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What qualifications must the person responsible for a “Listed Seller of Poisons” licence have? Does this person need to work full-time?

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

Q60 · Category B: Licence types and scope of application (Q51-Q100)
The key staffing requirement for a “Listed Seller of Poisons” licence (commonly known as a “dispensary licence”) is that the retail business must be continuously and personally supervised by one or more “Competent Persons”. A Competent Person must complete a training course approved by the Pharmacy and Poisons Board (PPB) and pass the relevant assessment, demonstrating sufficient knowledge to advise customers on the safe use of Part II poisons (non-prescription medicines). The law requires at least one Competent Person to be present during the shop's opening hours. Although the law does not expressly require the person to be “full-time”, in practice, covering all opening hours means that the person would need to work full-time or several Competent Persons would need to take turns on duty.

📘 Regulatory basis

Schedule 10 to the Pharmacy and Poisons Regulations (Cap. 138A) sets out in detail the requirements for a “qualified person”, including the content and duration of the training course to be completed. The Code of Practice for Listed Sellers of Poisons issued by the PPB further clarifies their supervisory duties in the shop.

📗 Drew Tang's recommendations

We recommend that the shop owner or key management personnel attend training and obtain the “qualified person” qualification in person. This not only meets regulatory requirements but also gives managers a deeper understanding of medicines and their legal responsibilities. Rengangyongsheng (Hong Kong) Limited can arrange enrolment in a PPB-recognised training course and provide examination preparation support to help you obtain the qualification.

📕 Risk notice

The Department of Health conducts inspections of “drug shops” from time to time to check whether a “qualified person” is present and carrying out their duties. If an inspection finds no “qualified person” on duty, or staff present cannot prove their qualifications, the shop may face a warning, a fine or even temporary suspension of its licence.

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