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What is the “Authorised Person” (AP) system? What are the AP’s responsibilities in an application for a pharmaceutical wholesaler licence?

A complete explanation of the regulatory basis, Drew Tang’s recommendations and risk alerts. The original material dates from 2025; read it alongside the latest official requirements.

Original guide, 2025 edition: These FAQs are provided for topic-based reference and have not all been individually checked against current rules. Please confirm fees, personnel, renewal, changes and product requirements against the professional in-depth guide for the relevant licence type and the official requirements in force at the time.

Drug Office, Department of Health Chinese Medicines Board

Q103 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
The “Authorised Person” (AP) system is a key element in ensuring the safety and quality of the medicine supply chain. For a pharmaceutical wholesaler, the AP is a staff member formally authorised in writing by the licensee to oversee and manage all activities relating to the procurement, storage, sale and distribution of medicines. The AP must ensure that all operations comply with the Pharmacy and Poisons Ordinance and Good Distribution Practice (GDP). Core responsibilities include approving and managing suppliers and customers, ensuring that medicines are from lawful sources, overseeing medicine storage conditions, handling customer complaints and medicine recalls, and maintaining complete distribution records. The AP is one of the company’s main contacts for communication with the Drug Office and bears significant responsibility for licence compliance.

📘 Regulatory basis

The Code of Practice for Holder of Wholesale Dealer Licence sets out in detail the role, responsibilities and qualification requirements of the Authorised Person. The AP’s appointment and qualifications are key areas reviewed by the Drug Office.

📗 Drew Tang's recommendations

An AP does not necessarily have to be a pharmacist, but must have relevant industry experience and knowledge of medicines. We generally recommend appointing a senior employee with at least 3–5 years' experience in pharmaceutical distribution or quality management. Clearly setting out the AP's qualifications and division of responsibilities in the application documents is crucial.

📕 Risk notice

If an AP fails to perform their duties effectively—for example, by failing to prevent counterfeit or unregistered medicines from entering the supply chain—the company may face serious legal consequences, including fines and licence revocation, and the relevant persons in charge may even face criminal prosecution. An AP's failure to discharge their duties is one of the greatest compliance risks for a licence holder.

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