Tracking Mercury Phase-Out Across 12 Asian Jurisdictions: Status and Deadlines
This blog was originally posted on 27th August, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
Authored by Alex Li, Regulatory Compliance Specialist, and Lynn Chiam, Regulatory Compliance Specialist, Adherent
Key Insight
Twelve Asian jurisdictions are at very different stages of implementing the Minamata Convention’s MC-5/4 amendment on mercury-added products. Seven — China, Japan, Hong Kong (China), Taiwan, Singapore, South Korea and India — have adopted phase-outs broadly aligned with the amendment, with staggered deadlines running through to 1 January 2028, while Thailand and the Philippines sit outside that pattern and Vietnam, Indonesia and Malaysia have yet to introduce any phase-out timeline. Companies placing mercury-added products on Asian markets should keep monitoring developments and pay close attention to divergence in scope, timing and transitional relief between jurisdictions.
Table of Contents
- Introduction
- The Twelve Asian Jurisdictions Covered
- Comparison Table
- Conclusion
- Frequently Asked Questions
Introduction
Navigating mercury regulations across Asia can feel like aiming at a moving target. The UN Minamata Convention sets global goals to phase out toxic substances, and at its fifth meeting (MC-5/4), the Conference of the Parties (COP) adopted decisions to amend Parts I and II of Annex A (mercury-added products) and Part I of Annex B (manufacturing processes). Under these Annex A amendments, the Conference of the Parties established new phase-out dates across several product categories to tighten global controls.
The comparison table covers twelve Asian jurisdictions and their progress in implementing the Minamata Convention’s amendment to Annexes A and B on mercury-added product phase-outs.
The Twelve Asian Jurisdictions Covered
The twelve asian jurisdictions are:
- China (Mainland)
- Japan
- Vietnam
- Hong Kong (China)
- Taiwan (China)
- Singapore
- South Korea
- Philippines
- India
- Thailand
- Indonesia
- Malaysia
Comparison Table
| Countries | Status | Dates | Commentary |
| China | In force | 31 December 2026 Compliance Deadline: Prohibition of manufacture, import or export of the following products: (1) Compact fluorescent lamps (CFLs) over 30 watts; (2) Non-integrated ballast CFLs ≤ 30 watts with a single lamp mercury content ≤ 5mg; (3) Straight linear fluorescent lamps (using halophosphate phosphor) ≤ 40 watts with a single lamp mercury content ≤ 10 mg, and those over 40 watts; (4) Non-linear fluorescent lamps (like U-shaped and circular) using halophosphate phosphor, including all wattages. 31 December 2027 Compliance Deadline: Prohibition of manufacture, import or export of the following products: (1) Straight linear fluorescent lamps for general lighting: (a) Triband phosphor below 60 watts with a mercury content not exceeding 5 mg per lamp; (b) Triband phosphor equal to or more than 60 watts with a mercury content not exceeding 5 mg per lamp; (c) Triband phosphor equal to or more than 60 watts with a mercury content exceeding 5 mg per lamp; (2) Non-linear fluorescent lamps (like U-shaped and circular) using tri-band phosphor for general lighting purposes, including all wattages. | On 24 December 2025, the Chinese Ministry of Ecology and Environment and 12 other departments jointly published an announcement concerning the control requirements for 12 types of mercury-added products and the polyurethane production process using mercury-containing catalysts. The announcement aims to implement the approval of amendments to Annex A and Annex B of the Minamata Convention on Mercury (Decision 5/4 of COP5). The announcement establishes several prohibitions on the production and import/export of certain mercury-added products, based on different deadlines. Furthermore, the announcement prohibits the use of mercury-containing catalysts in the production of polyurethane, and prohibits incorporating any mercury-added products banned under the amendment into assembled products. Products used for research, instrument calibration, or reference standards are generally exempt from the production and import/export prohibitions unless otherwise specified. |
| Japan | In Force | 1 January 2026 Complaince Deadline: The following mercury-added products shall be phased out by this date: (1) Batteries, specifically silver oxide batteries and zinc-air batteries; (2) Compact fluorescent lamps for general lighting, specifically those with a rated power consumption of more than 30 watts, regardless of mercury content; (3) Cold cathode fluorescent lamps and external electrode fluorescent lamps for electronic displays; (4) Pressure gauges, specifically non-electrical pressure gauges and electrical pressure gauges for measuring the pressure of objects that become liquid when heated. 1 January 2027 Compliance Deadline: The following mercury-added products shall be phased out by this date: (1) Compact fluorescent lamps for general lighting and bulb-shaped fluorescent lamps for general lighting; (2) Linear fluorescent lamps for general lighting that use phosphors with halophosphate as their main component; (3) Fluorescent lamps for general lighting whose main component is halophosphate. 1 January 2028 Compliance Deadline: The following mercury-added products shall be phased out by this date: (1) Linear fluorescent lamps for general lighting that use tri-wavelength phosphors; (2) Fluorescent lamps for general lighting that use tri-wavelength phosphors. | On 27 December 2024, the Japanese Cabinet issued an amendment to the Preventing Environmental Pollution of Mercury Act Enforcement Order (No. 378 of 2015). The amendment introduced changes to expand the the scope of batteries, compact fluorescent lamps, and straight fluorescent lamps that fall under the category of specified mercury-using products in order to align with Amendment MC-5/4 to the Minamata Convention. The prohibitions were phased-in from 1 January 2026 in three stages. On 7 March 2025, the Japanese Ministry of Economy, Trade, and Industry (METI) issued amendments to the Export Approval for Certain Mercury, Mercury Compounds, and Mercury-Containing Products (Notification No. 13 of 2017) and the Import Approval for Specific Mercury-Containing Products and Products that Use Them as Parts (Notification No. 19 of 2015). This amendment introduced the same MC-5/4-aligned products to the Annexes of the Notifications to prohibit the import and export of these products. |
| Vietnam | Not In Force | N/A | Although a signatory to the Minamata Convention on Mercury, Vietnam has yet to publish a regulation to prohibit the manufacture, use and import of mercury-added products in line with the MC-5/4 amendment. Vietnam recently enacted its new Chemicals Law No. 69/2025/QH15 and is still in the midst of issuing implemeting regulations to fully flesh out the regulatory framework. Decree No. 24/2026/NĐ-CP clarifies that mercury and its compounds are among the list of chemicals requiring special control as well as the list of chemicals requiring the developlment of a chemical incident prevention and response plan. Decree No. 26/2026/NĐ-CP stipulates that enterprises producing products or goods containing hazardous chemicals including mercury and its compounds must establish a control process, declare specific information about the hazardous chemicals used, and keep records. Nevertheless, none of the above Vietnamese laws and regulations mandate a product ban or phase-out timeline like other jurisdictions. |
| Hong Kong (China) | In Force | 27 March 2026 Compliance Deadline: the import, export and manufacture of the following mercury-containing products will not be allowed in Hong Kong by this date: (1) Batteries; (2) Switches and relays; and (3) Cosmetics. 31 December 2026 Compliance Deadline: the import, export and manufacture of the following mercury-containing products will not be allowed in Hong Kong by this date: (1) Compact fluorescent lamps for general lighting; and (2) Non-linear, including U-bend and circular, fluorescent lamps for general lighting that is made of halophosphate phosphor. 31 December 2027 Compliance Deadline: the import, export and manufacture of the following mercury-containing products will not be allowed in Hong Kong by this date: Linear fluorescent lamps, and non-linear (including U-bend and circular) fluorescent lamps, made of triband phosphor or halophosphate phosphor for general lighting. | On 30 May 2025, the Hong Kong Environment and Ecology Bureau issued an amendment to the Mercury Control Ordinance (Chapter 640) to incorporate the amendments regarding mercury-added products for both MC-4/3 and MC-5/4 amendments to the Minamata Convention of Mercury. The compliance deadlines for eight MC-4/3 products are 31 December 2025 whereas the MC-5/4 products have staggered compliance deadlines later prescribed by Notice L.N. 28 of 2026. Regarding enforcement, the Hong Kong Government indicated that they are offering a grace period until 31 January 2029 for industry players to comply. Prosecution will be carried out after sufficient evidence is gathered after the lapse of the grace period should violations continue. |
| Taiwan | In Force | 1 January 2027 Compliance Deadline: Prohibition of manufacture, import or export of the following products: (1) Compact fluorescent lamos for general lighting, (2) Halophosphate phosphor linear/non-linear fluorescent lamps for general lighting. 1 January 2028 Compliance Deadline: Prohibition of manufacture, import or export of linear/non-linear fluorescent lamps using tri-phosphor coating for general lighting. | On 22 June 2026, Taiwan’s Ministry of Environment announced amendments to the “Restrictions on the Import of Mercury-Containing Products.” The amendments are issued under Article 21 of the Waste Disposal Act, which empowers the Ministry to restrict the import of specific waste-generating or hazardous products. The notice implements the phase-out on a staggered timeline. Phase 1 takes effect immediately upon enactment, on 1 July 2026, and covers the following products: Switches and relays General-purpose high-pressure mercury lamps Fluorescent lamps with built-in ballasts ≤30W Cold cathode and external electrode fluorescent lamps used in electronic displays Strain gauges used in plethysmographs Mercury vacuum pumps Tire balancers and wheel balance weights Photographic film and paper Space vehicle propellants Melt pressure transducers, transmitters, and sensors (electrical/electronic measuring instruments) Non-electronic measuring devices: barometers, hygrometers, manometers, thermometers (including clinical thermometers), and blood pressure monitors Phase 2 will become effective on 1 January 2027, whereas Phase 3 will be enforced on 1 January 2028. |
| Singapore | In Force | 1 January 2027 Compliance Deadline: the import, export, and manufacture of the following 4 mercury-added products will not be allowed in Singapore by this date: (1) Compact fluorescent lamps (CFLs) for general lighting purposes that are > 30 watts; (2) Compact fluorescent lamps with a non-integrated ballast (CFL.ni) for general lighting purposes that are ≤ 30 watts with a mercury content not exceeding 5 mg per lamp burner; (3) Linear fluorescent lamps (LFLs) for general lighting purposes: – Halophosphate phosphor ≤ 40 watts with a mercury content not exceeding 10 mg per lamp – Halophosphate phosphor > 40 watt; (4) Halophosphate phosphor non-linear fluorescent lamps (NFLs)(e.g., Ubend and circular) for general lighting purposes. 1 January 2028 Compliance Deadline: the import, export and manufacture of the following 2 mercury-added products will not be allowed in Singapore by this date: (1) Linear fluorescent lamps (LFLs) for general lighting purposes: – Triband phosphor < 60 watts with a mercury content not exceeding 5 mg per lamp – Triband phosphor ≥ 60 watts with a mercury content not exceeding 5 mg per lamp – Triband phosphor ≥ 60 watts with a mercury content exceeding 5 mg per lamp (2) Triband phosphor non-linear fluorescent lamps (NFLs)(e.g., U-bend and circular) for general lighting purposes | On 20 April 2026, the Singapore National Environment Agency (NEA) published a circular on control of 6 mercury-added products under the Environmental Protection and Management Act 1999 (EPMA). Existing stocks imported before the compliance deadlines are allowed to be used and sold locally until depletion. The circular also updates the corresponding list of HS Codes and Product Codes including the versions to become valid after the 2028 phase-out. The new HS Codes and Products Codes for cold cathode fluorescent lamps and external electrode fluorescent lamps are also provided. |
| South Korea | In force | 31 Decmber 2026 Compliance Deadline: (Phase-out date) Prohibition on the manufacture, import, or export of the following products: (1) Small fluorescent lamps (CFLs) for general lighting over 30 watts, (2) Compact fluorescent lmaps CFLs (CFL.ni) with non-integrated stabilizers ≤30 watts with ≤5 mg mercury per burner, (3) Short-wavelength linear fluorescent lamps (Halophosphate phosphor) ≤40 watts with ≤10 mg mercury, (4) Short-wavelength linear fluorescent lamps (Halophosphate phosphor) exceeding 40 watts or across all watt ranges, as well as halophoshate non-linear fluorescent lamps. 31 Decmber 2027 Compliance Deadline: (Phase-out date) Prohibition on the manufacture, import, or export of the following products: (1) Linear fluorescent lamps (LFLs) for general lighting, including triband phosphor lamps under 60 watts with mercury content not exceeding 5mg per lamp, (2) Triband phosphor lamps 60 watts and over, (3) Non-linear fluorescent lamps (NFLs) for semi-lighting purposes, such as U-shaped and circular lamps, covering all wattage ranges. | On October 2, 2024, South Korea’s Ministry of Environment issued a full amendment to its Notice on the List of Persistent Organic Pollutants (POPs) — Ministry of Environment Notice No. 2024-186. The amendment specifies detailed chemical names and identification numbers (CAS Nos.) for pollutants that had previously been listed only in general terms, enabling precise verification while also clarifying exemption language and expiration dates. The Notice is built around two annexes: Annex 1 — Expanded to list specific chemical names and CAS numbers for each regulated persistent organic pollutant. Annex 2 — Clarifies the wording, scope of application, and explicit termination deadlines for specific exemptions. Annex 1 implements the Stockholm Convention, while Annex 2 implements the Minamata Convention on Mercury — the latter being the core focus of this comparison. Annex 2 transposes the Minamata Convention’s product phase-out list, assigning a phase-out deadline to each product category. Mercury-added products covered include batteries, switches and relays, CFLs and fluorescent lamps, cosmetics, measuring instruments, and others. |
| Philippines | In force (Delayed) | 1 January 2022 Compliance Deadline: the manufacture, and import of the products below shall not be allowed from this date. – Batteries, except for button zinc silver oxide batteries with a Mercury content <2% and button zinc air batteries with a Mercury content <2%; – Switches and relays, except very high accuracy capacitance and loss measurement bridges and high frequency radio frequency switches and relays in monitoring and control instruments with a maximum Mercury content of 20 mg per bridge, switch or relay; – Compact fluorescent lamps (CFLs) for general lighting purposes that are 30 watts with a Mercury content exceeding 5 mg per lamp burner; – Linear fluorescent lamps (LFLs) for general lighting purposes: (a) Triband phosphor < 60 watts with a Mercury content exceeding 5 mg per lamp; (b) Halophosphate phosphor ≤40 watts with a Mercury content exceeding 10 mg per lamp; – High pressure Mercury vapour lamps (HPMV) for general lighting purposes; – Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps (CCFL and EEFL) for electronic displays: (a) short length (≤500 mm) with Mercury content exceeding 3.5 mg per lamp; (b) medium length (> 500 mm and ≤1 500 mm) with Mercury content exceeding 5 mg per lamp; (c) long length (> 1 500 mm) with Mercury content exceeding 13 mg per lamp; – Cosmetics (with Mercury content above 1ppm), including skin lightening soaps and creams, and not including eye area cosmetics where Mercury is used as a preservative and no effective and safe substitute preservatives are available; – Pesticides, biocides and topical antiseptics; – The following non-electronic measuring devices except non-electronic measuring devices installed in large-scale equipment or those used for high precision measurement, where no suitable Mercury-free alternative is available: (a) barometers; (b) hygrometers; (c) manometers; (d) thermometers: (e) sphygmomanometers. | The Philippines has seen significant delays implementing amendment MC-5/4 to the Minamata Convention despite accepting it at the international treaty level. The Bureau of Philippine Standards (BPS) issued a draft technical regulation outlining the mandatory product certification requirements for MC-5/4 mercury-added products, but it has not been finalized as of yet. The products covered include: – Batteries; – Switches and relays with very high accuracy capacitance and loss measurement bridges and high frequency; – Compact Fluorescent Lamps (CFLs) for general lighting purposes that are ≤ 30 watts; – Linear Fluorescent Lamps (LFLs) for general lighting purposes; – Cold Cathode Fluorescent Lamps (CCFL) and External Electrode Fluorescent Lamps (EEFL). The currently enforced and most up-to-date regulation governing mercury-added products in the Philippines is still DAO No. 2019-20 issued by the Philippine Deparment of Environment and Natural Resources (DENR) or the Chemical Control Order for Mercury and Its Compounds on 20 November 2019. Under this Order, the use of mercury, mercury compounds and mercury-added products is only strictly prohibited for artisanal and small-scale gold mining and toher related mining activities. The import, manufacture, and use of mercury-related substances is allowed in lamps, batteries, relays, switches, cosmetics, dental amalgam, medical devices, pesticides and biocides provided that the relevant parties obtained prior permits, registraions and/or clearances. The Order introduced a selective ban on certain mercury-added products from 2022 which does not cover the products mentioned in the MC-5/4 amendment. |
| India | In force | 1 January 2026: The manufacture, import and export of the mercury-added products as specifies are prohibited. 1 January 2024: The use of mercury or mercury compounds as a catalyst in acetaldehyde production is prohibited. | India ratified the UN Minamata Convention on Mercury on 18 June 2018. Rather than enacting a single standalone “Minamata Act” imposing immediate bans on mercury-added products, India made use of the flexibility mechanism under Articles 4 (products), 5 (industrial processes), and 6 (exemptions) to secure a phased transition — extending the phase-out to 2025 for Annex A products and to 2023 for the one Annex B process it registered. This formal notification by the Indian Ministry of Environment, Forest and Climate Change (MoEF&CC) registers exemptions extending the phase-out dates for certain mercury-added products (Annex A) and one mercury-using manufacturing process (Annex B). Annex A (mercury-added products) — manufacture, import, and export extended to 2025: -Batteries (except low-mercury button cells) -Switches and relays (except high-accuracy/high-frequency types) -Compact fluorescent lamps (CFLs) ≤30W exceeding 5 mg mercury -Linear fluorescent lamps (triband and halophosphate types) -High-pressure mercury vapour lamps (HPMV) -Cold cathode and external electrode fluorescent lamps (CCFL/EEFL) for displays -Cosmetics with mercury above 1 ppm (including skin-lightening products) -Pesticides, biocides, and topical antiseptics -Non-electronic measuring devices (barometers, hygrometers, manometers, thermometers, sphygmomanometers), excluding large-scale or high-precision installations Annex B (mercury-using processes) — extended to 2023: -Acetaldehyde production using mercury or mercury compounds as a catalyst (Chlor-alkali production, though listed in the template, was not registered as an exemption — it appears struck through in the original filing.) |
| Thailand | In Force (Partial) | 2 September 2025 Compliance Deadline: Factories are prohibited from using mercury and mercury compounds in the manufacturing process. | Thailand made an Article 30(5) declaration under the Minamata Convention, meaning that it shall not be subject to the deadlines laid out in amendments including MC-4/3 and MC-5/4. Instead, it has been enforcing mercury bans at its own pace. On 17 May 2024, the Thai Ministry of Industry published an announcement establishing the industrial standard TIS 3604-2566 on mercury-added product – restriction of the use of mercury, issued in accordance with the Industrial Product Standards Act. TIS 3604 applies to electrical and electronic equipment containing mercury which is specified under Table 1. On 1 September 2025, the Thai Ministry of Industry published an announcement regarding the prohibition of factories using mercury and mercury compounds in the manufacturing process. The Announcement prohibits the establishment or expansion of factories that use mercury or mercury compounds in manufacturing in accordance with the obligations established by the Minamata Convention on Mercury. Additionally, it bans the use of mercury or mercury compounds in manufacturing at factories that were operating, received a business notification, or obtained a license under the Factory Act before the announcement took effect on 2 September 2025. |
| Indonesia | Not In Force | N/A | Indonesia signed the UN Minamata Convention on Mercury on 10 October 2013 and subsequently ratified it via Law No. 11 of 2017 on 20 September 2017. To operationalize these international commitments into domestic policy, Indonesia enacted Presidential Regulation No. 21 of 2019 (Perpres 21/2019), followed closely by Ministry of Environment and Forestry Regulation No. P.81/2019 (Permen LHK P.81/2019) to establish technical implementation guidelines. This regulatory framework translates treaty obligations into a coordinated two-tiered action plan: the National Action Plan (RAN-PPM) and subnational Regional Action Plans (RAD-PPM). The two-year implementation timeline between ratification (September 2017) and the enactment of implementing regulations (2019) reflects Indonesia’s deliberate effort to meet its international obligations through comprehensive domestic legislation. The Ministerial Regulation No. P.81/2019 establishes a comprehensive national framework for mercury reduction and elimination, systematically phasing out mercury-added products and reducing mercury emissions across key industrial sectors. This regulatory instrument operationalizes the Minamata Convention at the implementation level, providing detailed procedures for technical compliance, monitoring mechanisms, and accountability structures at both national and regional levels. Sectoral Approach The regulation targets four priority sectors reflecting both international Minamata obligations and domestic concerns: -Manufacturing: Battery and lamp production undergo mercury content reduction targets, with batteries allowed a maximum of 0.0101% mercury by 2030 (50% reduction from 2018 baseline) and lamp production capped at 81.5 kg annually. -Energy: Coal-fired power plants face emission reduction requirements of approximately 33% by 2030 based on business-as-usual projections, addressing a significant but often-overlooked mercury source. -Small-Scale Gold Mining (PESK): Recognizing vulnerable populations, the regulation targets complete mercury elimination across 180 mining locations by promoting formalization, alternative technologies, and livelihood transition support. -Healthcare: The most ambitious commitment involves eliminating 21,663 units of mercury-containing medical devices (thermometers, sphygmomanometers, dental amalgam) by 2020—demonstrating health sector leadership in phase-out efforts and meeting the Convention’s healthcare mandate. Implementation Strengths The regulation establishes robust monitoring and evaluation mechanisms, requiring quarterly assessments and annual reporting through an integrated information system (Motivasi Merkuri). This institutional architecture ensures accountability and enables adaptive management across national and subnational levels. The inclusion of regional action plans recognizes that mercury sources vary geographically, allowing contextual policy responses while maintaining national consistency—a critical feature for implementing international agreements in large, diverse nations. Alignment with Minamata Convention By targeting both mercury elimination (complete phase-out) and reduction (controlled use), Indonesia’s framework reflects the Convention’s dual approach. The 2030 targets demonstrate commitment to time-bound commitments, while the emphasis on vulnerable populations—particularly artisanal miners and healthcare workers—shows recognition of equity concerns central to the Convention’s design. The regulatory progression from international signature (2013) through ratification (2017) to detailed implementing regulations (2019) demonstrates Indonesia’s systematic approach to treaty compliance. The framework thus operationalizes post-ratification obligations, translating the Minamata Convention into measurable, enforceable action plans that advance global mercury governance at the national and subnational level. |
| Malaysia | Not In Force | N/A | Malaysia signed the Minamata Convention on Mercury in 2014 but has not yet ratified it. Despite this, the country enforces restrictions on mercury-added products through multiple regulatory mechanisms, including sectoral regulations and customs laws. Key Regulations Governing Mercury-Added Products -Customs Import Ban (2024): The Customs (Prohibition of Imports) (Amendment) (No. 2) Order 2024—enacted under the Customs Act 1967 and effective June 1, 2024—established an absolute import ban on mercury thermometers and mercury sphygmomanometers by adding “Products under the Minamata Convention” to the prohibited imports list. -Medical Devices: The Medical Device Act 2012 (Act 737) empowers the Medical Device Authority (MDA) to regulate mercury-containing medical equipment. Through MDA directives, the authority is phasing out market authorization and licensing for non-compliant mercury devices, aligning with WHO recommendations and Minamata commitments. -Cosmetics and Pharmaceuticals: The Control of Drugs and Cosmetics Regulations 1984—enforced by the National Pharmaceutical Regulatory Agency (NPRA) under the Sale of Drugs Act 1952—prohibits cosmetic products containing mercury above safety thresholds. Non-compliant products face immediate bans and recall. -Waste Management: The Environmental Quality Act 1974 (EQA) designates mercury-containing waste (e.g., SW 109) as scheduled waste, requiring proper management by the Department of Environment (DOE), particularly from phase-out activities. |
Conclusion
An Uneven and Evolving Picture
With the 31 December 2026 compliance deadlines fast approaching in China, Hong Kong (China) and South Korea, implementation of the Minamata Convention’s MC-5/4 amendment across Asia remains an uneven and evolving process.
Aligned Jurisdictions, Outliers and Those Without a Timeline
Seven jurisdictions — China, Japan, Hong Kong (China), Taiwan, Singapore, South Korea and India — have adopted product phase-outs broadly aligned with the amendment, with staggered deadlines running through to 1 January 2028 and concentrated on general lighting, display components, batteries, switches and relays, and measuring instruments. Thailand and the Philippines sit outside that pattern, the former through an Article 30(5) declaration and the latter through continued reliance on a 2019 order that does not cover MC-5/4 products. Vietnam, Indonesia and Malaysia have yet to introduce any phase-out timeline, though none of these positions should be treated as settled given the implementing measures still in progress.
What This Means for Businesses
Businesses placing mercury-added products on Asian markets should therefore continue to monitor developments at both national and treaty level, and companies operating across multiple jurisdictions should be particularly mindful of divergence in scope, timing and transitional relief — such as Hong Kong’s grace period and Singapore’s allowance for pre-deadline stock — which may create additional compliance and inventory planning obligations despite the common treaty basis.
For more on Product Compliance in Asia, check out our whitepaper!
Frequently Asked Questions
- What is the MC-5/4 amendment to the Minamata Convention?
At its fifth meeting (MC-5/4), the Conference of the Parties adopted decisions to amend Parts I and II of Annex A (mercury-added products) and Part I of Annex B (manufacturing processes). Under these Annex A amendments, the Conference of the Parties established new phase-out dates across several product categories to tighten global controls. - Which Asian jurisdictions have adopted phase-outs aligned with MC-5/4?
Seven jurisdictions — China, Japan, Hong Kong (China), Taiwan, Singapore, South Korea and India — have adopted product phase-outs broadly aligned with the amendment, with staggered deadlines running through to 1 January 2028 and concentrated on general lighting, display components, batteries, switches and relays, and measuring instruments. - Which compliance deadlines are approaching first?
The 31 December 2026 compliance deadlines in China, Hong Kong (China) and South Korea are fast approaching. Across the aligned jurisdictions, staggered deadlines run through to 1 January 2028. - Why are Thailand and the Philippines treated differently?
Thailand and the Philippines sit outside the pattern of aligned phase-outs — Thailand through an Article 30(5) declaration, and the Philippines through continued reliance on a 2019 order that does not cover MC-5/4 products. - What transitional relief should companies be aware of?
Companies operating across multiple jurisdictions should be particularly mindful of divergence in scope, timing and transitional relief — such as Hong Kong’s grace period and Singapore’s allowance for pre-deadline stock — which may create additional compliance and inventory planning obligations despite the common treaty basis.

See Adherent in Action
Discover how agentic AI is reshaping product compliance for global enterprises.
Authors

Alex Li
Global Regulatory Compliance Specialist
Global regulatory compliance expert in climate change laws and regulations, including but not limited to ESG reporting, climate disclosures, and carbon footprint.

Lynn Chiam
Regulatory Compliance Specialist
Global regulatory compliance with expertise in food contact materials, transport of dangerous goods, and chemicals in products.
