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What compliance matters should be considered for labels and package inserts of medicines manufactured under cross-border contract manufacturing?

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

Q456 · Category J: Cross-border pharmaceuticals and industry practice (Q451-Q500)
The labels and package inserts for medicines manufactured under cross-border contract manufacturing must comply with the requirements of Hong Kong’s Pharmacy and Poisons Ordinance (Cap.138), including the registration number, batch number, expiry date, ingredients, directions and dosage, and warning information. Labels should be in Chinese and English to ensure that consumers understand them. The licensee should verify that the label information provided by the OEM manufacturer is accurate and contains no misleading information. All labels and package inserts must be reviewed and approved by the Department of Health before use.

📘 Regulatory basis

Section 17 of the Pharmacy and Poisons Ordinance (Cap.138), drug labelling guidance

📗 Drew Tang's recommendations

We recommend that licence holders review label content rigorously to ensure compliance with local regulations and language requirements and avoid legal risks.

📕 Risk notice

Non-compliant labelling may result in medicines being seized and may even lead to consumer complaints and legal proceedings.

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