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There has been a shareholding change in the company holding my wholesale proprietary Chinese medicine licence. Must this be reported to the Chinese Medicine Council (CMRO)?

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

Q405 · Category I: Renewals, changes and penalties for non-compliance (Q401–Q450)
Yes, this is absolutely required. Whenever the directors or shareholding structure of a licensed company wholesaling proprietary Chinese medicines changes, you must notify the Chinese Medicines Board under the Chinese Medicine Council of Hong Kong in writing within 28 days of the change. You must submit details of the change, including identity documents for the new and former directors/shareholders and changes in shareholding percentages. Although a shareholding change does not necessarily require prior approval, notification after the event is mandatory. The Chinese Medicines Board will assess whether the change affects the company's effective control and management to ensure that it continues to meet the licensing requirements.

📘 Regulatory basis

Under the subsidiary legislation of the Chinese Medicine Ordinance (Cap. 549), licence holders are responsible for notifying the regulatory body of any significant change in the company’s control.

📗 Drew Tang's recommendations

We recommend seeking professional advice before any shareholding change transaction. We can help assess whether the background of a new shareholder may raise regulatory concerns and ensure that all notification documents are accurate, avoiding unnecessary scrutiny arising from improper notification.

📕 Risk notice

If you fail to report on time or provide false information, the Chinese Medicines Council has the authority to take disciplinary action against your licence, including issuing a warning letter, suspending the licence or, in extreme cases, revoking it.

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