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Is there a specific minimum area requirement for business premises when applying for a pharmaceutical wholesale dealer licence in Hong Kong?

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

Q151 · Category D: Premises and Storage Requirements (Q151-Q200)
When assessing applications for pharmaceutical wholesale dealer licences, the Drug Office, Department of Health, does not prescribe a minimum floor area for business premises in the regulations. This does not mean, however, that any floor area will suffice. The key principle is that “the area of the premises must be appropriate to the scale of the business and the types of medicines handled”. Inspectors will assess a range of factors, including the quantity and types of medicines you plan to store and handle, their storage requirements (such as ambient temperature or refrigeration), and whether processing or packaging will be required. If a space is too small to meet functional zoning requirements—for example, if it has no separate quarantine area pending examination, released-goods area, returns area or office—or if medicines are stored in a disorderly manner with a high risk of cross-contamination, the licence application is very likely to be refused. The floor area should therefore be sufficient to clearly separate each functional area and ensure the safe, orderly storage and handling of medicines.

📘 Regulatory basis

Under the Pharmacy and Poisons Regulations (Cap. 138A) and the Good Distribution Practices published by the Department of Health, a wholesaler’s premises must have sufficient space to enable all operations to be carried out in an orderly manner and to ensure the proper segregation of different categories of medicines.

📗 Drew Tang's recommendations

At Rengangyongsheng (Hong Kong) Limited, we generally recommend that even a start-up pharmaceutical wholesale business have a usable area of at least 80-100 square metres. This area can accommodate the necessary office, storage and operating areas, while leaving some room for future business growth. When choosing premises, be sure to prepare a detailed premises layout plan clearly identifying each functional area; this is a key document for submitting an application.

📕 Risk notice

Do not choose premises that are too small just to save on initial rent. If the Department of Health gives a negative assessment during an on-site inspection because the premises are too small, you may have to find new premises and renovate them, causing serious delays and financial losses. A record of a rejected application may also adversely affect future applications.

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