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What is an LSP? What special requirements should we observe in day-to-day sales?

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

Q365 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
A “Listed Seller of Poisons” (LSP) generally refers to what is commonly known as a “medicine shop” or “drug shop”. They are permitted to sell Part II poisons listed in Schedule 10 to the Pharmacy and Poisons Regulations. These medicines are relatively low-risk, such as certain topical antiseptic solutions and pain-relief balms. In day-to-day sales, you must observe the following special requirements: 1. Medicines must be sold at the registered premises. 2. Medicines must be sold in their original, unopened containers. You may not break up large packs for retail sale. 3. A pharmacist does not need to be present to supervise sales, and purchasers’ details do not need to be recorded. 4. However, you must ensure that medicine labels are clear and comply with regulatory requirements. 5. Most importantly, you must not sell any Part I poisons or unregistered pharmaceutical products.

📘 Regulatory basis

Section 19 of the Pharmacy and Poisons Ordinance (Cap. 138) and the Pharmacy and Poisons Regulations (Cap. 138A) define the rights and restrictions of Listed Sellers of Poisons.

📗 Drew Tang's recommendations

We recommend that operators and staff of Listed Sellers of Poisons clearly understand which medicines they may and may not sell. Check stock regularly to ensure that no Part I poisons or prescription medicines are included. Display a clear notice in the shop stating that prescription medicines are not sold there, to avoid unnecessary misunderstandings and disputes. Training staff to identify different categories of medicines is key to preventing unlawful sales.

📕 Risk notice

If a Listed Seller of Poisons (LSP) is found to have illegally sold Part I poisons (such as antibiotics and antihypertensive medicines), it will face very severe legal penalties. The Drug Office’s “sting” operations (that is, sending people to pose as customers and conduct undercover visits) are common. If a breach is established, the business may not only be fined but may also have its licence revoked. This is a regulatory red line that must never be crossed.

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