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What procedure should a wholesaler follow if a batch of medicines needs to be recalled? What key steps should the SOP include?

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

Q306 · Category G: Quality management and compliance systems (Q301–Q350)
A medicine recall is a key risk response within the quality management system and requires a rapid, accurate and efficient response. Once you receive a recall notification from a manufacturer or regulatory authority, or discover a serious product quality problem yourself, you must immediately initiate the recall procedure. Your recall SOP should clearly define different recall classes (such as Class I, II and III) and specify the response time and action plan for each. Key steps include: 1. Immediately quarantine affected batches and stop their distribution; 2. promptly identify all customers who purchased the batches and the quantities distributed; 3. issue written recall notices to all relevant customers within the prescribed time; 4. arrange the return, receipt, segregation and handling of recalled medicines; 5. continuously monitor recall progress and report regularly to the manufacturer and Department of Health; 6. investigate the root cause and take corrective and preventive action (CAPA).

📘 Regulatory basis

The Drug Office, Department of Health’s Guidelines on Product Recall provide licensed wholesalers with detailed guidance on actions to take. The guidelines classify recalls according to the level of risk to public health and set out specific requirements for notification timelines, execution effectiveness and reporting.

📗 Drew Tang's recommendations

“Acting swiftly is essential” is the golden rule of recalls. We recommend that clients conduct mock recall exercises regularly to test and improve the effectiveness of their recall SOP and traceability system. Ensure that you have an accurate customer contact database readily available. During a recall, appointing a dedicated coordinator to manage internal and external communications can help prevent confusion. All communications, actions and decisions relating to the recall must be documented in detail for review.

📕 Risk notice

Delays or ineffective execution of a recall expose the public to unnecessary risks, which regulatory authorities will not tolerate. Failure to carry out an effective recall may result in substantial fines, revocation of the licence and even criminal prosecution of the relevant persons. An ineffective traceability system would be a critical weakness at such a time.

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