environmental monitoring and audit projects should be accepted de facto in the Mainland without requiring tie-ups with local institutions. Although Hong Kong companies can set up environmental businesses in Guangdong under the CEPA mechanism, they are required to fulfill certain business establishment criteria before they can obtain practicing licenses for operating services. As Hong Kong SMEs may not be able to afford the initial investments only for getting licenses, it would be very helpful if such requirements are relaxed.

We sincerely hope that the above suggestions will be included in the new round of enhancements to CEPA, and that the issues raised in our submission will receive serious consideration by the HKSAR government and the Central Government.

Thank you.

With best wishes for a most fruitful outcome for the CEPA consultation, I remain,


Yours sincerely,





Alex Fong
CEO