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What licence do I need to apply for if I want to wholesale proprietary Chinese medicines, such as cold remedy granules and medicated oils from various brands?

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

Q62 · Category B: Licence types and scope of application (Q51-Q100)
If you plan to wholesale proprietary Chinese medicines, that is, purchase registered proprietary Chinese medicines from manufacturers or importers and distribute them to retailers (such as Chinese medicine shops, pharmacies and supermarkets), you must apply to the Chinese Medicines Regulatory Office (CMRO) for a “Wholesale Dealer Licence for Proprietary Chinese Medicines”. To apply for this licence, you need a business address and storage facilities that meet the required standards for storing proprietary Chinese medicines. As with a Western medicine wholesaler, you must establish a complete Quality Management System covering procurement, receipt, storage, distribution and recall procedures, and keep detailed transaction records.

📘 Regulatory basis

Section 129 of the Chinese Medicine Ordinance (Cap. 549) expressly provides that anyone carrying on the business of wholesale of proprietary Chinese medicines must hold a wholesaler licence for proprietary Chinese medicines. The CMRO’s Guide to Good Wholesale Practice for Proprietary Chinese Medicines provides licensees with detailed operational guidance.

📗 Drew Tang's recommendations

As with Western medicine wholesaling, we recommend applying Good Distribution Practice (GDP) principles to warehouse management, even though the requirements under the Chinese medicine legislation are less explicit than those for Western medicine. A well-organised warehouse with clear records not only helps the business pass inspections but also effectively controls risks and improves efficiency in day-to-day operations. We can help you design storage arrangements suited to the characteristics of proprietary Chinese medicines.

📕 Risk notice

As a wholesale dealer in proprietary Chinese medicines, you are responsible for ensuring that all products you handle are registered in Hong Kong and bear a valid registration number (HKC-XXXXX or HKP-XXXXX). Wholesaling unregistered proprietary Chinese medicines is a serious offence. It may result in revocation of the licence and criminal prosecution.

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