Q217 · Can I rent a commercial office and use part…

Q217 · Category E: Application Process and Approval Procedures (Q201-Q250)

This is a common question. Under Hong Kong’s Import and Export Ordinance, if your business consists solely of pharmaceutical product trans-shipment—that is, goods are shipped from one country or region, transhipped in Hong Kong (for example, by changing means of transport in a restricted area at the airport or port), and then continue to another country or region, without leaving the area under Hong Kong Customs control—those goods are not regarded as having been “imported” into Hong Kong. Under this narrowly defined trans-shipment model, you may need to register a company in Hong Kong to conduct business, but you would not generally need to establish your own physical warehouse in Hong Kong that meets GDP standards, because the pharmaceutical products do not enter Hong Kong’s commercial distribution chain. However, you must still ensure that storage and handling during trans-shipment meet GDP requirements in the country of origin, the destination country and during transport.

📘 Regulatory basis

The Code of Practice for Wholesale Dealers is the key reference for premises requirements. It expressly states that “the design and layout of the premises must minimise the risk of cross-contamination and mix-ups” and requires “adequate security measures to prevent unauthorised access”.

📗 Drew Tang's recommendations

We generally recommend that clients choose dedicated industrial buildings or commercial buildings with warehouse areas. If you do wish to adopt a “commercial office plus warehouse” model, we strongly recommend that you ask us to conduct a detailed site survey and feasibility assessment before signing the lease. We will assess the feasibility of physical separation, the building facilities' capacity to support your needs and the associated modification costs, and provide you with a clear, evidence-based recommendation.

📕 Risk notice

The greatest risk is investing heavily in fitting out premises only to be told during an on-site inspection that the physical segregation is non-compliant or prohibited by the building's deed of mutual covenant. For example, glass partitions or half-height wire-mesh fencing alone may well be considered inadequate segregation. In this situation, your entire investment would be wasted and the application could be deadlocked.

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

Can I rent a commercial office and use part of it to store medicines in order to apply for a licence?

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang