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What is the difference between licence ‘suspension’ and ‘revocation’ (Revocation/Cancellation)?

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

Q432 · Category I: Renewals, changes and penalties for non-compliance (Q401-Q450)
“Suspension” and “revocation” are disciplinary measures of different severity. “Suspension” temporarily suspends your licence for a specified period, such as 14 or 30 days, during which you may not carry out any licensed activities. After the suspension period, the licence may be reinstated if specific conditions are met. “Revocation” is the most severe measure: your licence is permanently cancelled and your licensed status terminated. Once your licence is revoked, you lose the right to conduct the relevant business at those premises. This is generally imposed for very serious breaches or where the licence holder is found no longer to be a “Fit and Proper Person”.

📘 Regulatory basis

Both the Pharmacy and Poisons Ordinance (Cap. 138) and the Chinese Medicine Ordinance (Cap. 549) confer disciplinary powers on regulators to suspend or revoke licences.

📗 Drew Tang's recommendations

Any breach that results in a licence suspension should be treated as a final warning. You must immediately undertake thorough internal reform and process redesign, and demonstrate your determination and ability to return to compliance to the regulator, to avoid moving towards revocation.

📕 Risk notice

Revocation of a licence is tantamount to an almost irreversible commercial death sentence. The relevant records are kept permanently. Not only does the current business come to an end, but the future industry reputations of the company and its key persons are also severely damaged, making it extremely difficult to re-establish themselves in the same field.

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