Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
Hong Kong pharmaceutical compliance · applications / acquisitions / ongoing maintenance Independent Third-Party Service Provider
HONG KONG DRUG LICENSING

I plan to import and wholesale a pharmaceutical product that is not yet registered in Hong Kong. What additional procedures are required?

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

Q57 · Category B: Licence types and scope of application (Q51-Q100)
In Hong Kong, all pharmaceutical products must be registered with the Pharmacy and Poisons Board (PPB) and obtain a Hong Kong registration number (HK-XXXXX) before they may be sold on the market. If you plan to import and wholesale a medicine that is not yet registered in Hong Kong, you must first act as the product’s local agent and submit a “pharmaceutical product registration application” to the Drug Office, Department of Health. This is a complex process requiring extensive technical documentation, including chemistry, manufacturing and controls (CMC) information, preclinical and clinical study data, and stability study reports, to demonstrate the medicine’s safety, efficacy and quality. You may lawfully import and sell the product only after obtaining a Certificate of Drug Registration and using it together with your wholesale dealer licence.

📘 Regulatory basis

Section 36 of the Pharmacy and Poisons Regulations (Cap. 138A) provides that all pharmaceutical products sold in Hong Kong must be registered unless exempted. The documents and procedures required for registration are explained in detail in the Department of Health’s Guidance Notes on Registration of Pharmaceutical Products.

📗 Drew Tang's recommendations

Pharmaceutical product registration is highly specialised and time-consuming, usually requiring 12 to 24 months or even longer. We recommend conducting a comprehensive assessment of the product's market potential and registration feasibility before launching the project. RGYS may assist with organising product documentation and project communications within the written scope; professional pharmaceutical judgments, statutory sign-off and regulatory assessment are the responsibility of legally qualified personnel and competent authorities. We can handle the entire process for you, from document review, translation of materials and communication with overseas manufacturers to submitting the application to the Department of Health.

📕 Risk notice

Dealing in unregistered pharmaceutical products is a serious offence. Even if you hold a Wholesale Dealer Licence, you must not deal in unregistered medicines. In addition, if the registration documents submitted are incomplete or do not meet the requirements, the application will be returned, substantially extending the time to market and increasing commercial costs.

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Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

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