Generally, if your logistics company (a third-party logistics provider, or 3PL) only provides warehouse space and transport vehicles, while ownership of the medicines and ultimate responsibility for quality management remain with your client—the licensed medicines wholesaler—your logistics company does not itself need to apply for a wholesale licence. However, your facilities and services must meet the wholesaler’s compliance requirements and be subject to its supervision and audit. This means that your warehouse must comply with GDP principles, such as temperature and humidity control and monitoring, good security and clearly defined zones. You must operate strictly in accordance with the Quality Agreement signed with your client.
HONG KONG DRUG LICENSING
I am a logistics company providing storage and transport services to licensed pharmaceutical wholesalers. Does my company need to apply for a pharmaceutical licence?
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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