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If part of the premises needs alteration or an extension, which department should we apply to? What is the process?

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

Q167 · Category D: Premises and Storage Requirements (Q151-Q200)
In Hong Kong, any work on premises involving structural alterations, additions or major renovations must comply with the Buildings Ordinance (Cap. 123) and may require an application to the Buildings Department. This is known as a “building plan submission”. First, you must engage an Authorised Person (usually an architect, engineer or surveyor) to assess your alteration plans. If the plans involve structural safety, fire safety, sanitary facilities or other relevant matters, the Authorised Person will determine whether a formal submission is required. If so, they will prepare the plans and related documents and submit the application to the Buildings Department on your behalf. The Buildings Department will review whether the plans comply with building standards and safety requirements. Once approval has been obtained, you must also engage a registered contractor to carry out the works. After completion, the Authorised Person will apply to the Buildings Department for a “Certificate of Completion” (also known as a “satisfaction letter”) confirming that the works have been completed in accordance with the approved plans.

📘 Regulatory basis

The Buildings Ordinance (Cap. 123) is the principal law governing building construction and alterations in Hong Kong. Any unauthorised building works are illegal, and the Buildings Department may issue a removal order requiring the owner to reinstate the premises.

📗 Drew Tang's recommendations

Before carrying out any alterations, even if you consider the work minor (for example, adding an internal partition), we strongly recommend that you first seek professional advice from an Authorised Person. Many seemingly simple internal alterations may require plans to be submitted if they affect fire escape routes or the building structure. Seeking advice beforehand can prevent major losses caused by discovering only after committing funds that the work is unlawful.

📕 Risk notice

The risks of carrying out unauthorised building works (UBWs) are extremely high. If discovered by the Buildings Department, you will have to bear the full cost of demolition and reinstatement, and may also face fines and prosecution. More importantly, the validity of the Occupation Permit for premises with UBWs may be questioned. This could directly result in the Department of Health refusing your pharmaceutical licence application because you cannot demonstrate that your business premises are lawful and compliant.

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