Hong Kong Drug Licence Applications and Acquisitions · RGYS|Global Licensing and Compliance Service Provider
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HONG KONG DRUG LICENSING

Hong Kong Drug Licence FAQs

Search 500 Hong Kong drug licence FAQs on applications, personnel, premises, quality systems, ongoing regulation, renewals and acquisitions.

Information status: The original FAQ material dates from 2025 and is provided for topic-based reference; it does not represent an individual verification of all 500 FAQs against current rules. For application, fee, renewal, change, product or prescription requirements, please refer to the current official forms and guidance.

Official information from the Drug Office Official information from the Chinese Medicines Board

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Q151 · 申请香港药品批发商牌照,对营业处所的最低面积有无具体要求?独立链接
When assessing applications for pharmaceutical wholesale dealer licences, the Drug Office, Department of Health, does not prescribe a minimum floor area for business premises in the regulations. This does not mean, however, that any floor area will suffice. The key principle is that “the area of the premises must be appropriate to the scale of the business and the types of medicines handled”. Inspectors will assess a range of factors, including the quantity and types of medicines you plan to store and handle, their storage requirements (such as ambient temperature or refrigeration), and whether processing or packaging will be required. If a space is too small to meet functional zoning requirements—for example, if it has no separate quarantine area pending examination, released-goods area, returns area or office—or if medicines are stored in a disorderly manner with a high risk of cross-contamination, the licence application is very likely to be refused. The floor area should therefore be sufficient to clearly separate each functional area and ensure the safe, orderly storage and handling of medicines.

📘 Regulatory basis

Under the Pharmacy and Poisons Regulations (Cap. 138A) and the Good Distribution Practices published by the Department of Health, a wholesaler’s premises must have sufficient space to enable all operations to be carried out in an orderly manner and to ensure the proper segregation of different categories of medicines.

📗 Drew Tang's recommendations

At Rengangyongsheng (Hong Kong) Limited, we generally recommend that even a start-up pharmaceutical wholesale business have a usable area of at least 80-100 square metres. This area can accommodate the necessary office, storage and operating areas, while leaving some room for future business growth. When choosing premises, be sure to prepare a detailed premises layout plan clearly identifying each functional area; this is a key document for submitting an application.

📕 Risk notice

Do not choose premises that are too small just to save on initial rent. If the Department of Health gives a negative assessment during an on-site inspection because the premises are too small, you may have to find new premises and renovate them, causing serious delays and financial losses. A record of a rejected application may also adversely affect future applications.

Q152 · What are the key principles for planning a medicine warehouse layout to meet Department of Health requirements?Direct link
The layout of a medicine warehouse is key to ensuring medicine quality and safety. It must follow the principles of clear workflow, physical segregation and prevention of cross-contamination. First, clearly defined functional areas must be established, including receiving, quarantined goods pending examination, released goods, non-conforming goods (including returned, recalled, expired or damaged medicines) and dispatch areas. There should be clear physical boundaries between areas, for example, walls, partitions or clearly marked floor areas. Second, the layout should ensure a one-way workflow from receiving to dispatch, without crossing paths, to avoid confusion between medicines that have passed examination and those pending examination or deemed non-conforming. In addition, dedicated storage areas meeting the relevant requirements must be provided for medicines with special storage conditions (such as refrigeration, protection from light or controlled poisons).

📘 Regulatory basis

Good Distribution Practice (GDP) expressly requires the design and layout of premises to minimise the risk of errors and allow effective cleaning and maintenance. It particularly emphasises the separation of receiving, storage and dispatch areas, and the need for dedicated areas for special materials.

📗 Drew Tang's recommendations

When planning the layout, consider using a racking system instead of storing goods on the floor. This makes effective use of vertical space and better supports the ‘first expiry, first out’ (FEFO) / ‘first in, first out’ (FIFO) inventory management principles. In the warehouses we help clients design, each rack and storage location is usually coded and integrated with the warehouse management system (WMS), enabling precise location and traceability. This creates a highly professional impression when Drug Office officers inspect the premises.

📕 Risk notice

A confusing layout is one of the common reasons for a licence application to fail. If the quarantine area is not physically segregated from the released goods area, or returned medicines are left near released goods, this will be regarded as a serious breach. Such confusion may result in non-conforming medicines being dispatched in error, leading to a serious public health incident and exposing the company to the risk of licence revocation and legal proceedings.

Q153 · What specific technical requirements apply to temperature and humidity control systems for medicines requiring temperature-controlled storage?Direct link
For medicines requiring constant-temperature storage (usually in the range of 15-25°C), the temperature and humidity control system is a core facility for ensuring medicine stability. The technical requirements mainly include the following. First, a commercial-grade air-conditioning system capable of covering the entire storage area and operating continuously must be installed. Second, calibrated temperature and humidity loggers must be installed at multiple representative locations in the warehouse for uninterrupted 24/7 monitoring. These locations should include the centre and corners of the warehouse, and areas near doors, windows or heat sources. Third, the system must have high- and low-temperature alarms that immediately notify designated personnel by audible and visual alerts, text message or email when temperature or humidity falls outside the preset range. Finally, all temperature and humidity data must be fully recorded and retained for at least one year after the medicines’ expiry dates, so that the Department of Health can inspect them at any time.

📘 Regulatory basis

The Good Distribution Practice (GDP) requirements under the Pharmacy and Poisons Ordinance require storage conditions to be controlled and monitored. Medicines requiring storage at a specific temperature should be monitored continuously using appropriate equipment (such as temperature and humidity data loggers), and relevant records must be kept. Equipment calibration is also mandatory.

📗 Drew Tang's recommendations

We strongly recommend that clients invest in an automated, cloud-based temperature and humidity monitoring system. Such systems not only provide real-time data and remote alerts, but can also automatically generate reports that meet regulatory requirements, greatly reducing the burden and risk of errors associated with manual record-keeping. When selecting equipment, be sure to obtain and check the supplier's Calibration Certificate, and establish an annual calibration plan.

📕 Risk notice

Installing a household air conditioner alone is wholly inadequate. Department of Health officers will carefully examine the continuity and completeness of temperature and humidity records and whether probe placement is appropriate. Any interruption in records, missing data or unrepresentative probe locations may result in an unsatisfactory inspection. Uncontrolled temperature and humidity may cause pharmaceutical products to degrade and lose efficacy, resulting in a serious quality issue.

Q154 · How should a medicine warehouse be effectively divided into zones, such as areas for quarantined goods pending examination, released goods and returned goods?Direct link
Effective zoning is fundamental to preventing medicine mix-ups and cross-contamination. First, each functional area must be clearly physically separated. Separate rooms or solid walls are ideal; if this is not possible, sturdy partitions, barriers or cage trolleys must be used to create clear separation. Second, every area must have prominent, firmly affixed signs naming the area in both Chinese and English, such as “待验区/Quarantine Area”, “合格品区/Approved Stock Area” and “不合格品区/Rejected Stock Area”. Third, the movement of materials between areas must be strictly controlled by procedures. For example, all newly received medicines must first be placed in the quarantine area. They may only be moved to the released goods area after inspection by the quality control department and issue of release authorisation. Any returned, recalled or damaged medicines must be isolated immediately in the non-conforming goods area pending further action.

📘 Regulatory basis

Good Distribution Practice (GDP) is explicit about functional segregation. It states that “physically separated areas or areas separated by other effective means should be provided for the storage of medicines pending examination, non-conforming medicines, returned medicines or recalled medicines” to prevent them from entering saleable stock without authorisation.

📗 Drew Tang's recommendations

We recommend that clients use different-coloured paint or tape on the floor to mark the boundaries of each area. This is a low-cost and highly visible way to reinforce zoning controls. For example, use yellow for the quarantine area, green for released goods, and red for non-conforming goods. This visual management approach can effectively reduce operator errors and is well regarded by Department of Health officials.

📕 Risk notice

A single line of adhesive tape or a verbal instruction is far from sufficient to define a segregated area. The Department of Health requires “effective segregation”. If products with different statuses are found stored in the same area or are not clearly labelled during an inspection, this will be treated as a serious deficiency. This may not only result in the licence application failing, but also require the relevant operations to cease immediately until the deficiency is rectified.

Q155 · 经营需要冷链储存的生物制剂,冷链设施(如冷库、冷藏车)需要满足哪些认证标准?独立链接
When handling medicines that require cold-chain storage, such as vaccines and insulin, cold-chain facilities must meet very stringent standards to ensure that the medicines remain within the specified temperature range (usually 2-8°C) throughout storage and transport. First, cold rooms and refrigerated vehicles must undergo a professional Temperature Mapping Study to demonstrate that temperatures at all points inside can be kept consistently within the required range. This validation must be carried out under both empty and fully loaded conditions. Second, all temperature-controlled equipment, including cold rooms, refrigerators, refrigerated vehicles and portable coolers, must be equipped with independent, calibrated temperature monitoring and alarm systems. Third, detailed Standard Operating Procedures (SOPs) must be established to cover all aspects, including routine use, cleaning, maintenance, calibration and emergency response (such as power failure). During transport, validated insulated shippers must be used together with temperature data loggers that record temperatures throughout the journey.

📘 Regulatory basis

The Department of Health’s Good Distribution Practice (GDP) and guidelines issued by the Pharmacy and Poisons Board (PPB) contain specific sections on cold-chain management. They explicitly require validation and qualification of cold-chain equipment, and set out detailed requirements for temperature records and deviation handling.

📗 Drew Tang's recommendations

We strongly recommend that clients engage a professional third-party service provider to conduct temperature mapping and issue an authoritative validation report. This is the strongest evidence of your cold-chain capabilities to present to the Department of Health. For refrigerated transport, if you do not plan to purchase your own refrigerated vehicle initially, you may work with a third-party logistics company qualified to transport medicines and able to provide full temperature data throughout the journey, but you must sign a detailed Quality Agreement.

📕 Risk notice

A break at any point in cold-chain management can be disastrous. Storing vaccines in a domestic refrigerator that has not undergone temperature validation, or transporting insulin in an ordinary vehicle with ice packs, is strictly prohibited. If discovered, this may result in the immediate refusal of a licence application and severe legal penalties for endangering public health. Temperature deviation events must be supported by detailed investigation reports and handling records; otherwise, they may be regarded as mismanagement.

Q156 · What measures must a warehouse implement to protect medicines from pests and rodents?Direct link
Pest control in a medicine warehouse is an ongoing, systematic activity aimed at prevention, not just extermination. First, the building structure of the premises must be intact, with no holes or gaps through which pests can enter. Doors and windows should close tightly, and drainage outlets should have mesh covers to prevent rodents from entering. Second, the environment must be kept clean and hygienic. There must be no standing water, rubbish or food debris in or around the warehouse, to eliminate sources that attract pests. Third, an integrated pest management plan should be established, usually in partnership with a professional pest control service provider. The plan should include regular inspections, installation and maintenance of pest control devices (such as glue boards, traps and fly killers), and detailed records of all activity. Any insecticides or rodenticides used must be approved products that pose no contamination risk to medicines, and must not be sprayed directly in medicine storage areas.

📘 Regulatory basis

Good Distribution Practice (GDP) requires premises to be kept clean and measures to be taken to prevent the entry and breeding of insects, rodents and other pests. A written pest control procedure must be in place and relevant records kept.

📗 Drew Tang's recommendations

We recommend that clients enter into an annual service contract with a reputable specialist pest control company. As well as carrying out regular inspections and treatments, it will provide a detailed pest control file, including service reports, a floor plan (showing the locations of all monitoring points), and safety data sheets (MSDS) for the chemicals used. This file is one of the documents that the Department of Health will check during an inspection and can clearly demonstrate your attention to pest control and professional management standards.

📕 Risk notice

Finding live pests or rodents, droppings or gnaw marks in a warehouse is a very serious deficiency. It directly demonstrates that pest control measures are ineffective and that medicines face a direct risk of contamination. In addition, indiscriminate use of highly toxic or odorous pesticides may chemically contaminate medicines and is equally unacceptable. Failure to have a contract with a professional company and retain complete records will be regarded as management negligence.

Q157 · 药品批发商的安保系统需要具备哪些功能,以确保药品安全、防止盗窃?独立链接
Medicines, particularly controlled psychotropic medicines or high-value medicines, are targets for theft. An effective security system is therefore essential. Basic requirements include: first, physical security. The premises must have sturdy doors, windows and locks to restrict access by unauthorised persons. Areas where controlled medicines are stored (such as poison cabinets) must have additional reinforcement and locking measures. Second, an intruder alarm system. A professional burglar alarm system connected to a 24-hour security company must be installed, covering all entrances and key areas. Third, a video surveillance system (CCTV). High-resolution cameras should be installed at key locations such as entrances and exits, goods receiving and dispatch areas, and medicine storage areas. Footage must be retained for at least 30 days to support investigation and traceability in the event of an incident. Fourth, access control. A strict key management or access card system should be established to ensure that only authorised staff can enter medicine storage areas, with corresponding entry and exit records.

📘 Regulatory basis

The Pharmacy and Poisons Ordinance and related regulations require licensees to take all reasonable steps to ensure that poisons in their possession are kept securely and protected from theft or loss. There are stricter storage requirements for Schedule 1 poisons, for example, they must be kept in a locked cupboard or room.

📗 Drew Tang's recommendations

When installing CCTV, we recommend ensuring there are no blind spots in camera coverage, particularly in areas where high-value or controlled medicines are handled. In addition, prepare a written security procedure setting out how staff should respond to suspicious persons or security incidents, and train staff accordingly. This demonstrates to the regulator that you have not only invested in equipment but also put a sound management system in place.

📕 Risk notice

A missing or ineffective security system is a major obstacle to a licence application. If Drug Office officers consider your security measures insufficient to protect medicines, particularly medicines with a risk of misuse, they may refuse your application. Any loss or theft of medicines must be reported immediately to the Drug Office and the police. Failure to report promptly may result in serious disciplinary action.

Q158 · 选择工业大厦还是商业楼宇作为药品经营处所,各有哪些利弊和合规考量?独立链接
Choosing an industrial building or commercial building as premises for a pharmaceutical business involves balancing cost, compliance and operational convenience. Industrial buildings generally offer lower rents, larger units, higher floor loading capacity and freight lifts, making them suitable for receiving and dispatching large volumes of medicines. However, some older industrial buildings may have poor hygiene and security, requiring additional investment in refurbishment. Commercial buildings are generally in convenient locations, with better building management and security and a better overall environment. However, rents are high, units are smaller, and there may be various restrictions on transporting goods, such as time-limited use of passenger lifts. From a compliance perspective, whichever type of building is chosen, you must ensure that the unit’s Occupation Permit and land lease allow it to be used as a ‘warehouse’ or for ‘non-domestic’ purposes.

📘 Regulatory basis

The Department of Health focuses mainly on whether premises meet the physical and management requirements for medicine storage, and has no preference for a particular building type. However, the use of the premises must comply with the requirements of the Buildings Department and the Lands Department. Operating from premises whose use does not comply with land-use requirements is illegal.

📗 Drew Tang's recommendations

For wholesalers requiring a larger storage area, we generally recommend newer industrial buildings, which have well-developed facilities, meet storage needs and provide a good office environment. Before signing a lease, have a solicitor or professional check the occupation permit and lease terms for the unit to confirm that its intended use is permitted. We can assist clients with due diligence to help them avoid leasing pitfalls.

📕 Risk notice

Leasing a unit that does not comply with statutory permitted use is a fatal mistake. Even if you invest heavily in fitting it out and pass a Department of Health inspection, if the Buildings Department or Lands Department discovers a breach, you may be ordered to vacate immediately, and your investment could be lost. This is the primary legal risk to avoid at the site-selection stage.

Q159 · 在卫生署进行场地视察前,企业应如何准备,以确保顺利通过检查?独立链接
A premises inspection is one of the most critical steps in the licence assessment process, and thorough preparation is essential. First, all hardware and facilities must be in place and operational, including all functional areas, temperature and humidity monitoring systems, security systems and pest-control equipment. Second, all documents and records must be complete, organised and readily accessible. These include company registration documents; qualification evidence for the Person-in-Charge and key personnel; all Standard Operating Procedures (SOPs); temperature and humidity records; cleaning records; pest-control records; and staff training records. Third, provide pre-inspection training to all relevant staff to ensure that they understand their responsibilities, relevant SOPs and the premises layout, and can answer inspectors’ questions clearly and accurately. Finally, conduct a comprehensive internal self-inspection, simulating a Department of Health inspection to identify and correct all potential issues.

📘 Regulatory basis

The Department of Health’s inspections are based on all the requirements of the Pharmacy and Poisons Ordinance and Good Distribution Practice (GDP). Inspecting officers will comprehensively examine your premises, facilities, documentation system and personnel qualifications to assess your ability to operate a pharmaceutical wholesale business in ongoing compliance.

📗 Drew Tang's recommendations

We usually provide clients with a “Mock Inspection” before the formal inspection. Our consultants act as inspectors and conduct the inspection to the strictest standards, then provide a detailed report recommending corrective actions. This process can greatly help clients identify blind spots, familiarise themselves with the process and ease their anxiety, thereby significantly increasing the likelihood of passing the formal inspection on the first attempt.

📕 Risk notice

Do not assume that inspection officers will just “go through the motions”. They are experienced and pay close attention to detail. The absence of any key facility (such as an uncalibrated thermometer), gaps in important records (such as an interruption in temperature records lasting several days) or employees being unable to answer basic questions about procedures may lead to an unsuccessful inspection. An unsuccessful inspection not only delays opening but may also require an additional reinspection fee.

Q160 · 药品处所的装修材料和设施(如地面、墙壁、照明)有无特殊要求?独立链接
Yes, the finishing materials and facilities in medicine premises are subject to specific requirements, primarily to facilitate cleaning, prevent contamination and ensure proper storage conditions. Floors should be seamless, smooth, durable and easy to clean, for example, epoxy floor coating. Avoid tiles with joints, as dirt can accumulate in the gaps. Walls and ceilings should be even and free from cracks, with a surface coating that does not readily peel and is easy to clean. It is recommended that wall, floor and ceiling corners be coved to eliminate hard-to-clean areas. Lighting should be sufficiently bright to ensure that all operations (such as checking labels and inspecting the appearance of medicines) can be carried out with clear visibility, and lighting fixtures should be designed for easy cleaning. In addition, the design and installation of all pipes, light fittings, vents and other facilities should avoid surfaces and recesses that are difficult to clean.

📘 Regulatory basis

Good Distribution Practice (GDP) expressly states that the “internal surfaces (walls, floors and ceilings) of storage areas should be smooth and free from cracks and open joints, should not shed particles, and should permit easy and effective cleaning”.

📗 Drew Tang's recommendations

For renovation budgets, we recommend that clients do not cut costs on floor finishes. Although a high-quality epoxy resin floor has a higher initial cost, its durability, ease of cleaning and dust-resistance far exceed those of ordinary tiles or a concrete floor, and it can make an excellent first impression on inspectors. In addition, all wiring and pipes should, as far as possible, be concealed or enclosed in trunking to prevent dust from accumulating on exposed runs. This is also a mark of professionalism.

📕 Risk notice

Using ordinary floor tiles, wooden flooring or wallpaper for refurbishment is completely unacceptable. If an inspection finds cracks in the floor, flaking wall surfaces or numerous areas that are difficult to clean, the premises will be considered unsuitable for storing medicines. This may mean costly refurbishment work and significant delays to the licence application.

Q161 · 如果药品仓库位于多层建筑的楼上,对电梯和搬运通道有何要求?独立链接
When a medicine warehouse is located on a floor above or below ground level, requirements for vertical transport and handling routes are critical. First, there must be a dedicated or sufficiently large freight lift, with dimensions and load capacity that can readily accommodate standard handling equipment such as pallets and roll cages. Passenger lifts must not be used to transport bulk medicines. Second, the routes from the loading bay to the lift, and from the lift to the warehouse entrance, must be unobstructed, level and clear, with sufficient width for handling equipment to pass and turn easily. The floor surfaces along these routes should also be durable and hard-wearing. Emergency arrangements must also be considered—for example, whether there is an alternative plan or procedure for urgent medicine transport if the lift breaks down. Although this may be difficult in practice, having a plan is better than having none.

📘 Regulatory basis

Good Distribution Practice (GDP) does not specify lift specifications, but its core principle is that “premises and equipment must be suitable for their intended use”. If transport facilities are inadequate to move medicines safely and effectively, resulting in damage to the medicines or interruption of temperature control during handling, this will be considered non-compliant.

📗 Drew Tang's recommendations

When selecting a site, we strongly recommend visiting in person and testing the goods lift, including its availability during peak periods. A goods lift that frequently requires queuing can seriously affect operational efficiency. You should also agree with the building management on the times and routes for moving medicines, to ensure compliance with the building’s management rules and avoid future disputes.

📕 Risk notice

Overlooking vertical transportation is a common mistake. If the premises have only passenger lifts or a small goods lift, daily operations may be extremely inconvenient or even impracticable. During an inspection by the Department of Health, if officers consider that your handling arrangements could damage medicines or create a safety risk—for example, by forcing goods through a narrow corridor—they may require you not to commence operations until improvements have been made.

Q162 · 对于需要避光储存的药品,除了存放在不透明容器中,处所在设计上还有什么要求?独立链接
For light-sensitive medicines, opaque original packaging or containers alone are not sufficient; the entire storage environment should take light protection into account. First, the storage area should be kept as far as possible from direct natural light. Windows should be fitted with blackout curtains or blinds, or covered with UV-blocking film. If windows cannot be fully avoided, medicine shelves should be positioned away from them. Second, lighting that does not emit significant amounts of ultraviolet radiation should be used. Traditional fluorescent tubes emit some ultraviolet radiation, which may affect medicine stability over prolonged exposure. LED lighting or other low-UV light sources are recommended. Finally, the relevant Standard Operating Procedures (SOPs) should clearly specify how light-sensitive medicines are to be handled. For example, during picking and packing, their exposure to strong light should be kept as short as possible.

📘 Regulatory basis

Medicine labels commonly state “Store protected from light”. Good Distribution Practice (GDP) requires licence holders to follow the storage conditions specified by the manufacturer. Failure to provide suitable protection from light breaches this basic requirement.

📗 Drew Tang's recommendations

We recommend that clients establish a dedicated “light-protected storage area”, which may have no windows or may have specially treated windows. Store all light-sensitive medicines in this area for centralised management and control. Adding a requirement to the SOP for staff to close the door behind them when entering the area is also a simple and effective control measure.

📕 Risk notice

Do not underestimate the effect of light on medicine stability. Prolonged exposure to unsuitable light may cause active ingredients to degrade and produce toxic by-products. If, during a Drug Office inspection, medicines clearly labelled “Protect from light” are found stored beside a window in direct sunlight, this will be regarded as a serious breach and will directly affect the licence application outcome.

Q163 · 药品仓库的清洁和消毒程序应如何制定和记录,才能符合GDP要求?独立链接
Establishing a compliant cleaning and disinfection procedure is fundamental to maintaining hygiene in the medicine storage environment. The procedure must be a written Standard Operating Procedure (SOP) and should include: 1. Scope of cleaning, covering all areas, including floors, walls, shelving and equipment. 2. Cleaning frequency, which may vary between areas—for example, daily cleaning of operational areas and weekly or monthly cleaning of high shelving. 3. Cleaning agents and disinfectants used, specifying the product name, concentration and method of use, and ensuring they will not contaminate medicines. 4. Cleaning tools, specifying dedicated tools (such as mops and cloths) and how they are to be cleaned and stored after use to prevent cross-contamination. 5. Cleaning methods, describing the operating steps in detail. 6. Record-keeping requirements: after each cleaning, the responsible person must sign and date the Cleaning Record Form. The disinfection procedure should be implemented when necessary, such as after a spillage or contamination incident, and documented in the same detail.

📘 Regulatory basis

Good Distribution Practice (GDP) expressly requires “written cleaning procedures that specify the cleaning methods, equipment and materials for different areas”. It also states that “cleaning records should be kept”.

📗 Drew Tang's recommendations

We recommend that clients display cleaning SOPs and record sheets in prominent locations in the warehouse so that staff can readily consult and follow them. Cleaning record sheets should be simple and clear, with fields for the date, time, area cleaned, person carrying out the cleaning and reviewer. It is very important to train cleaning staff regularly to ensure that they understand and strictly follow the SOP.

📕 Risk notice

The absence of written cleaning procedures and complete cleaning records is a common inspection deficiency. If the warehouse is visibly dirty, or you cannot provide cleaning records when requested by an inspector, this will be regarded as a lack of basic hygiene management. Strongly scented household cleaning agents may also be questioned, as their vapours could contaminate medicines.

Q164 · 如果我的业务同时涉及西药和中成药,是否可以在同一个仓库内储存?独立链接
It is permissible to store Western medicines and proprietary Chinese medicines in the same warehouse, but strict physical segregation and operational separation are required to prevent cross-contamination and mix-ups. First, the warehouse must have clearly defined, physically separated areas for Western medicines and proprietary Chinese medicines. Ideally, use separate rooms or separate them with solid walls. If this is not feasible, at least store them in different areas of the warehouse using a racking system and provide very clear labels. The handling processes for the two product categories (receipt, inspection, put-away, picking and checking) should be separated as far as possible, and they should not be handled at the same workstation or at the same time. In particular, some Chinese herbal medicines may have a strong odour or generate dust, so they must be strictly segregated from Western medicines to prevent odour or physical cross-contamination.

📘 Regulatory basis

Both the GDP guidelines for Western medicines and the Chinese Medicine Council of Hong Kong's Code of Practice for Retailers of Chinese Herbal Medicines emphasise the importance of preventing cross-contamination. Although no regulation expressly prohibits storage in the same warehouse, the regulatory focus is on risk management: you must demonstrate that adequate measures are in place to manage this risk.

📗 Drew Tang's recommendations

If your business is large-scale, we strongly recommend setting up completely separate warehouses for Western medicines and proprietary Chinese medicines. If they must be stored in the same warehouse, consider separate ventilation systems in addition to physical segregation, particularly if the Chinese herbal medicines area emits odours. The Warehouse Management System (WMS) should also use different location codes for the two product categories to distinguish them at system level.

📕 Risk notice

Storing western medicines and proprietary Chinese medicines together, or on adjacent shelves without effective segregation, is wholly unacceptable. If discovered during an inspection, this will be regarded as a serious breach. In particular, if western medicines, such as tablets, are contaminated by dust or odours from Chinese herbal medicines, they may be deemed contaminated and could all have to be destroyed, resulting in substantial financial loss.

Q165 · 对于储存受管制药物(危险药物),除了上锁的毒药柜,还有哪些额外的安保和记录要求?独立链接
Storage of drugs controlled under the Dangerous Drugs Ordinance (Cap. 134) (for example, certain potent analgesics) is subject to stricter security and record-keeping requirements than ordinary poisons. First, the storage facility must be a fixed, robust safe or vault; an ordinary locked cabinet is not sufficient. The safe must be secured to the building structure so that it cannot easily be removed as a whole. Second, access to and handling of these drugs must be very strictly controlled, usually through a dual-person, dual-lock or similar system, under which two authorised persons must be present for each operation. Third, and most importantly, a dedicated Dangerous Drugs Register must be maintained. Every receipt and issue must be recorded promptly and accurately, including the date, source or destination, quantity and signatures of the persons handling the transaction. The register must follow the prescribed statutory format and must not be altered.

📘 Regulatory basis

The Dangerous Drugs Ordinance (Cap. 134) and its regulations contain highly detailed and mandatory requirements for the storage, custody and recording of dangerous drugs. Any breach is a criminal offence. The Ordinance expressly requires licensed wholesalers to keep a dangerous drugs register and record all transactions in the prescribed form.

📗 Drew Tang's recommendations

We recommend that clients have two people check and sign every entry in the dangerous drugs register to minimise clerical errors. The register should be kept as securely as cash. Stock should also be physically counted and reconciled against the register balance regularly (for example, monthly), with the results recorded. Any discrepancy must be investigated and reported immediately.

📕 Risk notice

The management of dangerous drugs is a top regulatory priority, and any lapse can have extremely serious consequences. Late or inaccurate register entries, or unauthorised alterations, may be regarded as offences. Any unaccounted loss of medicines may trigger a criminal investigation. The licence holder and person-in-charge will bear personal legal responsibility.

Q166 · 仓库的消防安全需要符合哪些规定?是否需要安装特定的消防系统?独立链接
Fire safety in a medicine warehouse is a basic requirement for protecting people and property, and must strictly comply with the requirements of the Hong Kong Fire Services Department. First, the premises must be equipped with a sufficient number and appropriate types of fire-fighting equipment, such as portable fire extinguishers (dry powder, carbon dioxide, etc.) and fire hose reels, according to their area and the fire risk of the goods stored. All fire-fighting equipment must be placed where it is readily accessible, clearly marked, and inspected and maintained annually by a registered fire service installation contractor. Second, all fire escape routes, emergency exits and stairways must be kept clear and unobstructed; goods or other items must not be stored there. Emergency exit doors must be easy to open from the inside. Third, a fire detection and alarm system that complies with regulations (smoke detectors, fire alarm bells, etc.) should be installed. The Fire Services Department may also require automatic sprinkler systems in large or high-risk warehouses.

📘 Regulatory basis

The fire safety installations at the premises must comply with the Fire Services Ordinance (Cap. 95) and relevant subsidiary legislation. The Fire Services Department will issue “fire safety directions” based on the use and design of the building, which licence holders must comply with. The Department of Health will also consider whether fire safety requirements are met during inspections.

📗 Drew Tang's recommendations

We recommend that clients engage a registered fire service installation contractor to assess the premises before moving in, ensuring that all fire service installations are in good condition and meet the latest standards. A simple emergency evacuation plan should also be prepared and displayed prominently, so that all employees know the evacuation routes and assembly point in the event of a fire.

📕 Risk notice

Failure to comply with fire safety requirements will not only result in failure to pass a Department of Health inspection, but will also constitute a direct breach of fire safety legislation, potentially leading to fines or even imprisonment. Obstructing fire escape routes or emergency exits is an extremely dangerous and common breach. If discovered during a Fire Services Department inspection, it may result in an immediate warning letter or prosecution. A fire can cause not only property damage but also injuries or loss of life; this is a red line that must never be crossed.

Q167 · 如果处所内部分区域需要改造或加建,需要向哪个部门申请?流程是怎样的?独立链接
In Hong Kong, any work on premises involving structural alterations, additions or major renovations must comply with the Buildings Ordinance (Cap. 123) and may require an application to the Buildings Department. This is known as a “building plan submission”. First, you must engage an Authorised Person (usually an architect, engineer or surveyor) to assess your alteration plans. If the plans involve structural safety, fire safety, sanitary facilities or other relevant matters, the Authorised Person will determine whether a formal submission is required. If so, they will prepare the plans and related documents and submit the application to the Buildings Department on your behalf. The Buildings Department will review whether the plans comply with building standards and safety requirements. Once approval has been obtained, you must also engage a registered contractor to carry out the works. After completion, the Authorised Person will apply to the Buildings Department for a “Certificate of Completion” (also known as a “satisfaction letter”) confirming that the works have been completed in accordance with the approved plans.

📘 Regulatory basis

The Buildings Ordinance (Cap. 123) is the principal law governing building construction and alterations in Hong Kong. Any unauthorised building works are illegal, and the Buildings Department may issue a removal order requiring the owner to reinstate the premises.

📗 Drew Tang's recommendations

Before carrying out any alterations, even if you consider the work minor (for example, adding an internal partition), we strongly recommend that you first seek professional advice from an Authorised Person. Many seemingly simple internal alterations may require plans to be submitted if they affect fire escape routes or the building structure. Seeking advice beforehand can prevent major losses caused by discovering only after committing funds that the work is unlawful.

📕 Risk notice

The risks of carrying out unauthorised building works (UBWs) are extremely high. If discovered by the Buildings Department, you will have to bear the full cost of demolition and reinstatement, and may also face fines and prosecution. More importantly, the validity of the Occupation Permit for premises with UBWs may be questioned. This could directly result in the Department of Health refusing your pharmaceutical licence application because you cannot demonstrate that your business premises are lawful and compliant.

Q168 · 对于退回或召回的药品,在处所内应如何隔离和管理?独立链接
Managing returned or recalled medicines is a key closed-loop control in the pharmaceutical quality control system and must be strictly implemented. First, a physically segregated area must be established in the warehouse specifically for returned/recalled medicines, with clear and prominent signage such as “Returned/Recalled Products Area - Not for Use”. All medicines returned by customers or recalled under instructions from the manufacturer or Department of Health must be moved to this area immediately upon receipt and must not be mixed with released stock. Second, detailed records must be kept for each batch of returned/recalled medicines, including the medicine name, batch number, quantity, reason for return/recall, source and date received. These medicines should be treated as “non-conforming goods” and must remain segregated until the quality control department makes a final disposition decision (for example, destruction or return to the supplier).

📘 Regulatory basis

Good Distribution Practice (GDP) expressly requires that “dedicated areas should be provided for the storage of returned medicines, separate from released goods”. For recalled medicines, it also requires that “recalled medicines should be identified and stored separately from released goods in a secure area until a final disposition decision has been made”.

📗 Drew Tang's recommendations

We recommend that clients use a lockable cage trolley or locked room as the returns/recall area, providing two layers of protection. This is not only physical segregation but also access control, and can more effectively prevent these medicines from being incorrectly shipped again. In the warehouse management system (WMS), the stock status of these medicines should also be marked as “locked” or “unavailable” to prevent their allocation to new orders at system level.

📕 Risk notice

Failure to effectively segregate returned or recalled medicines is an extremely serious breach. If medicines with potential quality issues are accidentally sold again, they may harm patients and lead to serious medical incidents and legal disputes. If inspectors find returned medicines scattered in the area for released goods, your Quality Management System will be considered to have failed completely.

Q169 · 在进行场地视察时,卫生署官员会重点关注哪些文件记录?独立链接
The Department of Health’s premises inspection involves far more than checking the physical facilities. Reviewing documents and records is central to assessing whether your management system is effective. Officers will examine your documents systematically, much like auditors. The documents they typically focus on include: 1. **Quality Management System documentation**: the quality manual and complete set of Standard Operating Procedures (SOPs). 2. **Personnel records**: CVs and qualification documents for key personnel (such as the Person-in-Charge and quality manager), and training records for all staff. 3. **Premises and equipment documents**: the premises tenancy agreement and floor plan, validation/qualification reports for major equipment (such as cold rooms and refrigerators), and calibration certificates for all monitoring equipment (such as thermometers). 4. **Operational records**: complete temperature and humidity monitoring records (including any reports investigating out-of-range readings), cleaning records, pest-control records, and goods-in and goods-out records. 5. **Product-related records**: supplier and customer qualification files, purchase orders and sales invoices for medicines, and records of returned goods and recall handling. 6. **Controlled medicines records**: where applicable, the Dangerous Drugs Register and poisons sales records.

📘 Regulatory basis

Several chapters of Good Distribution Practice (GDP) emphasise the importance of documentation, requiring “all processes to have written procedures and relevant records to be kept” to provide an auditable trail.

📗 Drew Tang's recommendations

We recommend that clients establish a clear document index system, with all documents that may be inspected stored in designated folders or filing cabinets by category. On the day of the inspection, assign an employee familiar with all the documents (usually the quality manager) to assist officials with document reviews. Neatness, orderliness and completeness can greatly enhance officials’ confidence in your company’s management standards.

📕 Risk notice

“If it is not recorded, it did not happen” is the golden rule of regulators. If you claim to check the temperature every day but cannot produce continuous records, officers will conclude that you did not do so. Missing, falsified or inconsistent documentation is one of the main reasons for failing an inspection. Missing key records, such as calibration certificates and temperature and humidity records, is almost always a disqualifying deficiency.

Q170 · 如果药品在仓库内发生泄漏或溢出,应如何处理以确保存储环境不受污染?独立链接
Medicine leaks or spills must be handled promptly, safely and effectively in accordance with a pre-established emergency procedure. First, immediately isolate the affected area to prevent the contamination from spreading, and evacuate non-essential personnel. Operators must wear appropriate personal protective equipment (PPE), such as gloves and masks; if handling toxic or corrosive medicines, goggles and protective clothing may also be required. Second, use a dedicated spill kit to absorb and clean up the spill. A kit typically contains absorbent pads, absorbent powder, dedicated scoops and sealed bags. Do not rinse the spill directly with water, as this may spread contaminants into the drainage system. All contaminated materials, including spilled medicines, absorbents and contaminated packaging, must be collected in dedicated, clearly labelled sealed containers or bags and handled as chemical waste. Finally, after the area has been cleaned, it must be thoroughly cleaned and disinfected again, and checked by the quality department to confirm that no residue remains before it is put back into use. The entire incident response must be documented in detail.

📘 Regulatory basis

The Good Distribution Practice (GDP) requires written procedures for handling medicine spills to prevent cross-contamination and ensure the safety of personnel. Waste disposal must also comply with the relevant requirements of the Environmental Protection Department.

📗 Drew Tang's recommendations

We strongly recommend that clients keep at least one commercial-grade spill response kit in a prominent location in the warehouse, and train relevant staff in its correct use through instruction and drills. Prepare a simple, clear Spill Response SOP and keep it with the kit. This enables staff to follow the correct procedures even in an emergency.

📕 Risk notice

Improper handling of a medicine spill carries multiple risks: harm to employees, environmental contamination and cross-contamination of other medicines in the warehouse. If officers find during an inspection that you have no procedure or equipment for dealing with spills, your emergency management capability will be seriously questioned. Improper handling of spills involving high-risk medicines such as cytotoxic drugs may have serious consequences.

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Plan Your Hong Kong Pharmaceutical Licensing Project with Drew Tang

Business Manager Tang Shangyong (Drew Tang) will review your products, operating model, licence type and preparation requirements with you one-to-one. The precise service scope is confirmed in writing; pharmaceutical duties are carried out by legally qualified personnel, and approvals are determined by the competent authorities.

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