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HONG KONG DRUG LICENSING

Can I set up a temporary stall or mobile vehicle in a Hong Kong shopping centre to sell medicated oils or ointments?

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

Q79 · Category B: Licence types and scope of application (Q51-Q100)
No. Hong Kong medicine sale licences, whether a “pharmacy” licence or a “medicine shop” licence, are linked to a fixed, registered business address. The law requires all regulated medicine sales to take place at licensed premises inspected and approved by the Department of Health. This means that you cannot sell any products classified as “pharmaceutical products” at temporary, unregistered locations, such as a short-term stall in a shopping centre atrium, a trade fair booth or a mobile vehicle, even if the products are non-prescription medicines such as medicated oils or ointments. Such conduct would be regarded as unlicensed sale from unapproved premises.

📘 Regulatory basis

The Pharmacy and Poisons Ordinance provides that a licence authorises operations at a “specified address”. Conducting sales activities anywhere other than the registered address exceeds the scope of the licence and constitutes an offence.

📗 Drew Tang's recommendations

If you wish to use footfall in a shopping centre for promotion, you can adopt a display-only, no-sales approach. You can display product samples at your stand, distribute promotional leaflets, provide advice and direct interested customers to a nearby licensed physical shop to make their purchases. This achieves your promotional aims while avoiding legal risks. We can help you liaise with the shopping centre and the Department of Health before the event to ensure your promotional activities comply with requirements.

📕 Risk notice

Do not take chances and assume that the Department of Health and Customs and Excise Department will not inspect trade fairs and exhibitions. If actual medicine sales are found at a temporary stall, enforcement officers will stop them immediately and may seize all products and prosecute the relevant companies and individuals.

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