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Logistics services for poisons

Logistics companies that transport, store or deliver regulated poisons in Queensland will be affected by the changes and requirements that apply to the supply, storage and transport of regulated poisons under the Medicines and Poisons Act 2019 (the MPA). The MPA has replaced the Health (Drugs and Poisons) Regulation 1996 (HDPR) from 27 September 2021.

Changes in the MPA

If a logistics company is engaged or contracted by a poison manufacture or wholesale licence holder to store, distribute or transport regulated poisons, the company is not required to hold a licence or an approval under the MPA.


If, however, the logistics company repackages regulated poisons and distributes it (i.e. sell or supply), it will require a manufacturing licence, regardless of whether the work is being undertaken on behalf of a licensed manufacturer or wholesaler.

Substance management plan

The poison manufacture or wholesale licensee is responsible for meeting the requirements under the MPA. This includes developing and implementing a Substance Management Plan (SMP) to ensure safety and security in all dealings with regulated poisons.

Persons who hold a manufacturer or wholesaler licence will be required to prepare and implement an SMP.

The SMP must comply with Departmental standard - Substance management plans for regulated poisons (PDF 283 kB).

Licensees have until 26 September 2022 to prepare and implement SMPs.


Any premises where regulated poisons are stored, including at a logistic company’s storage facilities, are classed as a regulated place, and must be included under the manufacture or wholesale licence and comply with the licensee’s SMP.


During transport the regulated poisons may be transferred from one vehicle to another, or temporarily stored awaiting connection. Such arrangements must ensure the safety and security of the poison and be clearly set out in the licensee’s SMP, as the licence holder remains responsible for the safe transport and delivery including interim storage of the poison.

Apply for a licence

Apply for a licence by using Poisons licence application forms and fees.

Related information

Last updated: 24 September 2021