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How do the procedures differ for changing a pharmacy’s registered pharmacist (RP) and a pharmaceutical manufacturer’s Authorised Person (AP)?

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

Q414 · Category I: Renewals, changes and penalties for non-compliance (Q401–Q450)
Both are changes to key personnel, but the regulatory requirements and procedures differ. A pharmacy’s registered pharmacist (Registered Pharmacist, RP) is a key person responsible for supervising the sale of medicines, and a change must be notified to the Pharmacy and Poisons Board. By contrast, an “Authorised Person” (AP) of a manufacturer or wholesaler is a key quality person responsible for ensuring that the manufacture and batch release of medicines comply with GMP/GDP requirements. A change of AP requires an application to the Drug Office, Department of Health, and approval must be obtained. The scrutiny of qualifications and experience is more rigorous. In brief, a change of AP is an approval process, whereas a change of RP is primarily a prompt notification procedure.

📘 Regulatory basis

The RP requirement stems from the provisions on pharmacy sales in the Pharmacy and Poisons Regulations. The AP requirement stems from the quality management requirements for manufacturing under the Pharmacy and Poisons (Manufacturers and Wholesalers) Regulations.

📗 Drew Tang's recommendations

Whether an RP or AP leaves, a seamless handover must be ensured. In particular, pharmacies are prohibited from selling any medicines for sale under supervision when no RP is on duty. Staff cover must be planned in advance to avoid an interruption to business.

📕 Risk notice

Manufacturing or releasing medicines without a qualified AP is a very serious breach that may directly lead to suspension of the Manufacturer of Pharmaceutical Products licence. Selling medicines subject to pharmacist supervision without an RP may also result in disciplinary action.

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