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HONG KONG DRUG LICENSING

What qualifications are required of staff when applying for a “Listed Seller of Poisons” licence (for example, to sell medicines in a convenience store or supermarket)?

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

Q110 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
An LSP licence allows businesses such as convenience stores, supermarkets and personal care shops to sell Part II poisons (commonly called “P2 medicines”, such as some painkillers and cold medicines). The legal qualification requirements for sales staff are relatively less stringent, but there are clear rules. First, staff selling these medicines must be at least 18 years old. Second, and most importantly, the licence holder must ensure that all staff responsible for selling Part II poisons have received appropriate training. Training should cover how to identify Part II poisons, understand the legal restrictions on their sale (such as not selling them to anyone under 18), store the medicines, and advise customers to seek professional advice from a pharmacist or doctor when they make enquiries. The licence holder must keep all relevant staff training records for inspection by Drug Office inspectors at any time.

📘 Regulatory basis

Section 19 of the Pharmacy and Poisons Regulations (Cap. 138A) provides that persons selling Part II poisons must be at least 18 years old. The Code of Practice for Listed Sellers of Poisons further requires licence holders to provide staff with adequate training and keep records.

📗 Drew Tang's recommendations

We recommend that clients establish standardised training procedures and a manual for employees. Training should be conducted at least annually, with induction training for new employees. We will assist clients in designing training materials covering medicine classification, key sales considerations, legal responsibilities and emergency response, and provide training record templates. RGYS may assist with document preparation and project coordination within the written scope of services; the respective responsible parties must verify personnel qualifications and statutory roles and take responsibility for professional judgements, while approval is determined independently by the competent authority.

📕 Risk notice

If a Drug Office inspector finds during an inspection that shop staff know nothing about the legal requirements for the medicines they sell, or that the licence holder cannot produce any staff training records, this will be regarded as a serious breach. The regulator may fine the shop or even temporarily suspend its eligibility to sell the medicines concerned.

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