Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

How detailed should my Standard Operating Procedures (SOPs) be when I first submit my application?

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

Q224 · Category E: Application Process and Approval Procedures (Q201-Q250)
You do not need to submit a perfect final set of SOPs covering every detail with your initial application. However, you must prepare a core set of clearly structured draft SOPs to demonstrate to the regulator that you have systematically considered and planned your future operational processes. These drafts should cover at least all key areas of GSDP (Good Storage and Distribution Practice), including personnel and training, premises and equipment management, document control, receipt, storage, order processing, dispatch, transport, complaint handling, medicine recalls, returned goods handling and internal audits. Each SOP should have a clear title, purpose, scope, allocation of responsibilities and description of steps. During an on-site inspection, inspectors will sample these SOPs and may ask your Person-in-Charge about the procedures they describe to assess whether your quality management system is tangible and effective.

📘 Regulatory basis

The Code of Practice for Wholesale Dealers expressly requires licence holders to establish and maintain an effective Quality Management System, with SOPs as its core documentary evidence. Inspectors need to review your SOPs to assess your ability to ensure ongoing compliance.

📗 Drew Tang's recommendations

We will not leave you to start from scratch. RGYS may assist with document preparation and project coordination within the written scope of services; the respective responsible parties must verify personnel qualifications and statutory roles and take responsibility for professional judgements, while approval is determined independently by the competent authority. Based on your specific business model (for example, whether you handle cold-chain products), we will customise a set of draft SOPs to meet your needs. These documents can not only readily pass the initial review but, more importantly, are highly practical and can genuinely guide your future day-to-day work, rather than merely serving to satisfy inspections.

📕 Risk notice

The risk lies in submitting SOPs copied from the internet that are hollow and unrealistic. For example, the processes described may not match your warehouse layout, or the wrong terminology may be used. An experienced inspector will immediately recognise that the document is “theoretical” and may seriously question your professional competence and the sincerity of your application, resulting in unusually rigorous scrutiny.

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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.

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