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Records must be retained for at least two years under the regulations. Is it necessary for us to keep them for longer?

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

Q374 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
The statutory “at least two years” is a minimum requirement. In practice, however, many companies choose to retain key records for longer as a matter of prudence and risk management. For example, a widely accepted best practice for batch manufacturing and distribution records is to retain them until at least one year after the expiry date of the medicine. This means that if a quality issue or adverse reaction report is identified shortly before or after the medicine expires, you can still trace the complete manufacturing and distribution history for investigation. For some records relating to company operations, validation or critical equipment (such as validation reports, training records for key personnel and change control records), permanent retention is recommended, or at least retention for a substantial period after the relevant system or equipment has been decommissioned.

📘 Regulatory basis

The Pharmacy and Poisons Regulations (Cap. 138A) require records of poison purchases and sales to be retained for at least two years. The Code of Practice for Wholesale Dealers in Poisons also generally adopts this minimum standard. GMP guidelines, however, usually recommend a longer retention period.

📗 Drew Tang's recommendations

We recommend that clients establish a clear Document Retention Policy, setting different retention periods according to the nature and importance of different records rather than applying one rule to all. For example, financial records may need to be retained for 7 years under tax regulations, while batch records may follow the “expiry date + 1 year” rule. For electronic records, ensure their readability and integrity throughout the retention period, taking account of compatibility issues caused by technological changes.

📕 Risk notice

Meeting only the minimum two-year requirement may put you at a disadvantage in certain circumstances. For example, if an issue is discovered with a medicine having a three-year shelf life two and a half years after it was placed on the market, and you have already destroyed the relevant records, you will be unable to investigate effectively or defend yourself in legal proceedings. Destroying records too early is effectively destroying evidence that could protect you.

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