Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

What is a “Drug Recall”? In what circumstances might one occur?

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

Q46 · Category A: Pharmacy licensing system and regulatory foundations (Q1-Q50)
A medicine recall is an action to retrieve one or more batches of medicines already distributed on the market. It is an important measure to protect the public from medicines that may pose a risk. A recall may be initiated voluntarily by a manufacturer or distributor, or carried out compulsorily at the request of the Department of Health. Recalls may be triggered by various reasons, most commonly quality issues (such as incorrect ingredient content, impurities or packaging errors), safety issues (such as unexpected serious adverse reactions) or compliance issues (such as incorrect label information or use of unapproved raw materials). Recalls are classified by risk level, from the most urgent Class I recall, requiring retrieval to the patient level, to Class III, requiring retrieval only at the wholesale and retail levels. Licensed wholesalers and manufacturers must establish an effective recall procedure to ensure that, when needed, the distribution of affected medicines can be traced quickly and accurately and downstream customers notified.

📘 Regulatory basis

Both the Good Distribution Practice (GDP) for Pharmaceutical Products and the Good Manufacturing Practice (GMP) for Medicinal Products require licensees to establish written recall procedures and conduct mock recalls regularly to test their effectiveness.

📗 Drew Tang's recommendations

An effective batch tracking system is key to a successful recall. We recommend that clients’ inventory management systems record every goods receipt and dispatch by batch number. The ability to generate an accurate distribution list quickly during a recall is an important measure of your management capability in the regulator’s eyes.

📕 Risk notice

Delaying the reporting of a quality issue requiring recall, or acting slowly and failing to provide transparent information during a recall, will seriously undermine the trust of regulators and the public. The ability to handle a recall is a litmus test of whether a pharmaceutical company is responsible.

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