Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
Hong Kong pharmaceutical compliance · applications / acquisitions / ongoing maintenance Independent Third-Party Service Provider
HONG KONG DRUG LICENSING

What validation and management requirements apply to computerised systems used for GDP activities (such as WMS and ERP)?

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

Q344 · Category G: Quality management and compliance systems (Q301–Q350)
Computerised systems used to manage critical GDP activities (such as warehouse management systems (WMS), enterprise resource planning systems (ERP) and temperature and humidity monitoring systems) must themselves be controlled to ensure that the data they generate are reliable, accurate and secure. These systems require Computer System Validation (CSV), with documented evidence demonstrating that they consistently meet their intended functions and regulatory requirements throughout their lifecycle. CSV generally follows the GAMP 5 (A Risk-Based Approach to Compliant GxP Computerized Systems) framework. Key management requirements include: 1. **Data integrity**: the system must be designed to ensure compliance with the ALCOA+ principles; 2. **Audit trail**: the system must automatically record all activities relating to the creation, modification and deletion of GxP data, including timestamps and operator information; 3. **Access controls**: grant users the minimum system access necessary for their roles and responsibilities; 4. **Backup and recovery**: validated procedures must be in place to back up data regularly and restore it reliably when required; 5. **Change control**: any changes to the system (such as software upgrades or configuration changes) must be managed through a formal change control procedure.

📘 Regulatory basis

GDP expressly requires that the suitability of a computerised system be demonstrated before it is used, usually through validation. The system must prevent unauthorised access or modification, provide an audit trail and allow data backup. Annex 11 of the EU GDP guidelines and US FDA 21 CFR Part 11 are generally accepted standards in this area.

📗 Drew Tang's recommendations

When procuring a new system, make “support for GxP compliance” a key selection criterion. Ask the supplier to provide relevant documentation on its software development and testing. For cloud services (SaaS), you need to audit the service provider's quality system and security measures. CSV is a specialist field; if you lack in-house experience, consider seeking external expert support to plan and carry out validation activities.

📕 Risk notice

Using an unproven, “black-box” computer system to manage your pharmaceutical stock and quality data is unacceptable to regulators. If your system lacks an audit trail, you will be unable to explain any changes to the data. An uncontrolled computer system is a major source of risk to data integrity and may be sufficient for the entire quality system to be judged non-compliant.

Back to Category G: Quality Management and Compliance Systems (Q301-Q350) Search more questions

YOUR NEXT STEP

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

Book a Project Assessment ↗