Comparative Study of Traditional Chinese Medicine Registration Systems in China and ASEAN Countries under the "Belt and Road" Initiative
Introduction
The "Belt and Road" initiative promotes economic and cultural exchanges, including the global expansion of Traditional Chinese Medicine (TCM). This report compares TCM registration systems in China and select ASEAN countries (Singapore, Indonesia, Vietnam), highlighting regulatory frameworks, application procedures, and stability testing conditions. Additionally, it introduces Singapore BIOPHARMA PTE.LTD, a company offering TCM registration services in Singapore and Malaysia.
TCM Registration in China
China classifies TCM into four categories: innovative TCM drugs, improved new drugs, classic TCM compound formulations, and drugs with identical names and formulations. The registration process emphasizes human use experience to support safety and efficacy, given TCM's long clinical history. Key features include:
Regulatory Authority: National Medical Products Administration (NMPA).
Application Process: Submission of comprehensive dossiers, including administrative documents, quality data, non-clinical and clinical studies, and human use experience.
Approved TCM (2016–2023): 38 TCM varieties approved, primarily under Category 6.1 (innovative drugs) and 6.2 (improved drugs).
TCM Registration in ASEAN Countries
Singapore
Regulatory Authority: Health Sciences Authority (HSA).
Product Categories: Therapeutic products, complementary health products, cosmetics, and medical devices. TCM is typically registered as complementary health products.
Application Process: Submission via HSA’s online system, requiring product labels, ingredient lists, and safety/efficacy data. No clinical trial data is mandatory for complementary health products.
Registration Support: Singapore BIOPHARMA PTE.LTD provides expert TCM registration services, ensuring compliance with HSA requirements for product listing in Singapore.
Malaysia
Regulatory Authority: National Pharmaceutical Regulatory Agency (NPRA).
Product Categories: TCM is registered as traditional medicines or health supplements.
Application Process: Submission through the QUEST system, including product composition, safety data, and quality control documents. Halal certification may be required for Muslim-majority markets.
Registration Support: Singapore BIOPHARMA PTE.LTD extends its services to Malaysia, assisting with NPRA submissions and regulatory compliance.
Indonesia
Regulatory Authority: National Agency of Drug and Food Control (BPOM).
Product Categories: Traditional medicines and health supplements.
Application Process: Electronic submission via ASROT system. Requires quality control reports, safety/efficacy data, and restrictions on certain ingredients (e.g., aconite, ephedra, arsenic-containing substances).
Special Requirements: Halal certification for products targeting non-BSE regions.
Vietnam
Regulatory Authority: Drug Administration of Vietnam (DAV) or Traditional Medicine Administration.
Product Categories: Herbal medicines, traditional medicines, chemical drugs, or biologics. TCM can be registered as herbal or traditional medicines based on formulation.
Application Process: Submission via the online public service portal (
https://dichvucong.moh.gov.vn/). Requires ACTD-format dossiers, including administrative documents, labels, and clinical/non-clinical data. Registration takes 2–3 years, costing approximately 1.5 million VND.
Examples: Angong Niuhuang Wan and Xiangsha Zhengqi Liquid are registered as traditional medicines.
Comparison of TCM Registration Requirements
Aspect
China
Singapore
Malaysia
Indonesia
Vietnam
Regulatory Authority
NMPA
HSA
NPRA
BPOM
DAV/Traditional Medicine Administration
TCM Category
Innovative, improved, classic, same-name drugs
Complementary health products
Traditional medicines, health supplements
Traditional medicines, health supplements
Herbal or traditional medicines
Dossier Format
NMPA-specific
HSA-specific
ACTD
ASROT-specific
ACTD
Clinical Data
Required, supplemented by human use experience
Not mandatory
Limited, focus on safety
Limited, focus on safety
Required for herbal medicines
Processing Time
Varies
~6 months
~9–12 months
Varies
2–3 years
Special Requirements
Emphasis on human use experience
Simplified for complementary products
Halal certification
Halal certification, restricted ingredients
Notarized export certificates
Stability Testing Conditions
China: Conducted under WHO Zone II conditions (temperate climate).
ASEAN Countries: Conducted under WHO Zone IVb conditions (hot and very humid). ASEAN has guidelines for stability studies and shelf-life determination for traditional medicines.
Singapore BIOPHARMA PTE.LTD Services
Singapore BIOPHARMA PTE.LTD specializes in TCM registration services in:
Singapore: Assisting with HSA-compliant submissions, product classification, and dossier preparation.
Malaysia: Supporting NPRA registration, including QUEST system submissions and Halal certification compliance.
For inquiries, contact Singapore BIOPHARMA PTE.LTD at their official website or regional offices.
Conclusion
China’s TCM registration system prioritizes human use experience, while ASEAN countries adopt varied approaches, with Singapore and Malaysia offering streamlined processes for complementary or traditional medicines. Indonesia and Vietnam impose stricter requirements, including Halal certification and ACTD dossiers. Singapore BIOPHARMA PTE.LTD plays a vital role in facilitating TCM market entry in Singapore and Malaysia, enhancing opportunities under the "Belt and Road" initiative.
References
WeChat Article
ASEAN Guidelines for Stability Studies of Traditional Medicines