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As a registered pharmacist, may I serve as the “supervising pharmacist” at several different pharmacies at the same time?

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

Q129 · Category C: Eligibility and Personnel Requirements (Q101-Q150)
No. Under the law, a registered pharmacist may personally manage and operate the business at the premises of only one Authorised Seller of Poisons (pharmacy) at any one time. This means that you cannot be named as the “pharmacist-in-charge” of two or more pharmacies simultaneously. The intent of the legislation is to ensure that the sale of medicines at each pharmacy is subject to the focused, continuous personal supervision of a pharmacist. If you wish to work at multiple pharmacies, you may work shifts at different pharmacies as an ordinary locum pharmacist, but in legal terms each pharmacy must have exactly one designated pharmacist-in-charge who bears ultimate responsibility for supervision.

📘 Regulatory basis

Section 3 of the Pharmacy and Poisons Regulations (Cap. 138A) requires the business of a pharmacy to be “personally managed and conducted” by a registered pharmacist. The Pharmacy and Poisons Board’s Code of Practice further clarifies that this supervisory responsibility is exclusive and cannot be discharged at multiple locations at the same time.

📗 Drew Tang's recommendations

For pharmacy operators seeking to expand their business, this means that each new branch must have a new, full-time supervising pharmacist. When developing expansion plans, the human resource costs and challenges of recruiting and retaining qualified pharmacists must be treated as a key consideration.

📕 Risk notice

A pharmacist who is named as the “superintendent pharmacist” at several pharmacies at the same time is committing a serious breach, a form of “nominal appointment”. If this is discovered by the Drug Office, all the pharmacy licences concerned may be revoked, and the pharmacist may face a disciplinary hearing. Their registration may be suspended or even permanently revoked.

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