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What special requirements must the work area meet if the business involves repackaging or relabelling medicines?

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

Q175 · Category D: Premises and Storage Requirements (Q151-Q200)
If your business involves secondary packaging of medicines (such as assembling packs) or relabelling, the area where these operations take place must meet a higher standard than an ordinary storage area, approaching that of a basic cleanroom. First, it must be a physically separate, enclosed room with independent access control. Second, it should have its own filtered ventilation system to control airborne dust particles and prevent cross-contamination. The walls, floor and ceiling must be smooth, seamless and easy to clean. Third, there should be an anteroom at the entrance where staff change into dedicated clean workwear, shoe covers and head covers. Fourth, the outer packaging of all materials used for packaging (such as new labels and cartons) must be cleaned before entering the area. Finally, all operations carried out in the area must have detailed batch production records and be traceable.

📘 Regulatory basis

These operations constitute “manufacturing” or “assembling” under the Pharmacy and Poisons Ordinance, even if they involve only labelling. The area must therefore comply with certain principles of Good Manufacturing Practice (GMP), particularly those relating to preventing contamination and ensuring product quality. You may need to apply for permission for “secondary packaging” under a Manufacturer’s Licence.

📗 Drew Tang's recommendations

We recommend that, if repackaging/labelling is a core part of your business, you plan a separate operating room meeting basic GMP requirements from the initial design stage. This investment is necessary. Engage an experienced cleanroom engineering company to design and construct the area, and conduct environmental testing to ensure that it meets the standards. RGYS may assist with document preparation and project coordination within the written scope of services; the respective responsible parties must verify personnel qualifications and statutory roles and take responsibility for professional judgements, while approval is determined independently by the competent authority.

📕 Risk notice

Opening cartons or relabelling medicines in an ordinary warehouse environment is strictly prohibited. These open operations take place in an uncontrolled environment, making medicines highly susceptible to microbial or dust contamination and mix-ups. If discovered, not only may the relevant licence application be refused, but you may also be prosecuted for suspected unlawful manufacture of medicines.

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