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What are the specific record-keeping and management requirements for returned, rejected or recalled medicines?

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

Q387 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
Managing returned, rejected and recalled medicines is a key control point for preventing non-conforming goods from re-entering the market. You must establish strict procedures and a record system. First, all such medicines must be immediately segregated in a dedicated, secure, clearly identified physical area and must not be mixed with released goods. Second, every return, rejection or recall must be documented in detail, including the medicine name, batch number, quantity, source (customer), reason and date received. Third, the quality department must assess the medicines and decide on their final disposition. There are only three possible outcomes: a) if it can be confirmed that the medicine’s quality has not been affected (for example, it was simply sent in error and transport conditions were controlled throughout), it may be returned to stock with approval from the head of the quality department; b) if it needs to be destroyed, follow the destruction procedure; or c) if it has been recalled, handle it in accordance with the recall plan. All assessments, decisions and final disposition actions must be documented.

📘 Regulatory basis

The Code of Practice for Licensed Wholesale Dealers has dedicated chapters on handling returned goods and recalls, requiring written procedures and complete records to be maintained.

📗 Drew Tang's recommendations

We recommend that clients design dedicated record forms for these “problem medicines” to ensure that all required information is captured. Provide dedicated training to warehouse staff responsible for handling returns so that they understand the importance of segregation and record-keeping. Conduct regular stocktakes in the quarantine area to ensure that physical stock matches the records. Take particular care when deciding whether high-value returned goods can be returned to stock; if in any doubt, destroy them.

📕 Risk notice

Failure to effectively segregate and control non-conforming goods is a “critical deficiency” in a GDP inspection. If inspectors find recalled goods that should have been segregated stored together with released goods, or you cannot provide the final disposition record for a batch of returned goods, this indicates a serious risk that unsafe medicines could re-enter the market and may lead to immediate regulatory action.

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