Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

I hold a Listed Seller of Poisons (LSP) licence (drug store). Can I sell non-prescription medicines to local customers in Hong Kong through a website or social media?

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

Q71 · Category B: Licence types and scope of application (Q51-Q100)
Hong Kong law currently imposes very strict controls on the sale of medicines over the internet. Even if you hold a Listed Seller of Poisons licence and sell only non-prescription medicines (Part II poisons), you cannot freely sell directly through a website, app or social media platform. Medicines must be sold at your registered physical shop address under the supervision of a “qualified person”. Although you may display products and publish information online, the final transaction and delivery—particularly steps involving confirmation of the customer’s needs and provision of usage advice—must take place at the licensed premises. Any form of distance selling may be considered non-compliant.

📘 Regulatory basis

The core principle of the Pharmacy and Poisons Ordinance is to ensure that medicines are used safely under professional guidance. The current regulatory framework is based on the regulation of physical shops and does not provide a clear lawful route for remote sales, including online sales. The Department of Health takes a conservative and cautious approach to this.

📗 Drew Tang's recommendations

We recommend that clients adopt an “online customer acquisition, offline sales” (O2O) model. You can create a comprehensive product catalogue and provide health information on your website, while setting the purchase button to “collect in store” or “enquire in store”. This lets you benefit from the promotional advantages of the internet while avoiding the risk of breaching regulations. We can help you design compliant website features and user journeys.

📕 Risk notice

Do not attempt any “grey-area” online sales model, such as private transactions through instant messaging apps. The Drug Office is stepping up online surveillance. If clear evidence of online sales is found, disciplinary action may be taken against your licence, including a warning, a fine or even revocation.

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