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HONG KONG DRUG LICENSING

What are the specific requirements for record-keeping in a Quality Management System? How long must records be kept?

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

Q305 · Category G: Quality management and compliance systems (Q301–Q350)
In the pharmaceutical wholesale industry, complete records are the only way to demonstrate compliant operations and achieve product traceability. GDP requires clear, accurate and timely records of all key activities. These records must be sufficient to reconstruct the full “life history” of every batch of pharmaceutical products, from procurement, receipt, and putting into storage through storage, picking, sale and final dispatch. Records to be retained include, but are not limited to: purchase orders, invoices, receipt inspection records, inventory records, temperature and humidity monitoring records, sales orders, dispatch records, customer qualification documents, staff training records, internal audit reports, complaint handling records and recall records. All records should be kept securely and systematically and be available for inspection by the regulatory authorities at any time.

📘 Regulatory basis

The Good Distribution Practice (GDP) for Medicinal Products expressly requires all records relating to the distribution of medicines to be retained. As for the retention period, section 28 of the Pharmacy and Poisons Regulations (Cap. 138A) requires records of the sale and supply of poisons (the “poisons book”) to be kept for at least two years from the date of the last entry.

📗 Drew Tang's recommendations

Although the minimum retention period for poisons records under the regulations is two years, we generally recommend that clients keep all medicine-related transaction and quality records for at least one year after the medicines’ expiry date, as a precaution. For electronic record systems, data integrity, security and traceability must be ensured, with reliable backup and recovery procedures in place. In practice, clear records are valuable not only for inspections, but also for self-assessment, problem tracking and continuous improvement.

📕 Risk notice

Incomplete records or an inability to produce them is one of the most common and readily penalised deficiencies identified during inspections. If you cannot provide a complete medicine traceability chain, the regulatory authority may consider your management to be out of control and unable to assure medicine quality. Missing records may prevent effective action during an emergency, such as a product recall, magnify the risks and expose you to more serious legal liability.

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