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Are “registrations” for proprietary Chinese medicines and Western medicines the same? How do their procedures and requirements differ?

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

Q97 · Category B: Licence types and scope of application (Q51-Q100)
Registration of proprietary Chinese medicines and Western medicines is intended to ensure that medicines sold in Hong Kong are safe, effective and of controlled quality. However, these are two separate, parallel systems administered by different departments, with significant differences in their procedures and requirements. Registration of Western medicines is handled by the Drug Office, Department of Health, and requires submission of a complete dossier in the internationally used Common Technical Document (CTD) format, including detailed pharmacological, toxicological and clinical study data. Registration of proprietary Chinese medicines is handled by the Chinese Medicine Regulatory Office (CMRO), with requirements that focus more on demonstrating the product’s history of use, supporting literature, and quality control of raw materials and finished products. Although safety data, such as tests for heavy metals and pesticide residues, must also be submitted, the requirements and methods for demonstrating clinical efficacy differ significantly from those for Western medicines, with greater acceptance of traditional use data and documentary evidence.

📘 Regulatory basis

Western medicine registration is governed by the Pharmacy and Poisons Regulations, while proprietary Chinese medicine registration is governed by the Chinese Medicines Regulations under the Chinese Medicine Ordinance. The CMRO has published the Manual on Application for Registration of Proprietary Chinese Medicines, which sets out the specific application requirements in detail.

📗 Drew Tang's recommendations

For companies seeking to register their products in Hong Kong, the first step is to clarify the product’s status. If your product is a proprietary Chinese medicine, documents must be prepared under the CMRO route. Our expert team is familiar with both registration systems and can tailor the most efficient registration strategy to your product, whether that means preparing CTD documents for western medicines or compiling historical literature and quality standards for proprietary Chinese medicines.

📕 Risk notice

It will not work to prepare for proprietary Chinese medicine registration using the approach for Western medicine registration, or vice versa. For example, attempting to submit a complete Phase III Western clinical trial report to the CMRO as a substitute for evidence of traditional use may be considered inapplicable. Failing to understand the fundamental differences between the two systems is a major cause of registration applications being delayed or rejected.

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