Seat Belts ( see the law here )
If you intend to import your car and it was originally registered as a 4 seater in the country of origin ( a good example being the UK ), then be aware that the car MUST be fitted with rear seatbelts if it is to be registered as a 4 seater here in Hong Kong. This law came into effect on the 1st June 1996 and the Hong Kong Government when enacting the law did not appear to consider the impact that this would have on the first registration of classic cars in Hong Kong.....
The seat belts and seat belt anchorage points must comply with the provisions of the Road Traffic (Safety Equipment) Regulations, Cap. 374F. All seat belts must be permanently marked with a specification number, mark or symbol indicating compliance with the standards listed in the regulations.
Seatbelts are not required by law in Hong Kong to be fitted in the FRONT of a private car manufactured before 30 June 1964. What !! you say...why allow a classic car not to have seat belts in the front but require them in the back ?? Well, this is all to do with LEGCO ( the Legislative Council...i.e. the Government. ). Unfortunately the people that sit in LEGCO dont know much about classic cars and when legislation was being debated, nobody thought about what might happen one the law was enacted. The law has not been changed or modified much since and it does not appear to be a priority matter of discussion these days and so it is unlikely the law will change in the future !
So, to recap, seat belts are required to be fitted in the back of a car that is registered in Hong Kong after 1st June 1996 ( assuming you are going to regsier your car as a 4 seater ). If your 4 seater car arrives for its Government Inspection and is not fitted in the back with seat belts, then it can only be registered as a 2 seater, and providing the rear seats have been removed from the car for the inspection. If you do not have seat belts fitted in the back and have not removed the rear seats then the Government Inspector will merrily slap a fail notice on the Inspection form.
Lets say that you put the car in for its inspection with the rear seat removed, and the car swept through with a pass and it is registered as a two seater..... DO NOT consider putting the seats back into the rear of the car after it is registered as this will be illegal, and you will face all kinds of problems if you are stopped by the Police, especially as the rear of the car wont even have seat belts fitted ! This is all completely nuts, but this is how things work in Hong Kong and we all have to abide by the rule of law. If you want to change the car to a 4 seater registration later on then you have to go through the ballache of the whole examination process again.
To complicate matters further, you cannot simply bolt seat belts into the back of a classic car, cruise in for the Government Inspection and expect the inspector to rubber stamp your fabulous drilling and bolting skills. The chief honcho down at the Inspection Centre is no fool. He is well experienced with these kind of matters and he has an almost perfect memory of almost every right hand car ever produced...( some say....even before prehistoric times ). He is well aware if a car was supposed to be fitted with rear seat belts or not. In many cases the cars are so old that seat belts were never fitted, and as such, seat belt mounting points were never built into the car or even designed to be fitted with rear seat belts.
Ah....do I hear you sigh and mutter "well, the car was fitted with rear seat belts back in the UK, and it passed an MOT every year with no issues." Indeed this is the case, however Hong Kong is reportidly the safest place in the world to live ( despite questionable mainland vehicles bombing backwards and forwards over the HK / Mainland border ever day ). So being the safest place in the world, the MOT requirements of places like the UK are just not up to Hong Kong standards....cough cough.........
Oh, you havent fallen asleap yet.....very good....so lets get to the nitty gritty of seat belts....
If seat belts are fitted ( as many are ), then when you deliver your car for its first Government Examination, you will need to prove two things :
1. That the seat belt mounting points comply with BS AU48:1965 / BS AU48a.
2. That the seat belts themselves have the E4 mark on them and are not damaged in any way.
This is where it can all get tricky and lead to a lot of frustration ( if you are not already ripping the hair out of your head and jumping off every wall in the building ).
Firstly, the seatbelts should be compliant anyway as you should have bought them from a reputable seat belt manufacturer and they will be labelled with all the correct labels. Here is an example of how the labelling should look. If not, then tut tut....you should not have saved the £50 buying them from Arthur Daley....and in any case, who buys seat belts from stange old men in fur coats ??
Secondly, be well prepared for the examiners inspection of the seat belt mounting points. He will look for one of the following :
- An authentic original rivetted identification plate located somewhere on the chassis that identifies the chassis number of the car and states that the seat belt mounting points comply with the required standard. Now lets get this point straight...although BS AU48:1965 / BS AU48a kicked in during 1965, many cars produced before 1965 may today have seat belt mounting points identification plates located on the chassis. This is because many owners back in the days when seat belts were initially being fitted took their cars into main dealers to have seat belts retro fitted. It was common practice back then for the seat belt identification plates to be fitted by the main dealers when the seat belts were being installed.
This is a fabulous stroke of luck because if you are taking your car for an examination, it is pre 1965 and is a four seater....and is fitted with seat belts and has a genuine rivitted identification plate on the chassis, then this proves that the rear seat belt mounting points comply with BS AU48:1965 / BS AU48a. Unfortunately, if your car was not retro fitted with seat belts by a main dealer post 1965, then you have to go down this next route...
- A letter from the Commissioner for Transport of the Hong Kong Transport Department authorising that the seat belt mounting points are considered acceptable to the Transport Department. "What"...I hear you say...."how the monkeys am I going to get a letter saying that ?". Well, this route may ( and I know from personal experience ) does involve drinking a lot of coffee in a meeting room at the Transport Department in Admiralty with a team of senior Transport Department staff. Im not entirely convinced that it is the coffee that solves the issue....its more about how many times you have to go back to see the staff "cap in hand" with documentation to prove that your beloved little cherub ( im still talking about your classic car..... ) complies with BS AU48:1965 / BS AU48a.
The first document that the Transport Department staff will ask for is a test certificate carried out by a qualified engineer proving that the car has passed a crash test with the seat belts fitted in the back of the car. Lets get two things straight at this point......when the Government asks for a qualified engineers report, he is not talking about "Bob the Job" that works done at Harry's backstreet garage, or the very nice ( and most reasonably priced Mr Zhong ) who is very good at bashing bits of metal together just off Queen's Road East....nooooooo. They require someone with a Hong Kong engineers qualification....and as we all know that means the invoice is going to have lots of numbers on it and is a legitimate way to get legally ripped off.
"Hang on....." I hear you say..."if the car is crash tested, then its not much use afterwards". Wow...you are smart...but look on the bright side...you will have a lovely crisp certifcate evidencing that your seat belts passed the crash test and the mounting points were satisfactory...oh, I see your point....this is another totally illogical requirement by the Transport Department. In theory, you could get the crash test done on another car of same type and year and this would then become a form of "Type Approval", and then all classic cars of that type can present the blanket certificate to prove the seat belt mounting points comply. Unfortunately, that is not feasible as nobody is inclined to spend the HK$35,000 for the testing and some of the classics brought into Hong Kong are worth more than Rumpel Stiltskins solid golden dooberries...
Another method advised by the Transport Department is to get hold of a letter from the manufacturer stating that the rear seat belt mounting points do comply with the standard. In theory thats a great. In practice, its almost impossible as many of the original car manufactureres have merged, have gone bust or have simply been sold off to Mainland Chinese or Indian Companies. Getting anyone to reply to a request about a 50 year old car net alone knowing anything about it is as likely as waking up tomorrow and finding Central Hong Kong under two feet of snow.....or better still being able to buy Kenco Coffee in Park n Shop.....OK...so in theory, snow is possible if we hit another ice age, but Kenco coffee.....???
What you may be able to do is get a letter from the Owners Club of the car that you are importing from that country. It is not uncommon to be able to get copies of old manufacturing drawings showing the mounting points for retro-fitting of rear seat belts. This may well be your best option if you dont already have the original seat belt mounting points rivet plate on your chassis.
Oh no......there is something else....the Inspector will ask who it was that fitted the seat belts. Unless you are a qualified engineer, please refer to the seat belt manufacturer for a letter confirming that the seat belts have been fitted in accordance with the manufacturers instructions. You will generally find that most of the classic seat belt manufacturers are small scale quality businesses that if you provide them with photographs of the seat belt mounting points and the finished installation of the belts that they supplied will provide a letter for the purposes of satisfying the Transport Department.
Once you have submitted all your documents to the Transport Department, and have drunk them dry of coffee and have been to see a shrink due to the immense number of times that you wake up during the night screaming the words "seat belt", you will be happy to know that a letter should ( and I say SHOULD ) be issued. Here is an example of such a letter.
The Transport Department take a fairly dim view on the modification of the braking system of a classic car, or in fact any car for that matter and it is illegal to go modifying the braking system of any car without the prior approval of the Transport Department once the car is registered. When we talk about modification, we mean for example.... changing front drums into a disc brake set up. As we all know, Hong Kong is one hell of a hot place in the summer and drum type brakes are not members of the 'Hong Kong Bikini Fan Club'. In fact, drum type brakes suffer from something called 'brake fade' that is brought on by heat.
As Hong Kong is a fairly hilly place, you should be able to BBQ sausages and fry eggs on your brake drums after just a short journey. Despite the distinct advantages of turning your beloved classic into a part time BBQ grill, the problems associated with brake fade are quite serious and those pesky taxi things can make matters worse when they gate crash in to your lane without indicating and without giving more room that a brick up a rabbits back side.
So its understandable that many classic cars will already be retro fitted with uprated braking systems before they arrive in Hong Kong.
The Government Inspector will remind you of what an incredibly safe place Hong Kong is and suggest that the upgraded braking system may in fact be dangerous for two reasons :
1. The car might stop too quickly ( i.e stop faster than it was originally intended to do so ).
2. The car may fall to bits over time due to metal fatigue of the chassis mounting points of the suspension etc that are directly connected to the upgraded disk brake system.
There is some validity to the above as you cannot simply bolt vented disk brake systems onto a car that was never designed to stop so efficiently. That said, fitting a disc brake system to your classic is not actually going to make it stop faster. Drum brakes ( if adjusted correctly ) will stop your car just as well as discs, but discs wont suffer from the brake fade, and they require no adjustment during the life of the brake pads.
So you will yet again, require more paperwork from the company that put the kit together to state that the brake upgrade is a common upgrade used throught the industry for the type of car that it is being fitted to and that it has been regared as a safe and sensible option by the Owners Club in the country of manufacture for the past XXX years. If your brakes were fitted by a classic car specialist then a letter from them will also help. Did I mention that the Transport Department love paperwork ? Oh yes, they have telephones in their offices too so make sure that the company that supplies the letters will be happy to speak with a member of the Transport Department staff if they do want to follow up the paperwork..
Before we move on, and whilst on the subject of the brakes....there are three more points that you must be aware of :
1. The Government Inspector very much likes steel brake pipes. He does not like copper brakes. However.....copper brake pipes are widely used on classic cars internationally and strictly speaking the Transport Department cannot fail a car because it has copper brake pipes. What they will do is rub a screwriver or similar over the pipe surface to determine how soft the copper is. I think this is more to scare the hell out of you ( dont worry, there is a public loo in the testing centre waiting room.....but take your own loo paper ). Kunifer is also preferred over copper, but they do have a thing about steel !
2. Most ( if not all properly old ) classic cars are fitted with single braking line systems. Unlike modern day braking systems, if a brake pipe fails, a cylinder cracks open or a joint fails, then you know about it pretty fast...and thats not the best news whilst doing 80km through the Cross Harbour Tunnel with Mr Taxi Man popping his brakes in front of you every two seconds. In fact it can be rather an exciting experience. This means the use of the hand brake....but when you pull up the hand brake, the brake lights will not come on and the car behind you wont know you are stopping ( well he will, once he has stamped the words "Toyota" on your boot lid ). It is common for the Inspector to require that a switch menchanism be fitted to the hand brake lever so that when the hand brake is pulled up, the brake lights come on. Ive heard some say that this was not insisted on during an inspection, but I have experience of it being a requirement, so be aware....Its a simple thing to do and switches are easily purchased in electrical shops in Hong Kong...
3. Brake fluid leaks. If you have EVER had a leak in the brake system and have had it all fixed for the Inspection, be prepared for the inspector to fail the car because there is "evidence" of a brake system leak. In fact, the Government Inspector could be innocently mistaken for Inspector Clouseau due to the level of detail he will go to checking every pipe, every joint, every TYRE and and ever bit of metal under the car looking for evidence of brake fluid...and when I say evidence...it can be just an old stain on the side of a tyre. Make sure that if there was a drip at one time on a tyre or on the chassis that it has been removed in its entirety such that a bright light or even a DNA test will not detect anything.
Im not going to get into raunchy subject of upgraded suspension as it follows the same lines as the Braking System, so be aware !
Windscreens and Glass
OK, so your windscreen looks lovely. Its nice and clean and has no cracks or damage, you have polished it to perfection and the windows wind up and down a treat. Unfortunately the Government Inspector does not give a monkeys about how lovely your glass looks. He will look specifically for a marking on each and EVERY piece of glass that complies with the Specification of Safety Glass ( Chapter 374H...see a copy here ). The marking typically may say BS 857, BS 5282, BS AU 178 or ECE 43. Here is an Example.
If you have replaced a panel of glass on your car before it is shipped to Hong Kong, then please be sure to check that it has the markings on it to comply with the Hong Kong regulations. Some pieces of old glass may not have the markings and you can get the glass etched by a professional etching company before you have your car shipped over.
Emmissions and Noise
Providing your car is compliant with regulations 7 and 14 of the Air Pollution Control ( Vehicle Design Standards ) Regulation and Noise Control ( Motor Vehicles ) Regulation, then all you need to do is make an application for an exemption letter from the Environmental Protection Department Headquarters. They are based at 33/F, Revenue Tower, 5 Gloucester Rd, Wanchai. Have a butchers at the regulation here. If like many people, you are totally confused and wish to be made even more confused by chatting with a member of the Government, then feel free to call:
( 852 ) 2877 0448 ( Exhaust emission )
( 852 ) 2411 9665 ( Noise emission )
Basically all modern day cars have got to comply with Regs 7 and 14 so that they dont pollute the delicately beautiful and fresh air of Hong Kong and they dont cause deafness to pedestrians walking along the pavements or indeed the passengers within. By side stepping this required test, you are being given consent to chuff as much smog as you like from your delightful classic car and for it to make as much racket as it was originally intended.
The vehicle seeking exemption must be manufactured at least twenty (20) years before the date of application and the engine must be the ORIGINAL ENGINE AND POWERED BY PETROL ONLY. If the engine numbers dont match up with the original registration documents ( i.e. a replacement engine has at some point been fitted ), then you are screwed. Best make sure the number tie up properly !
Here is the form you need to fill in ( good as of April 2015 ) to get the exemption from both emmissions and noise ( look at page Annex 3 ). It is advisable to get this done before you ship the car as it can take several weeks for the form to be processed.
Here is an example of the letter of exemption that you will receive.
Dripping oil from your engine, gearbox and rear axle does not seem to be much of an issue in places like the UK during MOT examinations, and its not much of a bother anywhere else in the UK too unless of course you have just installed a lovely new tarmac driveway, in which case it will rip a hole in it in no time at all and you will wish you had never bought a classic car.
Here in Hong Kong, dripping oil is a 'no no' for the Examiner at the Government Testing Centre. If he finds a drip, then he will fail your car. Check it carefully beforehand, and if you are not sure if it will hold all its oil long enough for the day of the examination ( esecially A series engines that are notorious at dripping ), then take a rag with you and wipe its arse just before it goes in for the test.
The Vehicle Examination
The inital examination of cars imported into Hong Kong will need to be done at an actual Government Vehicle Testing Centre. Getting appointments can be a pain and take a long time. I have already been through some of the key points that the examiner will look for so im not going through that all again.
Here is the address to make your booking for the test and you can even call them up and speak with the Examiner there as he is very helpful and speaks superb English :
To Kwa Wan Vehicle Examination Centre
Long Yuet Street
Tel : 2333 3112
You MUST bring along with the approval letter of exemption issued by the Environmental Protection Department for making the appointment of vehicle
examination at the Examination Centre.
One thing you cannot do is drive the car down to the Government Inspection yourself unless you have trade plates. You are not likley to have trade plates unless you are a motor trader or garage here in HK, so the only other way to take the car down for its examination is on the back of a truck....and yes, that will cost a sack more dosh. Dont chance it and drive it there yourself as you will get caught by some smart young cop sitting on a shiney police motorcycle with fancy airforce issue eyewear and he will take great pleasure in slapping you with a ticket. Its not a lot of fun standing before a judge in Hong Kong trying to explain how you didnt quite undertsand the ins and outs of Hong Kong law, and I can assure you they dont have much of a sense of humor either....and that goes for both Chinese or Western Judges here in Hong Kong !
Dont expect your car to pass first time, as the Examiner is one tough cookie. The long and short of it, is that its his job is on the line, and in Hong Kong, these kind of things can be very political. He wants to be absolutely sure that the letter of the law has been followed during his Examination.....that said, when you take your car for subsequent MOT's at regular MOT testing stations afterwards, its quite shocking at what does get passed....and that's another story that im not going to get into now.
Here is an example of a Test Sheet issued by the Examiner at the Government Testing Centre.
First Registration Tax
Well things are really looking grand now.....you have your pile of certificates and letters of approval and you have passed your vehicle examination....sorry, what s that I hear you say... "how much tax do I have to pay" ?...Oh yes, you have to pay a First Registration Tax on your vehicle. It works differently to otehr countries like the UK where you simply pay VAT on import. In Hong Kong you pay the tax when you register the car....and boy can that be expensive, unless of course the car is not worth much.
Many of the classic cars imported into Hong Kong are seriously expensive compensations for a part on the male anatomy that may be on the rather....lets say "small side". OK, thats a rather unfair remark because the kind of people that bring these 'supercar classics' into Hong Kong are so loaded with money that an airbus A380 would not take off if packed with the actual individuals wealth in cool hard cash. So chances are that if you see some old bloke driving around Hong Kong in a fancy red E Type, then he most likely owns one of those fancy little palm free islands in Dubai.
OK, enough about the rich, colourful and infamous in Hong Kong....lets get down to the business of first registration tax......
In general, the first registration tax of vehicle will be derived from the taxable value times the appropriate tax rates as shown below:
Class of Motor Vehicle Rate of Tax
I. Private cars
(a) on the first $150,000 40%
(b) on the next $150,000 75%
(c) on the next $200,000 100%
(d) on the remainder 115%
There are deductions from the above depending on how long you have owned the car.
When applying for first registration and licensing of a vehicle, you should complete an application form (TD22) and submit it to the following office together with the documents listed below :
Hong Kong Licensing Office
3/F United Centre
Tel : 2804 2636
Documents required :
TD22 Form ( here it is ). If you download and use this form, then make sure that you print it out on both sides of the paper as the Licensing office WILL NOT accept two pieces of paper.....please...stop groaning will you !
(a) Invoice or payment receipt of vehicle manufacturer or car distributor. This proves the vehicle ownership, and the date and price of purchase.
(b) Original vehicle registration document and / or shipping document. This helps to prove the ownership of the vehicle that was registered outside of Hong Kong and helps in verifying the particulars of the vehicle. In recent times, the requirement has also included the need for a respective document proving permanent export for used vehicles imported from the U.K. or Japan. This is generally known as a Certificate of Permanent Export
from the U.K. or Japan that proves that the registration has been cancelled in that country. This was never required in the past but is now stated on formal documents required by the Licensing Office.
(c) Applicant’s Hong Kong identity card. This is to prove the identity of the applicant.
(d) Third party risks insurance certificate or cover note. This is to prove the vehicle under licensing fulfills the requirements laid down in the Motor Vehicles Insurance (Third Party Risks) Ordinance. And to get this, you will need to join The Classic Car Club of Hong Kong as ordinary insurance companies in Hong Kong will refuse to insure a classic car.
(e) Certificate of Roadworthiness issued by the Transport Department. This is proof of compliance with the engineering standards in the Road Traffic ( Construction and Maintenance of Vehicles ) Regulations, Road Traffic (Safety Equipment) Regulations, the exhaust emission and noise emission standards in the Air Pollution Control (Vehicle Design Standards) (Emission) Regulations and Noise Control (Motor Vehicles) Regulation.
(f) Notification of Motor Vehicle Provisional Taxable Value issued by the Customs and Excise Department and/or other relevant documentary
proof in connection with vehicle taxation which may be required. This is to prove the taxable value of the vehicle and the retail prices of accessories necessary for the calculation of first registration tax. You can in fact make an application to Customs and Excise before applying for the first registration so that you can agree the value of the car for taxation purposes. This is the best way forward.
After you have coughed up all your hard earned money in bringing the car into Hong Kong and taking it through the rigmorol of all the above to get it on the road, you will be issued with a lovely piece of paper that you will have to shove in the left hand side of your windscreen.
Now, all the above is provided from my own knowledge of the system in Hong Kong from my own experience of importing my own car into Hong Kong. Please DO NOT hang me for getting anything wrong as things do change over time and it was a few years since I brought my car into Hong Kong. If you know of any changes or other points that should be included in the above desction, then please let me know and I will put it right.
Some Helpful Documents :
This Information Sheet is summary of import procedures issued by the Government of Hong Kong.