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HONG KONG DRUG LICENSING

Can I destroy medicines requiring destruction myself instead of engaging a specialist company?

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

Q194 · Category D: Premises and Storage Requirements (Q151-Q200)
Absolutely not. In Hong Kong, no individual or company may destroy medicines themselves, particularly expired or non-conforming medicines classified as chemical waste. Self-disposal (for example, throwing medicines in the rubbish, flushing them down the toilet or burning them) is a serious offence. The correct approach is to treat these medicines as chemical waste and have them handled by a professional company holding a valid chemical waste disposal licence issued by the Environmental Protection Department. The process must be fully documented using a “Trip Ticket” to track the waste from your warehouse to its final disposal facility. This requirement not only protects the environment, but also prevents destroyed medicines from being unlawfully collected and re-entering the illegal market, where they could endanger public health.

📘 Regulatory basis

The Waste Disposal (Chemical Waste) (General) Regulation expressly stipulates how producers of chemical waste must package, label, store and dispose of that waste. Disposing of chemical waste yourself breaches the Regulation and may result in legal penalties.

📗 Drew Tang's recommendations

We recommend that clients treat medicines destruction as a formal process requiring strict document control. Before destruction, prepare a detailed destruction list covering the medicine name, batch number, quantity and reason for destruction. The list should be approved by the quality department. After destruction, file the certificate of destruction provided by the licensed disposal company together with the relevant transport records to create a complete destruction record pack.

📕 Risk notice

Do not assume that you can dispose of expired medicines through unofficial channels. The Environmental Protection Department enforces the rules very strictly. Furthermore, if your expired medicines are found circulating illegally on the market because they were disposed of improperly, you, as the source, will face extremely serious legal liability and reputational damage, and may even have all relevant licences revoked.

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