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HONG KONG DRUG LICENSING

Our “Responsible Person” has left the company. Will this affect the licence? What should we do?

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

Q362 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
The “Person-in-Charge” is a key position at a licensed wholesaler or manufacturer, responsible for overseeing day-to-day operations to ensure compliance. Their departure has a significant impact on the licence, and you must act immediately. First, you should appoint a new, suitably qualified Person-in-Charge as soon as possible. They should have sufficient pharmaceutical knowledge, industry experience and understanding of the relevant legislation. Second, you must notify the Drug Office, Department of Health in writing within a reasonable time after the personnel change (usually recommended within 14 days), advising that the former Person-in-Charge has left and submitting the new appointee’s detailed CV and proof of qualifications. The Department of Health will assess whether the new appointee meets the requirements. Until a suitable replacement is found, senior management should appoint an interim acting person and ensure that all compliance activities continue without disruption.

📘 Regulatory basis

Both the Code of Practice for Licensed Wholesale Dealers and the Code of Practice for Licensed Manufacturers require licensees to appoint one or more suitable “persons-in-charge”. The Department of Health should be notified promptly of any changes to key personnel.

📗 Drew Tang's recommendations

To avoid a compliance gap caused by the sudden departure of key personnel, we recommend that companies deliberately develop successors internally and establish a talent pipeline. When submitting details of a new Person-in-Charge to the Department of Health, prepare a detailed handover plan to demonstrate that the company has transitioned smoothly; this will create a good impression with the regulatory authority. Rengangyongsheng (Hong Kong) Limited can help you assess candidates’ qualifications and prepare all required documents for submission.

📕 Risk notice

A prolonged failure to appoint a qualified Person-in-Charge or to notify the Department of Health promptly of relevant changes may be regarded as a serious management deficiency. The Department of Health may consider that your company lacks effective oversight and cannot assure the quality and safety of pharmaceutical products. It may therefore review the status of your licence and even take measures such as suspending it until you rectify the issue.

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