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Are licence application fees (such as the application fee and licence fee) refundable if my application is rejected?

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

Q235 · Category E: Application Process and Approval Procedures (Q201-Q250)
For refunds, you need to distinguish between two main types of fees: the application fee and the licence fee. The application fee is payable when you submit your application and covers the administrative costs incurred by the Department of Health in processing and reviewing it. It is non-refundable whether your application is approved or rejected. For example, the application fee for a wholesaler’s licence is HKD$1,030 (the fee may be revised; refer to the official source). The licence fee, by contrast, is payable only after the PPB Committee has formally approved your application and is for obtaining the licence for that year. For example, the issue fee for a wholesaler’s licence is HKD$2,150. If your application is not approved, you will not need to pay the licence fee. In short, the review costs paid are non-refundable, while no fee is charged for a licence entitlement you do not receive.

📘 Regulatory basis

The Schedules to the Pharmacy and Poisons Regulations set out the charges for various applications and licences in detail. The principle underlying government fees is “user pays”, and application fees reflect this principle.

📗 Drew Tang's recommendations

Given that the application fee is a sunk cost, we should focus on maximising the likelihood of success on the first application to avoid paying the fee again. Although investing in professional consultancy services increases initial expenditure, by improving the likelihood of approval on the first attempt, it can in practice save you the cost of repeat application fees, additional time and lost opportunities resulting from an unsuccessful application, making it the more cost-effective choice.

📕 Risk notice

The risk lies in seeing that the application fee is relatively small and underestimating the total investment for the entire application process. Beyond government fees, the greater costs are rent for the premises, fitting-out, staff salaries and consultancy fees. If an application fails, all these investments may generate no return for months or even more than a year. That is the greatest financial risk.

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