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HONG KONG DRUG LICENSING

Can Hong Kong pharmacies dispense medicines against prescriptions issued by overseas doctors?

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

Q75 · Category B: Licence types and scope of application (Q51-Q100)
This is a common question about choosing premises. The answer is: it is theoretically possible, but very stringent conditions must be met in practice. The Drug Office, Department of Health, requires areas used to store pharmaceutical products to be physically separated, secure and dedicated to that purpose. This means that you cannot simply set aside a corner of an open-plan office for storing pharmaceutical products. You must establish a separate, access-controlled room or warehouse area, with walls, ceiling and floor that meet the requirements. More importantly, the entire premises, including office and storage areas, must be suitable for commercial use, and the building’s Deed of Mutual Covenant (DMC) must not prohibit the storage of pharmaceutical products. You must also ensure that the storage area has effective, independent temperature and humidity control, fire protection and security systems. Therefore, although a combined office-and-warehouse model is possible, the renovation and compliance costs may be substantial.

📘 Regulatory basis

The Pharmacy and Poisons Regulations define “prescription” clearly and require it to be issued for a particular patient by a “registered medical practitioner”, “registered dentist” or “registered veterinary surgeon”. “Registered” here means registered with the relevant professional board in Hong Kong.

📗 Drew Tang's recommendations

The correct approach is to advise patients with overseas prescriptions to consult a registered doctor in Hong Kong. Patients may show the Hong Kong doctor their overseas medical records and prescription for reference. The Hong Kong doctor can then exercise their professional judgement and issue a new, valid local prescription. The patient can obtain the medicine from a pharmacy using this new prescription. This is the only compliant way to protect patients’ safety in the use of medicines.

📕 Risk notice

If a pharmacy pharmacist dispenses medicines against an overseas prescription for convenience or commercial gain, and this is discovered, it will be treated as the sale of prescription medicines without a prescription. This is a very serious case of professional misconduct and an offence. Not only may the pharmacy’s licence be affected; the pharmacist on duty may also have their personal registration revoked.

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