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What additional regulatory requirements apply in Hong Kong if our medicines need to undergo clinical trials?

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

Q399 · Category H: Licensed operations and routine regulatory oversight (Q351–Q400)
Clinical trials conducted in Hong Kong for the purpose of obtaining pharmaceutical product registration must comply with requirements that are stricter than those for routine medicine management. First, the sponsor (usually a pharmaceutical company) must apply to the Department of Health for a “Certificate for Clinical Trial/Medicinal Test”. The application must include a detailed trial protocol, Investigator’s Brochure, sample informed consent form and approval documents from the ethics committee (IRB/IEC). Second, the labelling, manufacture, packaging and distribution of all investigational medicinal products (IMPs) must meet the specific requirements of GMP and relevant guidelines, ensuring that their quality and blinding are not compromised. Third, all serious adverse events (SAEs) occurring during the trial must be reported to the Department of Health within the prescribed time limits. The entire trial must strictly follow the principles of Good Clinical Practice (GCP).

📘 Regulatory basis

Section 36B of the Pharmacy and Poisons Regulations (Cap. 138A) sets out the requirements for applying for a clinical trial certificate. The International Council for Harmonisation (ICH) E6 guideline, Good Clinical Practice (GCP), is the globally recognised gold standard for clinical trials, and the Hong Kong Department of Health has fully adopted it.

📗 Drew Tang's recommendations

Our recommendation to sponsors planning to conduct clinical trials in Hong Kong: RGYS may assist with document preparation and project coordination within the written scope of services; the respective responsible parties must verify personnel qualifications and statutory roles and take responsibility for professional judgements, while approval is determined independently by the competent authority. Ensuring that your trial protocol is scientifically sound and ethically compliant, and that all documents are fully prepared, is key to obtaining approval. The management of investigational medicinal products requires a separate, highly rigorous supply chain and record-keeping system. RGYS can connect you with leading CRO resources and provide regulatory support throughout the process.

📕 Risk notice

Conducting a clinical trial without prior approval, or seriously breaching GCP principles during a trial, may invalidate the trial data so that it cannot be used for product registration. It may also expose you to legal proceedings and criminal prosecution for endangering participant safety. This is a serious violation of scientific, ethical and legal principles, with extremely serious consequences.

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