Hong Kong Drug Office has published some guidance notes on the classification of products as “pharmaceutical products” in June 2022.
A product will need to be assessed to determine its eligibility of being a pharmaceutical product. Some of the details required are the composition, presentation, use, and promotional material of the product.
The appendices in the guidance note provide some examples of different substances and their correlation with medicinal use.
A product can be classified as a “pharmaceutical product” if there is proof that it contains medicinal substance(s) at a reasonable amount with medicinal claims.
More details can be found in “Guidance Notes on Classification of Products as “Pharmaceutical Products” under the Pharmacy and Poisons Ordinance (Cap. 138), June 2022”: https://www.drugoffice.gov.hk/eps/do/en/doc/guidelines_forms/Guide_on_PRClass.pdf