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HONG KONG DRUG LICENSING

Can a medicine approval document provided by a Mainland OEM manufacturer be used directly for a Hong Kong medicine licence application?

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

Q453 · Category J: Cross-border pharmaceuticals and industry practice (Q451-Q500)
A medicine approval number (approval document) issued to a Mainland OEM manufacturer cannot directly replace a Hong Kong Certificate of Drug/Product Registration. A Hong Kong medicine licence application must include a complete set of registration information in accordance with local regulations, including evidence of quality, safety and efficacy. Although Mainland documents may be used as reference material, the Drug Office, Department of Health must still conduct an independent review and grant approval. Applicants should prepare information that meets Hong Kong standards, including the product insert, GMP certificate and test reports, and ensure compliance with the Pharmacy and Poisons Ordinance (Cap. 138).

📘 Regulatory basis

Section 16 of the Pharmacy and Poisons Ordinance (Cap.138), Guidance on Drug Registration Procedures

📗 Drew Tang's recommendations

We recommend that applicants submit mainland approvals as supporting documents while also preparing the complete registration documents required in Hong Kong, to avoid approval delays due to document discrepancies.

📕 Risk notice

Using approval documents from Mainland China in place of Hong Kong registration documents may result in the application being rejected or create a risk of illegal sales.

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