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

Can I apply as an individual (not a company) for a Listed Seller of Poisons (LSP) licence to sell medicines in my own small shop?

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

Q140 · Category C: Eligibility and Personnel Requirements (Q101-Q150)
Yes. Unlike most other pharmaceutical licences, for which the applicant entity must be a limited company, an application for a Listed Seller of Poisons (LSP) licence (commonly known as a “medicine shop licence”) offers more flexibility. You may apply as an individual (sole proprietor), partnership or limited company. If you apply as an individual, you will be the licensee and bear full legal responsibility for the licensed activities of the shop. You must submit your personal identity documents with the application and sign all application forms in your own name. Regardless of whether the applicant is an individual or a company, all other licensing requirements must still be met, including having suitable business premises, providing appropriate staff training and complying with all relevant codes of practice.

📘 Regulatory basis

The Pharmacy and Poisons Ordinance includes both natural persons and legal persons in its definition of “person”. Accordingly, for a relatively low-risk licence such as a Listed Seller of Poisons (LSP) licence, the regulator accepts an individual as the licensee.

📗 Drew Tang's recommendations

For shop owners operating on a small budget, applying in an individual capacity can simplify the procedures and costs associated with company incorporation and maintenance. We will guide you in correctly completing the Business Registration Certificate (BR) and licence application forms as a sole proprietor. 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

The main risk of holding a licence in your personal name is “unlimited liability”. This means that if the shop is fined for breaching pharmaceutical laws, or faces a civil claim arising from medicines it sold, your personal assets—not just the shop’s assets—may be used to pay the debt or compensation. This should be carefully considered when choosing the applicant entity.

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