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How is the regulation of “Chinese medicine granules” different from that of traditional Chinese herbal decoction pieces? What licence do I need to operate?

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

Q87 · Category B: Licence types and scope of application (Q51-Q100)
Formula granules for Chinese medicine (commonly known as ‘Chinese medicine granules’) are standardised granules made by extracting, concentrating and drying traditional Chinese herbal medicines and decoction pieces using modern technology. In Hong Kong, they are treated as a special form of Chinese medicine and are regulated between traditional Chinese herbal medicines and proprietary Chinese medicines. To trade in these products, you need a wholesaler’s and/or retailer’s licence for Chinese herbal medicines. However, because their production involves complex extraction and formulation processes, the Chinese Medicine Council of Hong Kong applies higher quality standards. Suppliers must be able to provide detailed quality documentation demonstrating that their granules meet Hong Kong standards for identification, content, pesticide residues, heavy metals and other aspects.

📘 Regulatory basis

At present, Chinese medicine granules are mainly regulated by reference to the provisions for Chinese herbal medicines under the Chinese Medicine Ordinance. The Chinese Medicine Council of Hong Kong has also issued the Hong Kong Chinese Materia Medica Standards and specific quality guidance for granules as important technical references for market regulation.

📗 Drew Tang's recommendations

If you plan to deal in Chinese medicine granules, choosing a reliable, compliant supplier is key to success. You must require the supplier to provide a Certificate of Analysis (COA) for every batch and ensure that it meets Hong Kong standards. Before signing a contract with a supplier, we recommend that you ask us to review its full set of qualifications and quality documents to avoid introducing non-compliant products.

📕 Risk notice

The quality of formula granules on the market varies. If the granule products you sell are found to contain insufficient active ingredients or excessive contaminants, you as the seller will bear direct legal responsibility. This may not only damage your reputation but also affect your Chinese medicine licence.

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