This depends on the specific contents of the first-aid kit. If it contains only non-medicated items, such as bandages, gauze, adhesive tape and scissors, as well as disinfectants that are not classified as “pharmaceutical products” (for example, low-concentration chlorhexidine or cetrimide disinfectant), a pharmaceutical licence is generally not required to sell the kit. However, if it contains any item classified as a Part I or Part II poison, such as an antibiotic ointment, a strong painkiller or a disinfectant at a specified concentration, the whole kit will be regarded as a combined medicinal pack and its sale will be regulated under the Pharmacy and Poisons Ordinance. You will need to hold at least a Listed Seller of Poisons (LSP) licence to sell it.
HONG KONG DRUG LICENSING
Do I need a pharmaceutical licence if I only want to sell first-aid kits containing disinfectant and bandages?
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.
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