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What are the consequences if no registered pharmacist is on duty during a pharmacy’s business hours?

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

Q436 · Category I: Renewals, changes and penalties for non-compliance (Q401-Q450)
A registered pharmacist (RP) must be physically present on duty at a pharmacy (Authorised Seller of Poisons) at all times during its business hours. This is a mandatory legal requirement. If no RP is present during business hours, the pharmacy must not sell any medicines required to be sold under supervision (that is, Part I and Part III poisons). If a Department of Health inspector finds a “ghost pharmacy” (a pharmacy operating without a pharmacist on duty), this will constitute a serious breach. The licence holder and/or company directors may be held responsible and are very likely to face disciplinary proceedings, which may result in a warning, suspension or revocation of the licence.

📘 Regulatory basis

The Pharmacy and Poisons Regulations (Cap. 138A) expressly provide that medicines for sale under supervision must be sold under the supervision of a registered pharmacist.

📗 Drew Tang's recommendations

Appropriate pharmacist rostering and a backup plan are vital to pharmacy operations. We recommend that clients establish working relationships with several pharmacists, both full-time and part-time, to ensure regulatory requirements can be met in all circumstances and to avoid being forced into non-compliance or closure because of staff shortages.

📕 Risk notice

“Snakehead pharmacies” are a target of strict enforcement by regulators because they directly endanger public medicine safety. If a business is classified as a “snakehead pharmacy”, it will generally face very severe penalties. Do not take any chances.

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