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HONG KONG DRUG LICENSING

I hold a Listed Seller of Poisons licence. Can I authorise a friend to sell Part II poisons in their shop?

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

Q412 · Category I: Renewals, changes and penalties for non-compliance (Q401–Q450)
Absolutely not. Hong Kong pharmaceutical licences are tied to the premises, not the person: a licence is strictly linked to specific approved licensed premises. Your Listed Seller of Poisons (LSP) Licence only authorises you to sell Part II poisons at the address stated on the licence. You cannot in any way “authorise”, “lend” or “transfer” your licence rights to a third party for use at any other location. Selling regulated medicines at an unauthorised location will be regarded as unlicensed sale.

📘 Regulatory basis

The core principle of the Pharmacy and Poisons Ordinance (Cap. 138) is to regulate the sale of medicines at specific premises; the geographical restriction of licences is a fundamental feature.

📗 Drew Tang's recommendations

If you or your friends wish to sell medicines at a new location, the only lawful option is to apply for a new, separate licence for that address. Do not try to take a shortcut: sharing or lending a licence is a serious regulatory breach.

📕 Risk notice

Your friend’s sales activities at their shop would constitute unlicensed business. As the licence holder, you would also be liable for authorising another person to engage in illegal activities. Your licence would very likely be subject to disciplinary action and could even be revoked.

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