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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Q141 · 一家公司是否可以同时持有多种类型的药品牌照,例如同时持有批发商和制造商牌照?独立链接
Yes. A company may apply for and hold more than one pharmaceutical licence, depending on its business needs. For example, a company that manufactures medicines and also sells them to other wholesalers, hospitals or pharmacies must hold both a manufacturer’s licence and a wholesaler’s licence. Similarly, a company may hold licences for both wholesale of proprietary Chinese medicines and wholesale of Western medicines. The key is that the company must meet the relevant statutory requirements for every licensed activity. This means that if it holds two types of licence, its facilities, personnel, Quality Management System and operating procedures must meet the regulatory standards for both licences, and it must be able to clearly demonstrate compliant operations under each licence during inspections.

📘 Regulatory basis

The Pharmacy and Poisons Ordinance regulates by “activity”. Each regulated activity (such as manufacture, wholesale or retail) requires a separate licence. The law does not prohibit the same legal entity from holding multiple licences, provided it can meet the conditions of each licence.

📗 Drew Tang's recommendations

For clients planning to diversify their business, we recommend identifying all the licensed activities involved at the outset of business planning. We can assist with a comprehensive compliance gap analysis to ensure that your premises layout, staffing and SOP documents meet the requirements for all applications together, enabling the most efficient application process.

📕 Risk notice

Holding multiple licences entails multiple compliance responsibilities. The company must ensure that different business activities are clearly separated and managed; for example, materials in the production area must not be confused with finished goods in the wholesale area. A serious violation under any one licence may affect the standing and validity of the company’s other licences.

Q142 · 对于需要冷链运输和储存的药品(如疫苗),对相关操作人员有何特殊的资格或培训要求?独立链接
Personnel handling medicines that require cold chain management (Cold Chain Products) are subject to stringent training and qualification requirements set by the regulatory authorities. All employees involved in receiving, storing, packing, transporting and distributing cold chain medicines must receive specific training. The training must cover: 1) the basic principles and importance of the cold chain; 2) the specific temperature requirements for different medicines (such as 2-8°C); 3) how to use and read temperature monitoring equipment correctly (such as data loggers); 4) the correct use of cold chain packaging (such as cool boxes and cool packs); 5) emergency procedures for temperature excursions; and 6) relevant record-keeping and documentation requirements. The person overseeing cold chain operations (usually the RP or their delegate) needs more in-depth knowledge to be able to validate the effectiveness of cold chain equipment and processes.

📘 Regulatory basis

The World Health Organization (WHO) and PIC/S Good Distribution Practice (GDP) annexes both contain dedicated sections on cold-chain products. The Code of Practice for Authorized Persons, Listed Sellers of Poisons and Listed Sellers of Poisons must also be observed by licence holders, who must ensure that medicines are stored under suitable conditions throughout the supply chain.

📗 Drew Tang's recommendations

We strongly recommend that clients operating cold-chain medicines make cold-chain management a core part of their Quality Management System (QMS). We can help clients draft a complete set of cold-chain SOPs, design staff training and assessment programmes, and recommend qualified cold-chain equipment and validation service providers to ensure that your cold-chain operations are robust.

📕 Risk notice

A break in the cold chain can be fatal to pharmaceutical product quality. A brief temperature excursion may render an entire batch of high-value vaccines or biological products ineffective, causing not only significant financial losses but also potential harm to public health. During regulatory inspections, cold-chain management records and implementation are a major focus, and any deficiency may have serious consequences.

Q143 · 如果持有药品牌照的公司发生了重大的股权变更,例如被另一家公司收购,是否需要重新申请牌照?独立链接
This depends on the circumstances, but a completely new application is generally not required; instead, strict notification and approval procedures must be followed. When a licensed company undergoes a major shareholding change or transfer of control, the legally licensed entity (that is, the company as a legal person) remains unchanged, so the licence itself remains valid. However, the company must immediately notify the Drug Office, Department of Health, in writing of this major change. The new major shareholders, directors and ultimate beneficial owners must submit their personal particulars to the Pharmacy and Poisons Board (PPB) and undergo a “fit and proper person” assessment. The PPB must be satisfied that, under the new control, the company can and will continue to comply with all licence conditions. In some cases, if the PPB has concerns about the new shareholders’ background or intentions, it may impose additional licence conditions or conduct inspections more frequently.

📘 Regulatory basis

Licence conditions generally require notification to the regulator of any significant change that may affect the company’s control. This is to ensure that the PPB can continue to discharge its statutory duty to supervise the ‘fitness’ of licence holders.

📗 Drew Tang's recommendations

Before any merger and acquisition or major share transaction, we strongly recommend that both buyer and seller make regulatory approval one of the key conditions precedent to completion. We will help the new shareholders prepare the full set of notification documents and proactively communicate with the Drug Office to explain the commercial rationale for the transaction and the future operating plan, with a view to securing a smooth approval process.

📕 Risk notice

“Act first and notify later”—that is, notifying the regulator only after completing a share transaction—is an extremely wrong and dangerous approach. It may be seen as disregard for regulatory requirements and could seriously call into question the integrity of the new management. In the worst-case scenario, if a new shareholder is found not to be a “Fit and Proper Person”, the PPB has the power to initiate licence revocation proceedings.

Q144 · 处理细胞毒性药物或其他危险药品的人员,需要具备哪些特殊的资格和防护培训?独立链接
Personnel handling hazardous drugs such as cytotoxic drugs must receive more stringent and specialised training than personnel handling ordinary drugs. Their qualifications and training are essential to occupational safety and the prevention of environmental contamination. Training must cover: 1) the characteristics and potential hazards of hazardous drugs (such as carcinogenicity and teratogenicity); 2) the correct selection and procedures for putting on and removing personal protective equipment (PPE), such as double gloves, protective gowns, goggles and respiratory protective equipment; 3) procedures for handling hazardous drugs in a dedicated negative-pressure isolator or biological safety cabinet; 4) emergency procedures for accidental spills and exposure incidents; and 5) the correct classification, labelling and handling of hazardous drug waste. Only employees who have completed the training and passed the assessment may be authorised to handle these high-risk products.

📘 Regulatory basis

The PIC/S GMP Guide and international occupational health and safety standards (such as OSHA and NIOSH) provide detailed guidance on the safe handling of hazardous medicines. During inspections, the Drug Office, Department of Health scrutinises whether licence holders follow these best-practice standards.

📗 Drew Tang's recommendations

We recommend that clients handling these products invest in suitable engineering control equipment (such as isolators) and establish a separate SOP for the safe handling of hazardous medicines. We will help clients design a comprehensive training programme covering both theoretical knowledge and practical exercises, and establish a strict authorisation system for staff to perform the work.

📕 Risk notice

Failure to provide staff with adequate training in the handling of dangerous drugs is a serious dereliction of responsibility for their life and health, as well as a major legal risk. If an employee’s health is harmed through occupational exposure, the company may face substantial compensation claims and legal proceedings, and the regulatory authority may also revoke its authorisation to handle the relevant medicines.

Q145 · 药剂业及毒药管理局(PPB)对申请人的背景审查范围有多广?会调查海外记录吗?独立链接
The PPB's background checks on key applicants (such as directors, UBOs and RPs) are extensive and in-depth, and are by no means limited to Hong Kong. The purpose is to assess comprehensively whether the person meets the “fit and proper” standard. Checks typically include: 1) identity verification; 2) criminal record checks (the applicant may be asked to authorise a criminal record certificate check); 3) checks of bankruptcy and company director disqualification records; 4) searches of publicly available information, including news reports and social media; and 5) verification of the applicant's declared academic and professional qualifications. For applicants with overseas backgrounds, the PPB may require overseas criminal record certificates and will pay particular attention to any adverse records with regulatory authorities in other countries, whether in medicines, finance or other sectors. Although cross-border checks can be complex, applicants are responsible for providing all relevant information and documents as requested.

📘 Regulatory basis

The PPB's discretion allows it to require an applicant to provide “any further information as it may consider appropriate” to help it determine whether the applicant is a “fit and proper person”. This provides a legal basis for extensive background checks.

📗 Drew Tang's recommendations

We recommend that clients conduct an internal “mock background check” of all key personnel before starting the application, to identify potential risk factors proactively. Prepare official supporting documents and a clear explanation for any overseas records. Transparency and cooperation are the best ways to earn regulators’ trust.

📕 Risk notice

Do not assume that an overseas “black history” will go undetected. In today’s increasingly globalised and information-sharing environment, regulatory authorities’ investigative capabilities far exceed what you might imagine. Being found dishonest during a background check can have disastrous consequences, far more serious than any past blemish itself.

Q146 · 如果一个人曾是某家药品牌照被吊销的公司的董事,他还能在新的申请公司中担任董事吗?独立链接
This situation will be subject to very stringent scrutiny, and the chances of success are slim, but it is not absolutely impossible. If a person has served as a director of a company whose licence was revoked, the PPB will conduct an extremely thorough investigation when assessing their eligibility to serve as a director of a new company. The PPB will focus on the following points: 1) What were the specific reasons for the company’s licence being revoked? Did they involve serious dishonesty or a significant threat to public health? 2) What role did the director play in the events leading to the revocation? Did they actively participate, knowingly fail to report the matter, or genuinely have no knowledge of it while fulfilling their duties as a director? 3) Has the director shown any reflection or improvement since the events? They must be able to provide highly persuasive evidence that they have learned significant lessons and that the new applicant company has established robust checks and oversight mechanisms to prevent a recurrence.

📘 Regulatory basis

This is a typical case in a “fit and proper person” assessment. Past regulatory breaches are an important basis for assessing the risk of future conduct. The PPB’s primary duty is to protect the public, so it takes an extremely cautious approach to applicants in such cases.

📗 Drew Tang's recommendations

If this happens, your only hope lies in complete candour and compelling evidence. The applicant must prepare an extremely detailed statement explaining the events and their own responsibility. The new company's business plan and compliance framework must also be beyond reproach. Even so, you should be prepared for the application to be rejected. In many cases, replacing the director is the wiser choice.

📕 Risk notice

If the reason for licence revocation involves serious issues such as fraud or deliberately endangering the public, it is almost impossible for the relevant directors to pass the PPB's “fit and proper person” test again. Attempting to excuse such a history may be viewed as a lack of remorse and make the situation worse.

Q147 · 公司是否需要为负责人员(RP)或注册药剂师设立“后备”或“代理”人选?独立链接
There is no legal requirement to formally appoint a “deputy” or “stand-in” RP or pharmacist for a licence application or day-to-day operations. The statutory requirement is that a qualified, approved key person must be available at all times. However, from the perspective of sound operations and risk management, having an effective succession or temporary cover plan is highly advisable and professional. Large wholesalers or manufacturers commonly appoint a deputy or senior manager who has the potential qualifications to become an RP and is familiar with all relevant duties, so that they can take over promptly if the RP is on leave or leaves unexpectedly. A pharmacy cannot have two pharmacists-in-charge of sale at the same time, but it can establish contacts with locum pharmacists so that temporary cover can be arranged to maintain lawful operations if the pharmacist-in-charge is ill or on leave.

📘 Regulatory basis

The core regulatory requirement is “continuous availability”, not “appointing a designated deputy”. However, guidance such as the Code of Practice forholders of licences issued under the Pharmacy and Poisons Ordinance encourages licence holders to establish a sound Quality Management System, of which continuity of personnel management is one part.

📗 Drew Tang's recommendations

RGYS may assist with clarifying roles, evidence of qualifications and responsibility arrangements within the written scope; the suitability, appointment and actual presence at work of candidates remain subject to verification by the applicant and legally qualified personnel, and no provision or certification of personnel is promised. A potential backup RP can be involved in all relevant compliance meetings and training to ensure that he or she stays up to date. For pharmacies, a reliable contact list of locum pharmacists should be established. This demonstrates the company's management maturity and commitment to business continuity.

📕 Risk notice

The greatest risk of having no contingency plan is that, if a key person suddenly leaves or becomes unable to perform their duties, the company will immediately fall into a non-compliant state. Finding and appointing a new qualified person takes time. During this gap, the company may be forced to suspend all licensed activities, resulting in substantial business losses and customer attrition.

Q148 · 对于计划提供“远程药事服务”或“网上药房”业务,对相关人员有何特殊的资格要求?独立链接
Regulation of “remote pharmacy services” and “online pharmacies” in Hong Kong is still evolving. The core principle, however, is that any dispensing and sale of prescription medicines must take place under the direct supervision of a registered pharmacist and comply with all applicable pharmaceutical regulations. This means that even if a prescription is received through an online platform, the final review, dispensing, checking and supply of the medicine must be carried out in person by a registered pharmacist at physical premises holding a valid Authorised Seller of Poisons (ASP) (pharmacy) licence. Pharmacists responsible for online consultations must also be registered pharmacists in Hong Kong. In addition, the IT systems, data privacy safeguards and medicine delivery arrangements (particularly for cold-chain medicines) used throughout the process must be designed and managed by personnel with the relevant expertise to ensure that the service is safe, compliant and traceable.

📘 Regulatory basis

The Department of Health issued Guidelines on Ethical Practice in Telehealth in 2023, and the Pharmacy and Poisons Board also issued relevant guidelines. The key principle is that online services must not lower or circumvent any statutory standards applicable to physical pharmacies, particularly the pharmacist’s personal supervision responsibilities.

📗 Drew Tang's recommendations

For clients wishing to explore this innovative business, we recommend proceeding with extreme caution. First, you must have a fully compliant physical pharmacy as the operational foundation. We can help you design an online and offline workflow (SOP) that complies with regulatory guidance and ensure that your IT platform meets standards for patient privacy and data security.

📕 Risk notice

It is strictly prohibited in Hong Kong to attempt to operate a purely “virtual pharmacy” entirely without a physical pharmacy or pharmacist supervision, in order to sell prescription medicines. Any conduct that bypasses a pharmacist's prescription checks or dispatches medicines from an unlicensed location will be treated as illegal sales and unlicensed operation, and will attract the most severe legal penalties.

Q149 · 药品批发商的负责人员(RP)或药房的注册药剂师,是否必须是香港永久性居民?独立链接
Not necessarily. Hong Kong’s medicines regulatory legislation does not make Hong Kong permanent residency a statutory requirement for appointment as an RP or registered pharmacist. Any non-permanent resident holding a valid Hong Kong work visa may take on these key roles, provided that they meet the relevant professional qualification, academic and experience requirements and pass the regulatory authority’s review or approval (such as a PPB interview or pharmacist registration). For example, a pharmacist holding a foreign passport may be employed by a pharmacy if they pass the Hong Kong licensing examination and are successfully registered. Similarly, a foreign expert holding a work visa may be appointed as the RP of a medicine wholesaler if they have the required experience and knowledge. What matters is their professional competence and lawful work status, not their category of residency.

📘 Regulatory basis

Neither the Pharmacy and Poisons Ordinance nor the Pharmacists Registration Ordinance restricts the residency status of key personnel. Hong Kong’s Immigration Ordinance sets out the visa requirements for non-local residents working in Hong Kong.

📗 Drew Tang's recommendations

For clients wishing to employ overseas professionals in key positions, we provide a one-stop service. We not only help assess whether their professional qualifications meet the requirements for pharmaceutical licences, but also assist them in applying to the Immigration Department for an employment visa. We will prepare strong supporting documents explaining the necessity of the position and the candidate’s unique qualifications.

📕 Risk notice

When employing non-local residents, ensure that applications for their work visas and visa renewals are fully compliant. If a key person’s visa becomes invalid during the licence application or while the licence is held, preventing them from working lawfully in Hong Kong, the company will immediately become non-compliant, with the same consequences as if the key person had left.

Q150 · 为了维持资格,负责人员(RP)和注册药剂师是否有持续专业发展(CPD)的强制要求?独立链接
Yes, continuing professional development (CPD) is essential to maintaining the professional standards and qualifications of key personnel. The Pharmacy and Poisons Board (PPB) has implemented a mandatory CPD programme for registered pharmacists. Pharmacists must complete the prescribed number of CPD credits within a specified cycle (for example, three years) in order to renew their practising certificates. CPD activities take various forms, including attending academic lectures and seminars, completing online courses and publishing research. Although there is currently no mandatory credit system for RPs of pharmaceutical wholesalers and manufacturers as there is for pharmacists, “continuing training” is a basic requirement of Good Distribution Practice/Good Manufacturing Practice (GDP/GMP). Licensed companies are responsible for providing RPs with ongoing training on regulatory updates, new technologies and industry best practices, and for keeping all training records. During inspections, the regulatory authority will assess whether the RP's knowledge is up to date.

📘 Regulatory basis

The Pharmacy and Poisons Board website sets out the CPD requirements for registered pharmacists. The Code of Practice for the Guidance of Authorised Persons and GMP guidelines also emphasise the responsibility to provide “continuous training” for all key personnel.

📗 Drew Tang's recommendations

We recommend that all licensed companies establish annual training plans for key personnel and allocate budgets to support their participation in high-quality CPD activities. We also regularly hold seminars on regulatory updates and compliance topics to help our clients meet these evolving requirements and provide certificates of attendance for their records.

📕 Risk notice

For pharmacists, failure to complete CPD credits will directly prevent renewal of their practising certificates, resulting in loss of the right to practise. If an RP’s knowledge becomes outdated and fails to keep pace with regulatory and technical developments, they will be unable to perform their supervisory duties effectively. Regulatory authorities may regard this as a significant compliance risk that could affect the company’s licence renewal.

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.

YOUR NEXT STEP

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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