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What is the correct procedure for handling expired or damaged medicines? Can they simply be discarded?

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

Q32 · Category A: Licensing system and regulatory fundamentals (Q1–Q50)
Absolutely not. Expired or damaged medicines must be handled according to a strict procedure to prevent them from accidentally re-entering the market or polluting the environment. The correct procedure is as follows: first, immediately segregate all expired, damaged or returned medicines from normal stock and place them in a clearly labelled, secure “non-conforming goods area”. Next, prepare a detailed inventory of the medicines awaiting destruction, recording their names, quantities, batch numbers and other information. The licensee must then engage a professional company holding a “chemical waste collection / disposal licence” issued by the Environmental Protection Department to handle the medicines. A representative of the licensee must supervise the destruction and obtain a certificate of destruction. All destruction-related records, including the inventory and certificate of destruction, must be properly retained for at least two years, just like purchase and sales records, for inspection by the Department of Health.

📘 Regulatory basis

Although the Pharmacy and Poisons Ordinance does not specify a destruction procedure, GDP and GSP codes of practice set out clear requirements. In addition, improper disposal of medicines may breach the provisions on chemical waste in the Waste Disposal Ordinance (Cap. 354).

📗 Drew Tang's recommendations

Regularly checking stock and promptly removing expired medicines are signs of good inventory management. We recommend making this a routine monthly or quarterly task and establishing a long-term relationship with a reliable compliant disposal company to simplify the process.

📕 Risk notice

Discarding expired medicines in ordinary rubbish or reselling them to illegal recyclers are both serious breaches. If these medicines are repackaged and re-enter the market, the risk to public health is enormous, and the licence holder may face the most severe legal sanctions and criminal liability.

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