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We are a manufacturer of proprietary Chinese medicines. What are the testing requirements for raw materials (Chinese herbal medicines) in routine production?

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

Q364 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
As a licensed manufacturer of proprietary Chinese medicines, quality control of raw materials is the first step in ensuring the safety and efficacy of the finished product, and is a core GMP requirement. Each batch of Chinese herbal medicines purchased must be rigorously tested before being used in production. The tests must include at least: 1. Identification of origin, confirming that the species is correct and that there is no confusion or adulteration. 2. Macroscopic examination, using traditional methods such as visual inspection, touch, smell and taste to check whether the appearance, colour and odour of the medicines conform to pharmacopoeial standards. 3. Microscopic identification, where necessary, using a microscope to examine the tissue structure of the medicines. 4. Physicochemical identification, including tests such as thin-layer chromatography (TLC), with comparison against the chromatogram of the relevant reference standard. 5. Safety testing for harmful substances such as heavy metals, pesticide residues and aflatoxins, to ensure that their levels are within statutory limits. All testing must be supported by detailed records and reports.

📘 Regulatory basis

The Good Manufacturing Practice Guide for Proprietary Chinese Medicines in Hong Kong, issued by the Chinese Medicine Council of Hong Kong, sets out detailed requirements for the receipt, sampling, testing and approval for release of raw materials. The requirements of the Chinese Medicine Ordinance (Cap. 549) must also be met.

📗 Drew Tang's recommendations

We recommend that manufacturers establish a reliable supplier audit and evaluation system to control the quality of Chinese herbal medicines at source. For certain critical or high-risk herbs, consider conducting on-site audits. In addition, retain a sample from every batch of herbs until one year after the expiry date of the corresponding finished product; this is vital for traceability investigations in the event of subsequent quality issues. If your in-house testing capability is limited, you can commission a third-party laboratory accredited by HOKLAS to carry out testing.

📕 Risk notice

Using Chinese herbal medicines for production without testing them or after they have failed testing is a serious GMP breach. This may result in an entire batch being deemed non-conforming and destroyed, causing substantial financial losses. If raw material issues, such as excessive heavy metals or toxic substances, cause harm to consumers through the finished product, the company may face a product recall, legal action and criminal prosecution, and its licence may also be at risk.

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