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What qualifications must Hong Kong sellers have to sell medicines on cross-border e-commerce platforms such as Tmall Global?

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

Q482 · Category J: Cross-border pharmaceuticals and industry practice (Q451-Q500)
Hong Kong sellers using cross-border e-commerce platforms such as Tmall Global to sell medicines must hold the relevant Hong Kong pharmaceutical licences and obtain the corresponding import and export licences. Under sections 18 and 20 of the Pharmacy and Poisons Ordinance (Cap. 138), sales of regulated medicines must comply with the applicable requirements and use lawful sales channels. Platforms will also require sellers to provide proof of their qualifications. Rengangyongsheng (Hong Kong) Limited recommends that sellers consult the platform and the Hong Kong Department of Health in advance to ensure that all necessary qualifications are in place and avoid the risks of non-compliant sales.

📘 Regulatory basis

Sections 18 and 20 of the Pharmacy and Poisons Ordinance (Cap.138); relevant cross-border sales rules of Tmall Global

📗 Drew Tang's recommendations

We recommend that sellers ensure they have the necessary medicine licences and import/export permits, and maintain communication with the platform's compliance team to avoid missing qualifications

📕 Risk notice

Selling medicines without the required qualifications may result in a platform ban and even enforcement action by Hong Kong regulatory authorities.

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