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How do the premises and storage requirements for Listed Sellers of Poisons (LSPs, commonly known as “drug stores”) differ from those for wholesalers?

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

Q197 · Category D: Premises and Storage Requirements (Q151-Q200)
A Listed Seller of Poisons (LSP) operates from a shop serving the public (a “drug store”). Its storage requirements differ in scale and layout from those of a wholesaler’s bulk warehouse, but the core principles are the same. The main differences are: 1. **Functional zoning**: The front of the drug store is the retail area, while the rear or an upper floor is used for storage. Clear zoning is still required. For example, prescription medicines must be kept in a “non-sale area” (dispensary) inaccessible to the public, while controlled poisons (such as Schedule 1 poisons) must be kept in locked cabinets or drawers. 2. **Storage quantities**: A drug store holds far less stock than a wholesaler, so its storage area is smaller. It must still be clean and orderly, and medicines must not be placed directly on the floor. 3. **Serving the public**: As the business serves members of the public directly, the overall environment, lighting and hygiene must be of a high standard to create a professional and reliable impression. 4. **Display of poisons**: Schedule 2 poisons may be displayed at the front of the shop, but must be kept where customers cannot reach them (for example, behind the counter). In short, although the premises are smaller, the requirements for storage by category, secure custody and prevention of mix-ups are equally strict.

📘 Regulatory basis

The Pharmacy and Poisons Regulations set out specific requirements for the premises of Listed Sellers of Poisons, such as keeping poisons separate from non-medicinal products and mandatory requirements for storing Schedule 1 poisons under lock and key.

📗 Drew Tang's recommendations

For clients planning to open a drug store, we recommend taking medicine segregation and storage requirements into account from the design stage. A well-designed “non-sale area” will not only meet compliance requirements but also improve the efficiency of the pharmacist or dispenser. Placing the poison cupboard used to store controlled medicines within the coverage of CCTV is a good way to strengthen security.

📕 Risk notice

The most common breaches by medicine shops are placing medicines that require a prescription or supervised sale on open shelves for customers to take freely, or failing to keep Schedule 1 poisons properly locked away. These acts may result in suspension or revocation of the licence because they directly endanger public safety in the use of medicines.

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