Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

We want to engage a third-party logistics company (3PL) to store and transport our medicines. What compliance requirements apply?

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

Q367 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
Outsourcing pharmaceutical-product storage and transport to a third-party logistics company (3PL) is permitted, but this does not mean you can outsource your compliance responsibilities as well. As a licensed wholesaler, you remain ultimately responsible. When selecting and using a 3PL, the following compliance requirements must be met: 1. Due diligence: you must rigorously audit the 3PL to ensure its facilities, equipment, personnel and procedures meet GDP requirements. 2. Technical agreement: you must enter into a detailed Technical Agreement with the 3PL, clearly defining each party's responsibilities and obligations at every stage of pharmaceutical-product handling, including receipt, storage, temperature monitoring, picking, packing, transport, record retention, and complaint and recall handling. 3. Audit rights: you must retain the right to audit the 3PL regularly to ensure ongoing compliance. 4. Department of Health notification: you must notify the Department of Health of the 3PL engaged and the address where it stores your pharmaceutical products.

📘 Regulatory basis

Chapter 9 of the Code of Practice for Licensed Wholesale Dealers specifically governs outsourced activities and emphasises that licensees must control such activities and remain responsible for the outcome of any outsourced activity.

📗 Drew Tang's recommendations

Choosing a 3PL company with extensive experience in handling medicines and its own Wholesale Dealer Licence is the best way to reduce risk. When signing a Technical Agreement, the more detailed it is, the better; it should cover all foreseeable situations. We recommend conducting an on-site audit of your 3PL partner at least once a year, rather than relying solely on its self-inspection reports. Rengangyongsheng can assist with supplier audits to ensure that your partner meets regulatory requirements.

📕 Risk notice

If your 3PL partner breaches requirements while handling your medicines (for example, if an excessive temperature causes them to deteriorate), you will still be accountable to the Department of Health. Any Department of Health penalties (such as a warning, fine or even licence revocation) will be directed at you. Choosing an unsuitable partner or failing to supervise them properly will therefore expose your business to substantial, uncontrollable risk.

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