Q106 · When applying for a pharmacy licence…

Q106 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)

Yes, this is an absolute requirement. Under Hong Kong law, any entity wishing to operate a pharmacy (that is, an “Authorised Seller of Poisons (ASP)”) must employ at least one Hong Kong registered pharmacist. The pharmacist is not merely an employee, but the pharmacy’s “superintendent pharmacist”, personally supervising its day-to-day operations and medicine sales. This means the pharmacist must be present at the pharmacy during its business hours, personally handle and check doctors’ prescriptions, and supervise the sale of all controlled medicines (Part I poisons). The pharmacist’s name and registration certificate must be displayed prominently in the pharmacy. Inspectors from the Drug Office conduct unannounced inspections to ensure that the pharmacist is on duty.

📘 Regulatory basis

Section 3 of the Pharmacy and Poisons Regulations (Cap. 138A) expressly provides that the business of an Authorised Seller of Poisons must be “personally managed and conducted at the relevant premises” by a registered pharmacist. This is the Pharmacy Licence’s most fundamental statutory requirement.

📗 Drew Tang's recommendations

When preparing to open a pharmacy, recruiting a suitable registered pharmacist should be your top priority. The pharmacist's employment contract should clearly specify their responsibilities as the “pharmacist supervising the sale of poisons” and their hours of attendance at the pharmacy. RGYS may assist with organising roles, qualification evidence and responsibility arrangements within the written scope; candidate suitability, appointment and actual attendance in the role must still be verified by the applicant and legally qualified personnel. No provision of personnel or certification is promised. RGYS may assist with organising roles, qualification evidence and responsibility arrangements within the written scope; candidate suitability, appointment and actual attendance in the role must still be verified by the applicant and legally qualified personnel. No provision of personnel or certification is promised. We also ensure that their qualifications meet regulatory requirements.

📕 Risk notice

The so-called ‘nominal appointment’ of a pharmacist—where a pharmacist is merely listed but does not actually supervise the pharmacy on site—is a serious offence. If discovered by the Drug Office, this may result in the pharmacy licence being revoked immediately. The pharmacist concerned may also face disciplinary proceedings and could have their registration suspended or cancelled. Both the operator and the pharmacist may face criminal prosecution.

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

When applying for a pharmacy licence (Authorised Seller of Poisons), is it necessary to employ a full-time registered pharmacist?

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang