Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

When applying for a pharmacy licence, can the shop's legal representative (company director) and the pharmacist on the premises be the same person?

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

Q122 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
Yes. The law does not prohibit the owner of a pharmacy (that is, a company director or shareholder) from also serving as the pharmacy’s resident registered pharmacist, provided that person is themselves a qualified registered pharmacist in Hong Kong. In fact, this is very common in Hong Kong, where many community pharmacies are established and operated by pharmacists themselves. This ‘pharmacist-owner’ model may even be considered ideal, as it ensures that the pharmacy’s highest decision-maker has the most relevant pharmaceutical knowledge and a strong compliance mindset. In this situation, the pharmacist holds two roles: as a company director, they are responsible for the company’s overall operations and finances; as the pharmacist-in-charge of sales, they personally supervise the pharmacy’s medicines management and sales activities.

📘 Regulatory basis

Neither the Pharmacy and Poisons Ordinance nor the Companies Ordinance prohibits this arrangement. The individual’s dual role is entirely lawful, provided they meet the statutory requirements for a company director and the professional requirements for a registered pharmacist.

📗 Drew Tang's recommendations

For pharmacists wishing to start their own business, this is an excellent option. We can assist them through the entire process, from company registration and finding premises to shop design and fitting-out (ensuring it meets pharmacy standards) and submission of the Pharmacy licence application, allowing them to focus on their profession and successfully launch their own business.

📕 Risk notice

In this arrangement, the pharmacist needs to distinguish clearly between their two roles. As a director, they handle business operations; as a pharmacist, they must strictly observe the professional code of conduct. They must not become less diligent in the sale and management of pharmaceutical products just because it is “their own business”. Regulatory authorities apply the same inspection standards to everyone.

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