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

What is a “Drug Surveillance System”? Does a company applying for a wholesale licence need to have one?

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

Q123 · Category C: Applicant eligibility and personnel requirements (Q101–Q150)
A drug monitoring system, also known as a pharmacovigilance system, is a system for detecting, assessing, understanding and preventing adverse drug reactions (ADRs) and other medicine-related problems. For a medicine wholesaler, establishing and maintaining an effective drug monitoring system is part of its licence responsibilities. Although it may be less complex than a manufacturer’s system, a wholesaler’s system should include at least the following: 1) designated staff responsible for receiving and handling ADR reports from customers such as hospitals, pharmacies and doctors; 2) standard operating procedures (SOPs) for recording, assessing and promptly reporting received ADR information to the medicine manufacturer and the Drug Office, Department of Health; 3) the ability to assist manufacturers with medicine recalls; and 4) retention of all relevant records.

📘 Regulatory basis

The Code of Practice for Holder of Wholesale Dealer Licence expressly requires licensees to establish procedures for handling customer complaints and medicine recalls. Pharmacovigilance is a core component of these procedures.

📗 Drew Tang's recommendations

When applying for a licence, we will help clients draft a complete pharmacovigilance SOP. This document needs to define clearly the reporting process, responsible personnel, time limits and record-keeping requirements. Being able to demonstrate a clear, workable pharmacovigilance system during a Drug Office site inspection will make a highly professional impression on the inspector.

📕 Risk notice

An effective pharmacovigilance system is an important part of the medicine safety net. If a wholesaler fails to establish such a system or implement it effectively, resulting in a serious adverse reaction not being reported promptly and necessary intervention, such as a medicine recall, being delayed, the company will face extremely serious legal and reputational risks.

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