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Can Hong Kong import and export licences for medicines be used directly for cross-border e-commerce?

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

Q485 · Category J: Cross-border pharmaceuticals and industry practice (Q451-Q500)
Hong Kong import and export licences for medicines mainly apply to the import and export trade in physical goods. Cross-border e-commerce involves online transactions and delivery, and must still comply with the relevant medicine sales and advertising regulations. Cross-border e-commerce sellers must ensure that they hold valid pharmaceutical trade and import and export licences, and that the medicines sold meet Hong Kong’s registration and labelling requirements. Rengangyongsheng (Hong Kong) Limited advises that cross-border e-commerce businesses take platform rules and Hong Kong regulations into account and use import and export licences appropriately and compliantly, to avoid compliance risks arising from differences in online sales models.

📘 Regulatory basis

Sections 18 and 20 of the Pharmacy and Poisons Ordinance (Cap.138); Department of Health guidance on cross-border e-commerce regulation

📗 Drew Tang's recommendations

Cross-border e-commerce sellers should comprehensively assess online and offline compliance requirements and ensure that licences cover every stage of sales

📕 Risk notice

Misusing permits or overlooking online sales compliance may result in regulatory penalties and damage to your reputation.

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