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What standards must cold-chain facilities (such as cold rooms and refrigerated vehicles) used for biological products requiring cold storage meet?

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

Q155 · Category D: Premises and Storage Requirements (Q151-Q200)
When handling medicines that require cold-chain storage, such as vaccines and insulin, cold-chain facilities must meet very stringent standards to ensure that the medicines remain within the specified temperature range (usually 2-8°C) throughout storage and transport. First, cold rooms and refrigerated vehicles must undergo a professional Temperature Mapping Study to demonstrate that temperatures at all points inside can be kept consistently within the required range. This validation must be carried out under both empty and fully loaded conditions. Second, all temperature-controlled equipment, including cold rooms, refrigerators, refrigerated vehicles and portable coolers, must be equipped with independent, calibrated temperature monitoring and alarm systems. Third, detailed Standard Operating Procedures (SOPs) must be established to cover all aspects, including routine use, cleaning, maintenance, calibration and emergency response (such as power failure). During transport, validated insulated shippers must be used together with temperature data loggers that record temperatures throughout the journey.

📘 Regulatory basis

The Department of Health’s Good Distribution Practice (GDP) and guidelines issued by the Pharmacy and Poisons Board (PPB) contain specific sections on cold-chain management. They explicitly require validation and qualification of cold-chain equipment, and set out detailed requirements for temperature records and deviation handling.

📗 Drew Tang's recommendations

We strongly recommend that clients engage a professional third-party service provider to conduct temperature mapping and issue an authoritative validation report. This is the strongest evidence of your cold-chain capabilities to present to the Department of Health. For refrigerated transport, if you do not plan to purchase your own refrigerated vehicle initially, you may work with a third-party logistics company qualified to transport medicines and able to provide full temperature data throughout the journey, but you must sign a detailed Quality Agreement.

📕 Risk notice

A break at any point in cold-chain management can be disastrous. Storing vaccines in a domestic refrigerator that has not undergone temperature validation, or transporting insulin in an ordinary vehicle with ice packs, is strictly prohibited. If discovered, this may result in the immediate refusal of a licence application and severe legal penalties for endangering public health. Temperature deviation events must be supported by detailed investigation reports and handling records; otherwise, they may be regarded as mismanagement.

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