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What are the financial costs and procedures involved for a pharmaceutical business in Hong Kong when disposing of expired or non-conforming medicines?

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

Q297 · Category F: Fees, budgeting and financial planning (Q251–Q300)
In Hong Kong, the disposal of expired or non-conforming medicines is a strictly regulated process that incurs costs. These medicines must be handled as “chemical waste” by a waste collector holding a specific licence issued by the Environmental Protection Department (EPD). The main costs are: 1. “Collection and transport fees”: the waste collector will charge according to the weight or volume of the waste. 2. “Treatment fees”: depending on the chemical properties of the medicines, special methods such as incineration may be required, at a higher cost. 3. “Administrative costs”: staff time is needed to segregate and record the waste and arrange its disposal. In the financial statements, the book value of medicines written off in this way must be fully written off as an operating loss for the current period.

📘 Regulatory basis

Under the Waste Disposal (Chemical Waste) (General) Regulation (Cap. 354C), anyone who produces chemical waste must register as a “chemical waste producer” and appoint a licensed collector to dispose of the waste in accordance with Environmental Protection Department requirements. Improper disposal is a criminal offence.

📗 Drew Tang's recommendations

We recommend that you enter into a long-term service contract with a reputable licensed chemical waste collector. At the same time, establish a clear internal medicines destruction SOP (Standard Operating Procedure) to ensure that every step, from identification and segregation to recording and final handover, is documented for inspection by the Department of Health or Environmental Protection Department.

📕 Risk notice

Carelessly discarding expired medicines is extremely dangerous and irresponsible. If discovered, you may not only face prosecution by the Environmental Protection Department and substantial fines, but may also have your licence revoked by the Department of Health for breaching medicines regulations. The price of this kind of ‘saving’ is one you cannot afford to pay.

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