Do I need a pharmaceutical licence if I only provide warehousing or logistics services to pharmaceutical manufacturers?

Yes, it is highly likely to be required. Under Hong Kong's GDP requirements, a third-party logistics provider (3PL) that provides medicine storage and transport services must apply for a Wholesale Dealer Licence if its services form part of the medicine distribution chain. Merely providing a “warehouse” or “delivery vehicle” is not sufficient; you must establish a complete Quality Management System (QMS) that complies with GDP requirements. This includes appointing a qualified responsible person, qualifying your storage facilities and cold-chain vehicles, establishing Standard Operating Procedures (SOPs) for receiving, storage, picking, packing and transport of medicines, and having contingency plans for handling deviations and emergencies. The Department of Health considers the quality and safety of medicines to be critical at every stage of the supply chain. Therefore, even if you do not own the medicines, you assume responsibility for safeguarding their quality if you physically handle and store them, and are subject to regulation.