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HONG KONG DRUG LICENSING

Is it permissible to use a warehouse shared with other companies?

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

Q190 · Category D: Premises and Storage Requirements (Q151-Q200)
Using a multi-tenant warehouse to operate a pharmaceutical wholesale business is permitted, but it presents additional compliance challenges that must be managed strictly. First, your licensed pharmaceutical storage area must be a physically independent and securely segregated unit, such as a caged area with its own lockable door or a separate room. You must have full control over access to the area and prevent employees or goods belonging to other companies from entering. Second, you must clearly define the scope covered by your licence to the Department of Health and mark it clearly on the floor plan. There must be clear agreements with the warehouse owner or other tenants on the management responsibilities and hygiene standards for shared common areas, such as loading platforms and corridors, and these must meet basic GDP requirements, such as cleanliness and pest control. You must demonstrate that the activities of other tenants, such as storing food or ordinary goods, will not create cross-contamination or security risks for your pharmaceutical storage environment.

📘 Regulatory basis

GDP requires licence holders to have sufficient control over their licensed premises. In a shared environment, you must demonstrate to the Department of Health that you have absolute and exclusive control over your dedicated medicine storage area, and have measures in place to manage risks arising from the shared environment.

📗 Drew Tang's recommendations

If you choose to use a shared warehouse, we strongly recommend that you clearly define your dedicated area and each party’s responsibilities for managing common areas in the lease. When applying for a licence, proactively submit a risk assessment report to the Department of Health analysing the risks that may arise from the shared environment (such as security, pests and contamination) and setting out in detail the control measures you will take. This proactive and transparent approach will increase the regulator’s confidence.

📕 Risk notice

The worst-case scenario is simply marking out an open corner in a shared warehouse to store medicines, which is absolutely not permitted. You cannot prevent anyone from accessing your medicines or control the surrounding environment. If other tenants in the shared warehouse have very poor hygiene, causing a pest infestation throughout the building, your licence application may still be refused because of excessive external environmental risks, even if the management of your own independent unit is excellent.

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