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HONG KONG DRUG LICENSING

Does a change to the premises address require a new licence application? What is the process?

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

Q196 · Category D: Premises and Storage Requirements (Q151-Q200)
Yes, a pharmaceutical wholesaler licence is tied to a specific premises address. If you plan to move your warehouse or office to a new address, this is considered a major change. You must apply to the Drug Office, Department of Health, to change the licensed premises, and will generally need to undergo an approval process similar to that for a new application. The process is broadly as follows. First, submit a written application to the Department of Health explaining the reason for the change and providing details of the new premises, including the tenancy agreement and a detailed layout plan. Secondly, the new premises must be fully fitted out and equipped in accordance with GDP requirements. Once preparations are complete, notify the Department of Health, which will arrange a new site inspection. The Department of Health will approve the change-of-address application and issue a new licence showing the updated address only after the new premises have passed inspection and been confirmed as fully meeting all GDP requirements.

📘 Regulatory basis

Under the Pharmacy and Poisons Regulations, any change to licensed premises must be approved by the Pharmacy and Poisons Board. Pharmaceutical wholesale business must not be conducted at the new address before approval is granted.

📗 Drew Tang's recommendations

We strongly recommend that clients begin planning a relocation at least 6-9 months before the current lease expires. The entire process, from selecting a site and fitting it out to submitting an application and passing the final inspection, takes a long time. Be sure not to terminate the licence for the old premises before the new licence is approved, to ensure business continuity. We can help clients manage the entire relocation and licence change process to ensure a seamless transition.

📕 Risk notice

Moving to a new address and commencing operations without first obtaining formal approval from the Department of Health constitutes unlicensed operation and is a serious offence. This may result in your licence being suspended or revoked, and criminal prosecution. Similarly, terminating the lease for your existing premises before the new premises have passed inspection may leave your business without compliant operating premises and bring operations to a halt.

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