Article Summary
UBHIU (Universal Beauty and Health Industry Union) and IQA (International Qualifications Assessment Alliance) formally submitted a joint consultation submission on 25 July 2026 regarding Hong Kong's Trade Descriptions Ordinance prepaid consumption amendment. The submission covers six key recommendations: raising the service fee cap from 150% to 200%, opposing inclusion in the Organized and Serious Crimes Ordinance, clearer legal definitions (Section 5.4 "same service" ambiguity), cooling-off period exemptions for special circumstances with 14 working days refund, SME support with monetary thresholds and a 48-month transition period, and an anti-abuse reporting mechanism. The submission supports reasonable regulation for industry health while urging the government to consider frontline realities and avoid a one-size-fits-all approach that disproportionately impacts compliant SMEs.
Key Points at a Glance
‧ UBHIU and IQA formally submitted a joint consultation submission on 25 July 2026 to CEDB, Hong Kong Customs, and the Legislative Council.‧ Six key recommendations: service fee cap raised to 200%, oppose inclusion in Organized and Serious Crimes Ordinance, clearer legal definitions, cooling-off exemptions, SME transition support, and anti-abuse mechanisms.
‧ Support the government's efforts to combat unfair sales practices and regulate prepaid consumption – reasonable regulation benefits long-term industry health.
‧ Recommend raising the service fee cap from 150% to 200% to reflect actual operating costs.
‧ Oppose including relevant provisions in the Organized and Serious Crimes Ordinance – existing penalties are sufficient.
‧ Recommend exemption clauses for serious illness, disability, and other special circumstances; extend refund period to 14 working days.
‧ Recommend establishing monetary thresholds, a 48-month transition period, and grandfather clauses to ease SME compliance burden.
Hong Kong Trade Descriptions Ordinance
Prepayment Consumption Public Consultation
UBHIU and IQA Submit Joint Industry Response
Universal Beauty & Health Industry Union (UBHIU) ｜ International Qualifications Alliance (IQA) ｜ LBEDU Sparkle Beauty International Education & Training Academy
In June 2026, the Hong Kong Commerce and Economic Development Bureau launched a public consultation on amendments to the Trade Descriptions Ordinance regarding prepayment consumption, proposing the introduction of statutory cooling-off periods and contract term regulations for the beauty and fitness industries.
The Universal Beauty & Health Industry Union (UBHIU), together with the International Qualifications Alliance (IQA) and LBEDU Sparkle Beauty International Education & Training Academy, has consolidated practical feedback from member organisations and frontline practitioners. A joint submission was formally submitted to the Commerce and Economic Development Bureau, Hong Kong Customs, and the Legislative Council on 25 July 2026.
UBHIU and IQA formally submit joint response to the Trade Descriptions Ordinance Prepayment Consultation
Our Core Position
Support the government in cracking down on malpractices and regulating prepayment consumption, acknowledging that reasonable regulation contributes to the long-term healthy development of the industry
Believe that certain provisions in the current consultation paper are disconnected from frontline operational realities, and recommend refinements to avoid a one-size-fits-all approach that would impact legitimate SMEs
Industry representatives actively participate in the prepayment consultation, advocating for policies that reflect operational realities
Six Key Recommendations (Summary)
Full论述, data support and legal reasoning available in the PDF submission
Service Deduction Cap
Recommend relaxing the cap from 150% to 200% to cover actual operational costs
Enforcement Powers
Oppose inclusion under the Organised and Serious Crimes Ordinance; existing penalties are sufficient
Clarity of Provisions
Clause 5.4 on "same services" is vague; recommend issuing scenario-based implementation guidelines
Cooling-Off Mechanism
Add exemption clauses for serious illness, disability, and other exceptional circumstances; extend refund period to 14 working days
SME Support Measures
Establish monetary thresholds, 48-month transition period, and grandfather clauses to ease compliance burdens
Anti-Abuse Mechanism
Establish reporting channels for malicious cancellations to protect legitimate rights of frontline staff and businesses
The beauty industry looks forward to reasonable regulation that protects frontline practitioners and SMEs
Download Full Submission (PDF)
UBHIU × IQA Submission on Trade Descriptions Ordinance Prepayment Consultation (PDF)
Frequently Asked Questions
Q: Does this submission represent the entire beauty industry? A: No. This submission represents the position of UBHIU, IQA, the Academy, and over 100 partner beauty establishments. Other industry groups will also submit their own recommendations.
Q: When is the cooling-off period expected to take effect? A: The public consultation runs until 31 August 2026, followed by LegCo review. The industry generally expects implementation within 12-18 months.
Q: Where can I access the full submission? A: The complete submission has been compiled as a PDF document, available for download via the button above.
For any enquiries regarding the content, or to learn more about industry policy developments, please contact the IQA Secretariat.