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How can I find out which Chinese herbal medicines are toxic Chinese herbal medicines listed in Schedule 1 or Schedule 2?

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

Q448 · Category I: Renewals, changes and penalties for non-compliance (Q401-Q450)
The most authoritative way to identify the toxic Chinese herbal medicines listed in Schedules 1 and 2 to the Chinese Medicine Ordinance (Cap. 549) is to consult the text of the Ordinance. Schedule 1 lists 31 “highly toxic” Chinese herbal medicines, such as nux vomica and Sichuan aconite, while Schedule 2 lists 579 “toxic” Chinese herbal medicines, such as aconite and pinellia. The official website of the Chinese Medicine Council of Hong Kong will generally also make these lists available for public reference. As a practitioner, you are responsible for familiarising yourself with them. When purchasing and selling these herbal medicines, you must manage them with particular care, for example by storing them separately and clearly labelling them. When selling Schedule 1 herbal medicines, you must also record purchaser details as required.

📘 Regulatory basis

Schedules 1 and 2 of the Chinese Medicine Ordinance (Cap. 549) provide the legal basis for distinguishing and regulating toxic Chinese herbal medicines.

📗 Drew Tang's recommendations

We recommend that clients print out these two schedules and display them in the purchasing and sales departments, and provide dedicated training to relevant staff to ensure they can accurately identify these herbal medicines. These medicines should also be specially flagged in your computerised inventory system as a warning.

📕 Risk notice

Improper handling or sale of these toxic Chinese herbal medicines, such as confusing them with ordinary herbal medicines or failing to sell them in accordance with requirements, is a very serious violation. If this causes poisoning or harm to a patient’s health, you may face serious criminal prosecution and substantial civil liability.

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