Do I also need a pharmaceutical licence if I only want to sell health products online?

This is a key question, and the answer depends on how your “health product” is classified under Hong Kong law. Hong Kong law does not have a statutory category of “health products”. A product is classified as a “pharmaceutical product” or a “non-pharmaceutical product” according to its ingredients and claimed effects, regardless of its market positioning or common name. If your product contains any Western medicine ingredient listed in the Poisons List under the Pharmacy and Poisons Ordinance, or its claimed effects meet the definition of a “pharmaceutical product” (that is, it is intended to diagnose, treat or prevent disease), it will be regarded as a pharmaceutical product. Once classified as a pharmaceutical product, it must first be registered in Hong Kong before it can be sold, whether in a physical shop or online, and the seller must hold the relevant pharmaceutical licence, such as a wholesaler licence. If your product contains no Western medicine ingredients and makes no therapeutic claims in its promotion, it may be regarded as an ordinary food and may not require a pharmaceutical licence. However, classification can be complex and requires case-by-case analysis.