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Wholesale licences

Licences to wholesale regulated poisons under the Health (Drugs and Poisons) Regulation 1996 (HDPR) will continue under the Medicines and Poisons Act 2019 (MPA) which replaced the HDPR on 27 September 2021. New licences for the wholesale of hazardous poisons will continue to be issued under the MPA.

Who needs a licence

A licence will be required to wholesale hazardous poisons under the MPA. Hazardous poisons include substances in schedules 2, 3, 4, 7 and 8, under the Commonwealth’s Standard for the Uniform Scheduling of Medicines and Poisons (the Poisons Standard), when not used or intended for use for therapeutic purposes.

Queensland manufacturing licence holders are deemed to also hold a wholesale licence for the poisons stated on their licence.

Transition of poison wholesaler authorities under the MPA

PersonPoisonAuthorisation under HDPRAuthorisation under MPAScope
Poison wholesalersHazardous poisons

(S2, S3 and S7) 
Poison wholesale licence for S2, S3 and S7 poisonsWholesale licence for hazardous poisons

May apply to include additional poisons
  • Authorised to buy, possess, supply and dispose of waste
  • Must have a substance management plan
Poison wholesalersProhibited substances

(S9 and S10)
ApprovalGeneral Approval or Wholesale licence
  • Authorised to buy, possess, supply and dispose of waste
  • May need a substance management plan, if required as a condition of licence

Authorisations under the HDPR will transition as closely as possible to a new authority under the MPA. A wholesaler may apply for an amendment to their authority to wholesale additional substances.

Why you need a licence

The wholesale licence authorises the licence holder to buy, possess, supply primarily by wholesale and dispose of the substances stated on the licence.

Wholesalers may also apply for an approval to wholesale prohibited substances (S9 and S10 substances under the Poisons Standard).

Apply for a licence

Apply for a licence to wholesale poisons using Poisons licence application forms and fees.

Licences across multiple sites

The holder of a wholesale licence who operate from multiple sites may request one licence to cover all sites, rather than having separate licences for each site. The licence fee will be calculated based on the number of sites held under the licence.

Substance management plans

The holder of a wholesale licence will be required to have a substance management plan (SMP), which identifies and addresses the risks associated with the wholesale supply of hazardous poisons. An SMP may form a part of other plans or systems including quality and safety management systems.

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

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

Requirements for licence holders

The Poisons Regulation requires the holder of a wholesale licence to implement measures to ensure the supply and purchase of regulated poisons is restricted to authorised persons.

Purchase orders

Purchase orders for wholesale buying of regulated poisons must contain specific details such as form, strength and amount of regulated poison sought, details of the substance holder and delivery address, etc. The purchase order must allow the licensee to verify the details of the buyer.


Wholesalers must ensure that storage and transport of regulated poisons occur in a manner that prevents access to unauthorised persons. Additional physical or electronic security measures are required for high-risk poisons.


Wholesalers must ensure details of poisons sold by wholesale are recorded in an appropriate manner. Specifically, a High-risk poison register, which records all dealings in relation to high-risk poisons, must be established. The register may be electronic or paper based and must include details (e.g. date, name, form, strength and amount of poison, nature of dealing) to be able to reconcile the amount of poison received, applied, supplied or disposed of.

Other jurisdictions

Wholesalers from another state or a foreign jurisdiction may supply a regulated poison if they are authorised to do so in their jurisdiction.

Related information

Departmental standards

Last updated: 24 September 2021