DH Reminds Public That Injection Procedures Should Only Be Administered by Registered Medical Practitioners or Registered Dentists

DH reminds public that injection procedures should only be administered by registered medical practitioners or registered dentists

In response to media enquiries regarding the Department of Health's (DH) plan to revise the Codes of Practice (CoPs) for licensed private healthcare facilities (PHFs) to update regulatory requirements on the use of injectable and infusible products in PHFs, the DH today (September 29) responded as follows:

The Department of Health, Photo source: reference image

In 2013, the Government accepted the recommendations of the Working Group on Differentiation between Medical Procedures and Beauty Services under the Steering Committee on Review of Regulation of Private Healthcare Facilities that procedures involving injections should be regarded as medical procedures and only be performed by registered medical practitioners or registered dentists. Products intended for human parenteral injection are high-risk products. Unless they fall within other regulatory categories (e.g. medical devices or proprietary Chinese medicines), they are generally classified as pharmaceutical products under the Pharmacy and Poisons Ordinance (Cap. 138) and must be registered with the Pharmacy and Poisons Board of Hong Kong before they can be sold or distributed in Hong Kong. The "Guidance Notes for Definitions and Abbreviations for Medical Device Administrative Control System (GN-00) " published by the DH also explicitly stipulates injectable dermal fillers are classified as medical devices.

All registered pharmaceutical products carry a Hong Kong registration number in the format of "HK-XXXXX" on their packages. Members of the public can use the "Search Drug Database" function on the website of the Pharmacy and Poisons Board of Hong Kong to check information on individual registered pharmaceutical products by entering the product name or ingredient; all listed medical devices carry a listing number in the format of "HKMD XXXXXX". Members of the public may refer to the "List of Medical Devices" at the Medical Device Division's website for detailed information.

The DH regulates premises where registered medical practitioners and registered dentists practise under the Private Healthcare Facilities Ordinance (Cap. 633) (the Ordinance). The Government set up the Advisory Committee for Regulatory Standards for Private Healthcare Facilities (Advisory Committee) under the Ordinance. It comprises members from the Hong Kong Academy of Medicine, the Hospital Authority, the academia, and representatives from private hospitals, registered medical practitioners' as well as dentists' associations. The terms of reference of the Advisory Committee are to devise, review and update the standards of regulation for PHFs and make recommendations on the CoPs issued by the Director of Health from time to time.

Since injectable and infusible products intended for human are high-risk products, the Advisory Committee has endorsed updated regulatory requirements and required that all injectable and infusible products used in licensed PHFs must fall within one of the following categories:

i) Pharmaceutical products registered or exempted from registration under the Pharmacy and Poisons Regulations (Cap. 138A);

ii) Human organ or human tissue products in compliance with the Human Organ Transplant Ordinance (Cap. 465); or

iii) Medical devices listed under the Medical Device Administrative Control System (MDACS).

The dental clinic, Photo by Bastille Post

In light of the Advisory Committee's decision, the DH will also revise the CoPs for licensed PHFs accordingly. The DH intends to publish the revised CoPs in the Gazette in the fourth quarter of 2026. The revised CoPs, except for the sections on medical devices, will take effect one month after publication in the Gazette. To allow licensed PHFs sufficient time to identify compliant alternative products,the requirement for using injectable and infusible medical devices listed under MDACS will take effect on March 1, 2027.

Regarding the aforesaid requirement on injectable and infusible products, the DH issued a letter on September 9, 2026, to notify licensees of PHFs, licence applicants and the medical device industry. This letter, as well as frequently asked questions, have also been uploaded to the DH's website for reference.

The Ordinance stipulates that operators of PHFs must obtain a licence or a letter of exemption before they can operate the relevant PHFs. The regulatory regimes for private hospitals and day procedure centres have been fully implemented, while the Government has started accepting applications for clinic licences and requests for letters of exemption for small practice clinics since October 2025. Any premises (including premises claiming to provide beauty services) that provide medical services/carry out medical procedures must obtain a relevant licence or letter of exemption under the Ordinance according to the nature of the medical services/procedures. The Government expects that, as early as the end of December 2027, any premises (including premises claiming to provide beauty services) that provide medical services or carry out medical procedures will be required to hold a relevant licence or letter of exemption under the Ordinance according to the nature of the services or procedures. As of yesterday (September 28), the DH has issued a total of over 3 400 clinic licences or letters of exemption for small practice clinics.

Compliance with the CoP is a condition for the issuance and renewal of licences. The DH inspects licensed PHFs from time to time and will take regulatory action if any licensed PHF is found to be in violation of the CoPs.

From time to time, the DH receives notifications of cases in which members of the public have developed complications following injection procedures, such as a probable case of botulism after a botulinum toxin injectionannounced on September 21 this year.

The DH has consistently reminded the public through various channels that injection procedures are medical procedures which should only be performed by locally registered medical practitioners or registered dentists. Members of the public should first ascertain the full name of the medical practitioner/dentist and check the List of Registered Medical Practitioners maintained by the Medical Council of Hong Kong or the List of Registered Dentists maintained by the Dental Council of Hong Kong. The professional qualifications and relevant credentials of the medical practitioner/dentist should also be verified. Before receiving an injection, members of the public should first understand the details of the procedure, potential risks and possible complications to make an informed decision. They should refuse injections from unknown sources, as their quality and efficacy are not assured.

Photo source: reference image

Any person who is not a registered medical practitioner or registered dentist shall not perform medical procedures; otherwise the person may be charged for violating the Medical Registration Ordinance (Cap. 161) and the Dentists Registration Ordinance (Cap. 156).

The illegal sale or possession of unregistered pharmaceutical products is a criminal offence. The maximum penalty for each offence upon conviction is a fine of $100,000 and two years' imprisonment. If a person is suspected of illegally providing unregistered pharmaceutical products, the DH will conduct investigations and take enforcement actions. If medical professionals are involved, the DH will refer the case to relevant professional regulatory bodies for follow-up actions.

Ombudsman probes effectiveness of Leisure and Cultural Services Department's management of indoor fitness rooms

The following is issued on behalf of the Office of The Ombudsman:

The Ombudsman, Mr Jack Chan, today (October 13) announced the launch of a direct investigation operation to examine the effectiveness of the Leisure and Cultural Services Department (LCSD)'s management of indoor fitness rooms.

The National 15th Five-Year Plan explicitly proposes to actively develop mass sports, extensively promote fitness activities for all and strengthen participation in fitness activities among young people, with a target of raising the proportion of the population regularly participating in physical exercise to approximately 40 per cent. The country will enhance the national fitness institutional system, and step up the planning and construction of venues and facilities in local communities. Hong Kong's First Five-Year Plan also proposes to drive wider participation in sports, and promote sports in the community with the goal of enhancing the overall health of the public.

Currently, the LCSD operates a total of 87 indoor fitness rooms, generally located within sports centres across various districts. However, except for holders of relevant qualifications recognised by the Physical Fitness Association of Hong Kong, China, members of the public who wish to register as a user of LCSD fitness rooms and hire fitness equipment must first attend a three-hour "Briefing on Proper Ways to Use Fitness Equipment" (Briefing Session) organised by the LCSD and then pass a written test, or complete its 12-hour "Fitness (Multi-gym) Training Course" (Training Course) with an attendance rate of at least 80 per cent. Between 2023 and 2025, the number of registered users of LCSD fitness rooms increased by 56 per cent from around 151 000 to 236 000, while the total number of user visits to fitness rooms per year increased by 50 per cent from around 4.852 million to 7.262 million.

A preliminary inquiry by the Office of The Ombudsman revealed a severe shortage of places for the Briefing Sessions and Training Courses organised by the LCSD. In 2025, the LCSD held around 1 000 Briefing Sessions throughout the year with a total of 25 000 places, but the total number of applications in the year was as many as 377 000. In the same year, the LCSD held around 2 500 Training Courses with a total of 58 500 places, but the total number of applications in the year reached 257 000. Unsuccessful applicants who cannot attend the Briefing Session or Training Course are not eligible to use the LCSD's fitness room facilities.

Mr Chan said, "Public recreation and sports facilities are of utmost importance to promoting participation in sports in the community. The high volume of applications for the LCSD's Briefing Sessions and Training Courses reflects keen public demand for use of fitness rooms. While the LCSD requires members of the public to either possess relevant qualifications or complete its fitness training before they can use its fitness rooms, no similar requirements are in place for other risky sports such as swimming. Furthermore, the supply of such training falls far short of demand. All these may be the biggest barrier for wider participation in the fitness sport and should be addressed and removed. The Office considers it necessary to review whether the qualification requirement for users still serves any practical need and whether a similar requirement is in place for public fitness rooms in the country and elsewhere."

Meanwhile, there are two types of hire charges for LCSD fitness rooms, i.e. an hourly ticket and a monthly ticket, the latter entitling the holder to unlimited use. In view of the higher demand by monthly ticket holders, most fitness rooms allocate a larger share of the quota to them. Starting from November 1, 2024, monthly ticket holders have been required to book fitness room facilities via SmartPLAY. In response to their calls for greater flexibility, the LCSD currently allows monthly ticket holders to cancel the booking via SmartPLAY up to one hour before the start of the booked session. The Office has received views that other members of the public can hardly proceed to the fitness room at such short notice, leading to wastage of the vacated place.

The Office also notes that the LCSD does not impose any penalties on monthly ticket holders for failing to take up a booked session. A monthly ticket holder who has made a booking but is absent need not take responsibility at all. Moreover, there is no cap on the number of sessions in fitness rooms that monthly ticket holders can book each day. Their actual use of the facilities is significantly less than the booked period. As a result, even though bookings are full, the actual number of users in the fitness rooms falls short of the number of hirers.

Mr Chan said, "LCSD fitness rooms are publicly funded and affordable. The facilities are scarce public resources and should be reasonably used. An appropriate balance should be struck between convenient booking and efficient use of limited public resources.

"With the promotion of fitness for all elevated to a national strategic level, the LCSD should proactively align with national development strategies by enhancing the mechanism for use of fitness rooms to foster broader participation in sports. In this light, I have decided to launch a direct investigation operation to examine the LCSD’s management of fitness rooms, including the mandatory training requirement prior to use of fitness rooms, the booking mechanism, the utilisation rate of fitness rooms, the LCSD’s monitoring measures and maintenance and repair of fitness equipment. Where necessary, pertinent recommendations will be made for improvement."

The Ombudsman welcomes views from members of the public on this topic. Written submissions should reach the Office of The Ombudsman by November 13:

Address: 30/F, China Merchants Tower, Shun Tak Centre

168–200 Connaught Road Central, Hong Kong

Fax: 2882 8149

Email: di496@ombudsman.hk

The Ombudsman, Mr Jack Chan, today (October 13) announced the launch of a direct investigation operation to examine the effectiveness of the Leisure and Cultural Services Department (LCSD)'s management of indoor fitness rooms. Photo shows available quotas for the LCSD's indoor fitness rooms. Zero represents that the relevant slot was fully booked. Source: HKSAR Government Press Releases

The Ombudsman, Mr Jack Chan, today (October 13) announced the launch of a direct investigation operation to examine the effectiveness of the Leisure and Cultural Services Department (LCSD)'s management of indoor fitness rooms. Photo shows an indoor fitness room of the LCSD. Source: HKSAR Government Press Releases