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How should returned or recalled medicines be segregated and managed on the premises?

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

Q168 · Category D: Premises and Storage Requirements (Q151-Q200)
Managing returned or recalled medicines is a key closed-loop control in the pharmaceutical quality control system and must be strictly implemented. First, a physically segregated area must be established in the warehouse specifically for returned/recalled medicines, with clear and prominent signage such as “Returned/Recalled Products Area - Not for Use”. All medicines returned by customers or recalled under instructions from the manufacturer or Department of Health must be moved to this area immediately upon receipt and must not be mixed with released stock. Second, detailed records must be kept for each batch of returned/recalled medicines, including the medicine name, batch number, quantity, reason for return/recall, source and date received. These medicines should be treated as “non-conforming goods” and must remain segregated until the quality control department makes a final disposition decision (for example, destruction or return to the supplier).

📘 Regulatory basis

Good Distribution Practice (GDP) expressly requires that “dedicated areas should be provided for the storage of returned medicines, separate from released goods”. For recalled medicines, it also requires that “recalled medicines should be identified and stored separately from released goods in a secure area until a final disposition decision has been made”.

📗 Drew Tang's recommendations

We recommend that clients use a lockable cage trolley or locked room as the returns/recall area, providing two layers of protection. This is not only physical segregation but also access control, and can more effectively prevent these medicines from being incorrectly shipped again. In the warehouse management system (WMS), the stock status of these medicines should also be marked as “locked” or “unavailable” to prevent their allocation to new orders at system level.

📕 Risk notice

Failure to effectively segregate returned or recalled medicines is an extremely serious breach. If medicines with potential quality issues are accidentally sold again, they may harm patients and lead to serious medical incidents and legal disputes. If inspectors find returned medicines scattered in the area for released goods, your Quality Management System will be considered to have failed completely.

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