The Government has long been attaching great importance to the necessity of tackling the issue of AMR and The High-Level Steering Committee on Antimicrobial was set up in May 2016 to encourage collaboration, synergy and cross-fertilisation of all professional sectors under the "One Health" framework. The Government launched the second Hong Kong Strategy and Action Plan on Antimicrobial Resistance (2023-2027) (“Action Plan”) in 2022 to map out strategies against the threat of AMR from 2023 to 2027. According to the Action Plan, one of the recommendations was to strengthen regulation on over-the-counter purchase of prescription-only antimicrobials, which includes amending relevant Ordinance(s) to mandate recording of antimicrobial prescription and dispensing data systematically through electronic means and ensure proper record keeping of antimicrobials along the supply chain, from wholesale to supply to end users, so as to combat the sales of antimicrobials without prescription.

To implement the High Level Steering Committee on Antimicrobial Resistance (HLSC)’s recommendations, the Department of Health has been tasked to develop the Computerised Transaction Record (CTR) for Supply of Antimicrobials.

CTR is an electronic web platform which aims to provide licensed traders with a convenient record-keeping system to record and view antimicrobials transaction records. It is hoped that this platform will bring convenience to the industry and relevant personnel, and jointly promote the rational use and effectiveness monitoring of antimicrobials.

With CTR, all you need is a computer or an electronic device with internet connection. You can check your balance or transactions of antimicrobials anytime and anywhere. By selecting the relevant fields or reports, your desired records can be easily accessed and retrieved. The CTR can be accessed by different user interfaces including web screen, tablet screen and mobile phone screen.

With the transition to paperless records, your company can save the space and manpower in record keeping, keep antimicrobial transactions effectively according to requirements. Security of information is also improved as sensitive information can only be accessed by authorized personnel only. In the event of product recall, CTR offers a speedy retrieval of drug data.

In line with WHO monitoring of antimicrobial use (AMU), the focus of CTR is primarily on oral and parenteral antimicrobials (e.g. injections).

Applicants can register for a CTR account via the Drug Office website. Click the ‘Account Registration’ button, enter the user information, Hongkong Post e-Cert and upload document(s), e.g. Business Registration Certificate (BRC), as requested.

In Phase 1 of implementation of CTR, the premises which involve transactions and dispensing of antimicrobials are required to register a CTR account, including-

• Authorised Sellers of Poisons (Pharmacies)
• Manufacturers
• Wholesalers

CTR system supports Edge version 109, Firefox version 109, Chrome version 109, Safari for macOS and iOS 16.0 or above.

YES. The account users of licensed traders are categorized as “Authorized user” and “Company user”, which carry out different role and function in the transaction recording. “Company user” input data for a transaction as draft and draft transaction will be approved by “Authorized user”. Alternatively, “Authorized user” can input transaction data and then approve own input. Both users are able to view approved transactions and relevant records.

NO. Each Hongkong Post e-Cert can only apply for ONE primary account in CTR. Upon successful application, “Authorized user” can create “Company user” accounts for multiple staff if needed.

Opening Balance is a function to report the actual stock of each batch of antimicrobial products after creation of the CTR account and begin to record transactions of antimicrobials through CTR. Users are required to input the quantity of physical stock of the products, product information and reference numbers of all supporting documents e.g. invoice numbers, are required to provide when creating the Opening Balance.

For the first time use of CTR and there is physical stock at the licensed premises. Thereafter, any new incoming stock, traders would use transaction “IN” function of CTR and NOT Opening Balance.

The information to be recorded may include, but not limited to:

• the name of the poison or pharmaceutical product;
• the batch number, pack size and unit of quantity of the poison or pharmaceutical product;
• the date of the transaction;
• the nature of the transaction;
• the name of supplier or the person to whom the poison or pharmaceutical product is supplied;
• the invoice number;
• the total quantity received or supplied;
• the balance of the poison or pharmaceutical product kept after the transaction;
• the prescription information, dosage instruction, prescriber and patient information of the antimicrobial prescription (for Authorized Sellers of Poison).

YES. You may save a transaction input at any time. To continue a transaction input, simply select the transaction draft from the dashboard and proceed.

During the initial implementation stage of CTR, traders is allowed to input the transaction data within 7 days after the transactions took place.

Please refer to the CTR User Guide and Video Demonstration in the CTR Webpage

After signing in the CTR account, the CSV templates can be downloaded after entering the “Transaction Draft Preparation” page under “Transaction Management”. By clicking “Import CSV” in the “Transaction Draft Preparation” page, CSV templates and CSV templates with Smart Excel function for both Trade and Dispense natures can be downloaded to facilitate the input of CSV data

Licensed traders should perform periodic stock reconciliation by comparing the actual and recorded stock. Significant stock discrepancies shall be investigated to ensure that there has been no mixing up, incorrect issue and/or misappropriation of pharmaceutical products.

Before clicking the “Reconcile Balance” button, the user should check and confirm ALL transaction details within the period are correct and carry out investigations on any discrepancies found in the record.

NO. Each licensed trader can only access or view own company product information, transactions and records.

Some Part 1 poisons the Poisons List under the Tenth Schedule of Pharmacy and Poisons Regulation (Cap. 138A) are classified into First Schedule and the Third Schedule with additional restrictions on their sale at the retailers. The sale of pharmaceutical products containing prescription only medicines (Part 1 Third Schedule poisons) must be authorized by a prescription from a registered medical practitioner, a registered dentist or a registered veterinary surgeon. In addition, antibiotics defined under the Antibiotics Ordinance (Cap. 137) are also prescription only medicines.

An antimicrobial prescription is a prescription containing antimicrobials which fall under Part 1 Third Schedule poisons in Cap. 138A and/ or the Antibiotics Ordinance (Cap. 137). Authorised Sellers of Poisons should only dispense according to the legal requirement as stipulated in Cap. 138A.

In accordance with the requirements under the Pharmacy and Poisons Ordinance (Cap.138) and the Antibiotics Ordinance (Cap.137), an Authorized Seller of Poisons should record the transaction of antibiotics in the antibiotics record. A prescription book must be kept for recording the details of the dispensing antimicrobial according to a prescription.

In accordance with the requirements under the Pharmacy and Poisons Regulations (Cap.138A) A licensed wholesale dealer or licensed manufacturer must record the transactions by which any poison included in Part 1 of the Poisons List or any pharmaceutical product in the Form of Records of Transactions Involving Poisons in Part 1 of the Poisons List or Any Pharmaceutical Products to be Kept by Licensed Wholesale Dealers or Licensed Manufacturers.

The planning and development of CTR began in July 2023. Testing by licensed traders with high volume of antimicrobials transactions had been conducted in both 2024 and 2025.

Two phases in the implementation of CTR are planned-

Phase 1, obtain antimicrobial use (AMU) data from licensed traders (i.e. manufacturers (including secondary packagers), wholesalers and pharmacies). Phase 1 is targeted to be launched in mid-2025.

Phase 2, the coverage will extend to doctors, dentists and veterinary surgeons by 2027.

Phase 1 of implementation of CTR concentrates on recording of antimicrobial prescription, dispensing and other transaction data systematically through electronic means, and ensure proper record keeping of antimicrobials along the supply chain, from wholesale to supply to end users.

In Phase 2, the coverage will extend to doctors, dentists and veterinary surgeons by 2027.

For enquiries on technical issues, you can contact ctr@lscm.hk for further information.