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What final disposition procedure should be followed for non-conforming medicines that need to be destroyed (Final Disposition)?

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

Q350 · Category G: Quality management and compliance systems (Q301–Q350)
Destroying non-conforming medicines is the final step in quality management and requires equally strict controls and records to ensure that the medicines do not accidentally re-enter the market. The disposal procedure should include: 1. **Formal decision**: The decision to destroy must be made by an authorised person in the Quality Department (such as the RP), who must sign a written destruction instruction. 2. **Segregation and records**: Medicines awaiting destruction should be kept in a secure, dedicated area clearly labelled ‘Awaiting Destruction’. Before destruction, check and record the name, batch number and quantity of the medicines one final time. 3. **Select a qualified destruction service provider**: Medicines must not be disposed of like ordinary rubbish. A specialist company qualified and authorised by the government to handle pharmaceutical waste must be engaged. You should verify its qualifications. 4. **Secure transport**: Transport the medicines awaiting destruction securely to the service provider’s premises and keep a record of the transport. 5. **Witnessing and certification**: If possible, send a staff member to witness the destruction on site. Whether or not it is witnessed, you must obtain a formal Certificate of Destruction from the service provider. This document is key legal evidence that the medicines have been disposed of lawfully. 6. **Update inventory**: Once destruction is confirmed, reduce the quantity of the medicines to zero in your inventory management system and archive all relevant records.

📘 Regulatory basis

GDP requires non-conforming goods to be segregated and properly handled. Although it does not set out the destruction process in detail, environmental laws and waste management regulations impose strict requirements on the disposal of medicines. You are responsible for ensuring that the destruction process complies with all relevant laws and regulations.

📗 Drew Tang's recommendations

Enter into a long-term contract with one or more qualified medicine destruction service providers. Set out the entire destruction process in your SOP and create a “medicine destruction record pack” containing all relevant documents, including destruction instructions, inventory records, transport documents and the final certificate of destruction. This creates a complete, traceable evidence trail.

📕 Risk notice

Carelessly discarding non-conforming medicines is extremely dangerous and irresponsible. It not only seriously breaches environmental regulations, but may also result in the medicines being found by others and misused or resold, creating a public safety risk. If you cannot provide lawful proof of destruction, you will be unable to demonstrate to the regulator that you have properly handled the non-conforming goods. This may be regarded as a loss of ultimate control over your supply chain.

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