Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
Hong Kong pharmaceutical compliance · applications / acquisitions / ongoing maintenance Independent Third-Party Service Provider
HONG KONG DRUG LICENSING

What specific requirements apply to personnel at a Chinese herbal medicine retail shop? Must they hold Chinese medicine practitioner qualifications?

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

Q115 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
The requirements for personnel working for a Chinese herbal medicine retailer differ from those for a Western medicine pharmacy. There is no mandatory requirement to have a registered Chinese medicine practitioner on the premises. However, the law requires one person to be responsible for supervising the business at a Chinese herbal medicine retail shop. This supervisor must have specific knowledge and experience in Chinese herbal medicines. Under the requirements of the Chinese Medicine Council of Hong Kong, the person must meet one of the following conditions: 1) be a registered or listed Chinese medicine practitioner; 2) have successfully completed a training course in retail of Chinese herbal medicines recognised by the Chinese Medicine Council of Hong Kong; or 3) have engaged continuously in the retail of Chinese herbal medicines for at least 10 years before the Chinese Medicine Ordinance came into effect. This means that a person who is not a Chinese medicine practitioner may still qualify as a supervisor by completing a recognised training course and obtaining a certificate.

📘 Regulatory basis

Section 115 of the Chinese Medicine Ordinance (Cap. 549) and the Chinese Medicines Regulation set out in detail the qualification requirements for supervising personnel of retailers of Chinese herbal medicines. These are key areas for licensing and routine inspections by the Chinese Medicines Board.

📗 Drew Tang's recommendations

For a newly opened retail Chinese herbal medicine shop, the most direct and effective approach is to arrange for one or more key employees to attend a training course recognised by the Chinese Medicine Council of Hong Kong. These courses are usually provided by local universities or professional institutions. We will provide clients with the latest course information and assist employees with enrolment to ensure that they obtain the necessary qualifications before the business opens.

📕 Risk notice

Do not assume that hiring any long-serving employee will satisfy the requirements. If the employee cannot provide legally required proof of qualifications (such as Chinese medicine practitioner registration, training certificates or evidence of sufficient years of experience), the shop may face a fine or even suspension of operations until a suitably qualified person is hired, if this is discovered by an inspector of the Chinese Medicines Board.

Back to Category C: Applicant Eligibility and Personnel Requirements (Q101-Q150) Search more questions

YOUR NEXT STEP

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.

Book a Project Assessment ↗