Absolutely not. Holding a “wholesaler’s licence” does not mean that you can sell medicines to anyone. Your customer base is strictly restricted by law. You may sell pharmaceutical products only to the following eligible customers: 1. Other licensed wholesalers; 2. Licensed manufacturers; 3. Authorised Sellers of Poisons (ASPs) (pharmacies); 4. Listed Sellers of Poisons (LSPs) (medicine shops, but only for the sale of Part II poisons); 5. Doctors, dentists or veterinary surgeons registered in Hong Kong, for their professional use; and 6. Specified hospitals, clinics, academic institutions or government departments. You must not sell any medicines, directly or indirectly, to end consumers, that is, members of the public.
HONG KONG DRUG LICENSING
I hold a Wholesale Dealer Licence. Can I sell medicines to anyone? What restrictions apply to customers?
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.
Back to Category B: Licence Types and Scope of Application (Q51-Q100) Search more questions