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I hold a Wholesale Dealer Licence for western medicines. Can I occasionally sell small quantities of medicines to end consumers?

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

Q422 · Category I: Renewals, changes and penalties for non-compliance (Q401-Q450)
Absolutely not. The type of licence strictly defines the scope of your business. A Wholesale Dealer Licence authorises you to supply medicines to specified parties, such as other licensed wholesalers, licensed manufacturers, registered pharmacies, hospitals and registered doctors. It is, by nature, a B2B (business-to-business) activity. You must not sell medicines directly to end consumers, regardless of the quantity. Direct sales of regulated medicines to the public are the exclusive right of an Authorised Seller of Poisons (ASP) (pharmacy) or a Listed Seller of Poisons (LSP).

📘 Regulatory basis

The Pharmacy and Poisons Regulations (Cap. 138A) clearly define the scope of authorisation for different licence types. Operating outside that scope is an explicit breach.

📗 Drew Tang's recommendations

Please provide rigorous training to your sales team to ensure they clearly understand the types and qualifications of customers. Establishing a customer qualification review procedure to verify a customer's licence or registration status before opening an account is an effective way to prevent non-compliant sales.

📕 Risk notice

Selling medicines to the public as a wholesaler not only breaches your licence conditions and may result in disciplinary action, but may also be regarded in law as unlicensed retailing, exposing you to the risk of criminal prosecution.

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