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How should medicines that are nearing expiry or have expired be managed in a warehouse to prevent them from being supplied in error?

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

Q177 · Category D: Premises and Storage Requirements (Q151-Q200)
Managing medicines by expiry date, particularly those nearing expiry or already expired, is central to inventory control. The aim is to strictly apply the “first expired, first out” (FEFO) principle and prevent expired medicines from entering the market. First, your inventory management system, whether a computerised WMS or a manual system, must accurately record the expiry date of each batch and sort stock by expiry date so that batches expiring sooner are picked first. Second, establish an “expiry-soon alert” mechanism. For example, the system could automatically flag all medicines due to expire within the next 6 months. Third, establish a specific procedure for handling flagged items approaching expiry, such as prioritising their sale or negotiating their disposition with the supplier. Fourth, once a medicine has expired, remove it from released stock immediately, transfer it to a physically segregated, clearly identified “non-conforming goods” or “expired goods” area, update the inventory records and await destruction under the chemical waste procedure.

📘 Regulatory basis

Good Distribution Practice (GDP) requires measures to ensure that expired medicines are not issued and are stored separately from usable stock. GDP also encourages the implementation of electronic systems to strengthen expiry date management controls.

📗 Drew Tang's recommendations

We strongly recommend that clients use a fully functional Warehouse Management System (WMS). A good WMS can not only automatically apply the FEFO principle, but also generate daily or weekly reports on products approaching their expiry dates, turning expiry management from a reactive process into proactive prevention. Regularly taking stock and reconciling the batch numbers and expiry dates of physical stock against the system records is also necessary to ensure the system's accuracy.

📕 Risk notice

Selling or distributing expired medicines to patients is an extremely serious offence. It may lead to revocation of the company's licence, and the person responsible may face criminal prosecution. If even one box of expired medicine is found on your released-goods shelves during a Department of Health inspection, your stock-management system may be considered to have failed completely, with very serious consequences.

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