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As a licensed retailer of Chinese herbal medicines, what conduct would be considered non-compliant?

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

Q407 · Category I: Renewals, changes and penalties for non-compliance (Q401–Q450)
Common violations by licensed retailers of Chinese herbal medicines mainly fall into several categories. First, “adulteration or substitution”, meaning that the Chinese herbal medicines sold do not match the varieties indicated on the labels, or that other substances have been added. Second, non-compliant labelling, such as failing to state the name, origin, batch number or expiry date of the Chinese herbal medicines as required. Third, improper storage, with inadequate storage conditions to prevent deterioration, mould or contamination. Fourth, failing to record purchaser details as required when selling toxic Chinese herbal medicines listed in Schedule 1 or Schedule 2. Finally, operating beyond the scope of the licence, such as also selling proprietary Chinese medicines, is a violation.

📘 Regulatory basis

The Chinese Medicine Ordinance (Cap. 549) and its subsidiary legislation, particularly the Chinese Medicines Regulation, set out in detail the requirements for the retail of Chinese herbal medicines, labelling and storage.

📗 Drew Tang's recommendations

We recommend that clients establish a strict internal control system, including supplier audits, quality inspection of incoming goods (SOP), and clear labelling and stock management systems. Regular staff training is also essential to ensure that everyone understands the legal requirements.

📕 Risk notice

Any breach may result in disciplinary action by the Chinese Medicine Council. Serious breaches affecting public health, particularly the sale of adulterated or poisonous herbal medicines, may not only put the licence at risk of revocation but may also lead to criminal prosecution.

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