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I plan to operate both a western medicine wholesale business and a proprietary Chinese medicine wholesale business. Do I need to set up separate accounts for the two businesses?

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

Q288 · Category F: Fees, budgeting and financial planning (Q251–Q300)
Although the law does not require separate legal entities or bank accounts for different business lines within the same company, from a management and compliance perspective we strongly recommend setting up separate “cost centres” or “profit centres” in your accounting system for wholesale of western medicines and wholesale of proprietary Chinese medicines. This means you should be able to track and distinguish clearly the sales revenue, procurement costs, inventory value and related operating expenses for each. This gives you a more detailed management perspective and allows you to assess the profitability of each business area accurately.

📘 Regulatory basis

Western medicines and Chinese medicines are regulated by the Drug Office, Department of Health and the Chinese Medicine Council of Hong Kong respectively, under different regulatory frameworks (Cap. 138 vs Cap. 549). Providing clear, separate business records during inspections by the respective regulatory authorities is an important part of demonstrating compliant operations.

📗 Drew Tang's recommendations

Clear separation of accounts can help you make better-informed business decisions. For example, if you find that the profit margin for your proprietary Chinese medicine business is far higher than that for your Western medicine business, you may decide to allocate more resources to the former, or vice versa. Without separate accounting, all your financial data is a muddle and cannot be analysed effectively.

📕 Risk notice

If accounts are unclear or mixed together, a serious compliance issue in one business segment (for example, the discovery of illegally imported Western medicines) may affect your company’s entire licensing eligibility, including its otherwise compliant Chinese medicine business. Financial segregation can provide a firewall to some extent and reduce the likelihood of risk spreading.

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