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Can applications be made at the same time for the Chinese herbal medicine wholesaler and proprietary Chinese medicine wholesaler licences?

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

Q63 · Category B: Licence types and scope of application (Q51-Q100)
Yes. If your business covers wholesale of both Chinese herbal medicines (such as crude herbal medicines and prepared slices) and proprietary Chinese medicines (such as capsules, pills and medicinal oils), you may, and must, apply for both a wholesaler’s licence for Chinese herbal medicines and a wholesaler’s licence for proprietary Chinese medicines. Both licences are approved by the Chinese Medicines Regulatory Office (CMRO), but they are different licence categories. You may operate from the same business address and warehouse, but must demonstrate to the CMRO that you can effectively manage the two types of products separately and prevent confusion. Your Quality Management System and record-keeping system must also be able to manage and trace the movement of Chinese herbal medicines and proprietary Chinese medicines separately.

📘 Regulatory basis

The Chinese Medicine Ordinance (Cap. 549) sets out separate licensing requirements for wholesale of Chinese herbal medicines (section 119) and wholesale of proprietary Chinese medicines (section 129). Accordingly, anyone carrying on both businesses must apply for two licences.

📗 Drew Tang's recommendations

When submitting the application, we can prepare an integrated application plan that clearly shows the CMRO how you will meet the compliance requirements for both licences within a unified management framework. For example, clearly marking the dedicated storage areas for Chinese herbal medicines and proprietary Chinese medicines, as well as quarantine and returned goods areas, on the warehouse layout plan will create a professional and thorough impression on the reviewing officer.

📕 Risk notice

In daily operations, the inventory and records for the two product categories must be strictly separated. For example, batch management and traceability requirements for Chinese herbal medicines may differ from those for proprietary Chinese medicines. Disorganised records will not only cause difficulties during routine inspections; if a product quality issue requires a recall, they may also prevent you from quickly and accurately identifying the affected products, leading to greater losses.

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