Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
Hong Kong pharmaceutical compliance · applications / acquisitions / ongoing maintenance Independent Third-Party Service Provider
HONG KONG DRUG LICENSING

What role should the Quality Department (QA/QC) play in our organisational structure?

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

Q380 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
In organisations operating in accordance with GDP/GMP, the Quality Unit has an independent and critical role. It consists of Quality Assurance (QA) and Quality Control (QC). QC primarily assesses whether the quality of raw materials, intermediates and finished products meets established standards through sampling and testing. QA has a broader role: it establishes, implements and maintains the company's overall Quality Management System (QMS), ensuring that all activities affecting product quality are controlled. The Quality Unit must be independent of the production or sales departments and have sufficient authority and resources to fulfil its responsibilities. Its core duties include approving or rejecting all quality-related materials and products, approving all SOPs and master documents, managing quality system processes such as deviations, changes and complaints, organising self-inspections, and making the final decision on whether each batch may be released for sale.

📘 Regulatory basis

Chapter 2 of the PIC/S GMP Guide expressly provides that the heads of quality assurance, pharmaceutical production and quality control should be independent of one another. The quality department must participate in all quality-related decisions.

📗 Drew Tang's recommendations

We recommend that the company’s senior management fully empower the head of the quality department and support them in making independent quality decisions, even when those decisions may conflict with short-term commercial interests (such as meeting delivery deadlines). The quality department should not be regarded as the “police” or an “obstacle”, but as a partner helping business teams achieve their objectives within the compliance framework. Holding regular management review meetings with senior management participation is an effective way to ensure that the quality system receives sufficient attention and resources.

📕 Risk notice

If the quality department does not have an independent status and its head has to report to the production or sales manager, it will be difficult for its quality decisions to be objective and impartial. In the regulator’s view, this is a fundamental organisational defect that indicates an ineffective quality assurance system. During an inspection, inspectors will assess the independence and effectiveness of the quality department through interviews and document reviews. Any evidence of interference with quality decisions may have serious consequences.

Back to Category H: Licensed Operations and Routine Oversight (Q351-Q400) Search more questions

YOUR NEXT STEP

Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

Book a Project Assessment ↗