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What key steps should be taken when conducting an initial qualification check of a new medicine supplier?

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

Q347 · Category G: Quality management and compliance systems (Q301–Q350)
Initial qualification of new suppliers is the first safeguard for ensuring that your supply chain is lawful and compliant at source, and must be conducted with great care. Key steps include: 1. **Document review**: Ask the supplier for a complete set of qualification documents, including its business licence, medicines trading licence (such as a wholesale licence) and, where applicable, the manufacturer’s GMP certificate. Verify that these documents are authentic and valid. 2. **Questionnaire**: Send the supplier a detailed quality system questionnaire to understand its QMS, including its personnel, facilities, SOP system, temperature-control capabilities and recall procedures. 3. **Risk assessment**: Use the document review and questionnaire results to conduct an initial assessment of the supplier’s potential compliance risk. 4. **On-site audit (for high-risk suppliers)**: For critical, high-risk suppliers—for example, the sole supplier from which you plan to source a core product—an on-site audit is strongly recommended to verify in person that its operations match the documents. 5. **Approval and agreement**: Only after all review steps have been completed satisfactorily should the supplier be added to the “Approved Supplier List” and a formal quality agreement signed.

📘 Regulatory basis

Chapter 5, “Operations”, of the Good Distribution Practice (GDP) for Medicinal Products expressly provides that wholesalers must procure medicines from suppliers holding the relevant licences. You are responsible for verifying this through a formal qualification procedure.

📗 Drew Tang's recommendations

Establish a standardised new-supplier qualification SOP and checklist to ensure every assessment is thorough and consistent. Do not rely solely on documents supplied by the supplier; cross-check the authenticity of its licence using public government databases, such as the Department of Health website. Treat supplier qualification as an investment, not a cost. A sound start can prevent countless problems later.

📕 Risk notice

Purchasing medicines from a new supplier based solely on commercial negotiations, without adequate qualification checks, is extremely risky. You may unknowingly obtain medicines through an unlicensed or non-compliant channel, or even purchase counterfeit medicines. If discovered, you may face serious legal and regulatory penalties for failing to fulfil your due diligence responsibilities.

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