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How does the approval process for a “Listed Seller of Poisons” (LSP) licence differ from that for a pharmacy?

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

Q232 · Category E: Application Process and Approval Procedures (Q201-Q250)
Applying for a “Listed Seller of Poisons” (LSP) licence usually refers to what are commonly known as a “dispensary” or “drug shop”. Its approval process and scope of business differ significantly from those of an “Authorised Seller of Poisons” (Pharmacy). The key distinction is that an LSP may sell only Part II poisons in the First Schedule (commonly called “P2 medicines”, such as some painkillers and cold medicines), and may not sell prescription medicines or P1 medicines that require pharmacist supervision. Although an application must also be submitted to the Department of Health and the premises are subject to an on-site inspection, the requirements are relatively less stringent. A registered pharmacist does not need to be present on the premises, but staff must have received appropriate training. The premises must have a dedicated locked cabinet for storing P2 medicines, which must not be displayed where customers can help themselves. The focus of approval is to ensure that the applicant can store and sell these restricted non-prescription medicines safely.

📘 Regulatory basis

The Pharmacy and Poisons Regulations set out clear requirements for Listed Sellers of Poisons’ qualifications, premises conditions and sales methods. For example, they provide that such shops must renew their licences every January.

📗 Drew Tang's recommendations

For clients wishing to enter pharmaceutical retail but currently unable to engage a registered pharmacist, applying for a Listed Seller of Poisons licence is a good starting point. We will guide you on fitting out your shop correctly and installing compliant lockable cabinets, and provide your employees with training on the regulations governing sales of P2 medicines. 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, for lawful operation.

📕 Risk notice

The greatest risk is “selling beyond the permitted scope”. Some pharmacy owners may illegally sell P1 medicines requiring pharmacist supervision or prescription medicines for profit. This is a very serious offence. If discovered through a test purchase or inspection, the licence may be revoked immediately and the operator may face imprisonment. The permitted scope of business must be followed strictly.

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