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HONG KONG DRUG LICENSING

The Department of Health requires us to submit a “Site Master File” (Site Master File, SMF). What is this document, and how should we prepare it?

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

Q393 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
A Site Master File (SMF) is a detailed document prepared by a medicine manufacturer or wholesaler describing the company’s activities relating to the handling of medicines (such as production, packaging, quality control and distribution). It does not replace documents such as master batch records; rather, it provides an overview of the company’s overall quality management policy and activities, enabling the regulatory authority to gain a clear and comprehensive understanding of the company before an on-site inspection. The SMF follows a set format and usually includes basic company information, the Quality Management System, personnel and organisational structure, premises and equipment, the document management system, production operations, quality control, distribution/complaint/recall activities and self-inspection. Preparing an SMF requires the systematic review and summary of all relevant company SOPs and policies, presented clearly, concisely and accurately.

📘 Regulatory basis

The PIC/S GMP Guide and EU EudraLex Volume 4 provide detailed guidance on the format and contents of an SMF. The Department of Health in Hong Kong will usually ask licence holders to provide this document when applying for a manufacturer's licence or during a GMP/GDP inspection.

📗 Drew Tang's recommendations

We recommend treating the SMF as the company’s “quality CV”. It should be kept up to date, with any significant changes (such as a change of quality lead or the addition of a new production line) reflected promptly. It should be prepared honestly and accurately, without exaggeration or concealment. A well-written, logically structured SMF can make a professional and rigorous first impression on inspectors. If you lack experience in preparing one, you can seek help from a professional consultant such as Rengangyongsheng (Hong Kong) Limited.

📕 Risk notice

Submitting an SMF that is inaccurate, outdated or seriously inconsistent with actual operations will severely damage your credibility. Inspectors will use the SMF as a blueprint for their on-site checks. Any major discrepancies may be regarded as evidence of data integrity issues or poor management, leading to a more in-depth and rigorous review.

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