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What are a “Qualified Person” (QP) and a “Responsible Person” (RP)? How do their roles in pharmaceutical regulation differ?

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

Q390 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
A “Qualified Person” (QP) and a “Responsible Person” (RP) are two distinct but equally important roles in the regulatory framework for medicines. QP is a legal concept under the EU and PIC/S GMP systems and is primarily found in pharmaceutical manufacturing. The QP’s core responsibility is to personally review batch records and issue a declaration before each batch of medicine is placed on the market, confirming that the manufacturing and testing of the batch fully comply with GMP requirements and the marketing authorisation. The QP bears personal legal responsibility for product quality. By contrast, the RP is a GDP concept found primarily in pharmaceutical wholesale and distribution. The RP is responsible for ensuring that the wholesaler’s Quality Management System is effectively implemented and maintained, and that medicines retain their quality and integrity during storage and distribution. The RP is responsible for compliance in wholesale activities. In short, the QP is responsible for “release from manufacture” and ensuring manufacturing quality; the RP is responsible for “distribution compliance” and ensuring supply chain quality.

📘 Regulatory basis

Chapter 2 of the PIC/S GMP Guide defines the responsibilities and qualification requirements of a QP in detail. Hong Kong's Drug Wholesalers Code of Practice sets out the appointment and responsibilities of an RP.

📗 Drew Tang's recommendations

Companies holding both a Manufacturer of Pharmaceutical Products licence and a wholesale licence must clearly distinguish the responsibilities of the two roles and define them in their quality system documentation. Although the same person may hold both roles in a small company, they must have all the knowledge and experience required for each role and be able to “switch hats” clearly when performing different duties. The QP’s decisions should focus on the batch itself, while the RP’s decisions should cover the entire distribution chain.

📕 Risk notice

Confusion over the responsibilities of the QP and RP may create regulatory gaps. For example, a QP focused only on production may overlook risks in distribution, while an RP familiar only with storage may be unable to make an informed quality assessment of production deviations. The performance of these two key roles is assessed in depth during Department of Health inspections; unclear responsibilities or insufficient capability will be treated as a major systemic deficiency.

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