Summary of APSMI Country Report 2019
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Contents
Introduction…………………………………………………………………………… 2 I. Summary of OTC Regulation in Member Countries………………………. 3 II. Activities to Promote Self-Medication by Member Associations…………11 III. OTC Market in Asia-Pacific Region…………………………………………..23
Annex 1: Dossier Requirements for OTC Registration Annex 2: Rx-to-OTC Switch Products in Member Countries Annex 3: New and Amended Regulation from 2016 to 2019 in Member Countries
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Introduction
Thanks to the contributions by its member associations and magnanimous provision of the market analysis by Nicholas Hall, Asia-Pacific Self-Medication Industry (APSMI) compiled the APSMI Country Report 2019 in October 2019. The Report was published on the occasion of the 12th Global Self-Care Federation Asia-Pacific Regional Conference & 4th APSMI General Assembly held in Beijing, October 2019, made available to the meeting participants and the APSMI members.
The Report outlines the OTC regulations and the activities to promote self- medication in APSMI member countries; i.e. China, Chinese Taipei, Indonesia, Japan, Korea, and Thailand. It also includes analyses of global and Asian OTC markets as well national markets in the region.
Though the access to the full Report remains to be the members’ privilege, APSMI has decided to publish its summary to the open public. The APSMI sincerely hopes that the information contained in the Summary Report will contribute to the OTC market growth, harmonization of OTC regulation, and promoting self-medication in the region.
APSMI Secretariat November 2019
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I. Summary of OTC regulations in member countries
-Notes – The description of each country is simplified for the ease of comparison.
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1. Category of drugs (OTC and Prescription and others?) China OTC and Rx. Herbal medicines are classified into OTC or Rx. OTCs are subcategorized with regard to allowable sales route. Some are general sales line items. Chinese OTC, RX and Traditional Chinese Drugs. OTCs are Taipei subcategorized into Pharmacy-only and general sales drugs. Indonesia OTC and Rx. Herbal medicines form another category different from OTC or Rx. OTCs are subcategorized with regard to allowable sales route. Some are general sales line items. Japan OTC and Rx. Herbal medicines are classified into OTC or Rx. OTCs are subcategorized with regard to allowable sales route. Korea OTC and Rx. Except for little exception, OTCs are sold only at pharmacies. Philippines OTC and Rx. Herbal medicines form another category. OTCs are sold only at pharmacies. Thailand Rx, Modern OTC, and Traditional OTC. OTCs are subcategorized into drug store-only and general sales drugs.
2. Abridged approval applications (for e.g. OTC with precedents, monograph- compatible OTCs, etc.) China Full application only. There is no difference in required data between Rx and OTC. Chinese Abbreviated applications for switch OTC and monographs- Taipei compatible OTCs Indonesia Abbreviated applications for drugs with precedents. Japan Abbreviated applications for switch OTC and monographs- compatible OTCs Korea Abbreviated applications for switch OTC and monographs- compatible OTCs Philippines Abbreviated applications for switch OTC and monographs- compatible OTCs Thailand No abbreviated application for OTC. OTC applications follow the guidelines for new drugs or generic drugs.
3. Review track /Review department specially for OTCs
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China The authority has no specially designated review track or review department for OTC. Approval application for OTC is reviewed not differently from new drugs. Chinese The authority has no specially designated review track or review Taipei department for OTC. Approval application for OTC is reviewed not differently from new drugs. Indonesia The authority has specially designated review track and review department for OTC. Japan The authority has specially designated review track and review department for OTC. Korea The authority has no specially designated review track or review department for OTC. Approval application for OTC is reviewed not differently from new drugs. Philippines The authority has no specially designated review track or review department for OTC. Approval application for OTC is reviewed not differently from new drugs. Thailand The authority has no specially designated review track or review department for OTC. Approval application for OTC is reviewed not differently from new drugs.
4. Regulatory permission on Advertisement of OTC to the general public China Need of regulatory permission for advertisement in all media (TV, Radio, Internet, Printed materials). Chinese Need of regulatory permission for advertisement in all media Taipei (TV, Radio, Internet, Printed materials). Indonesia Need of regulatory permission for advertisement in all media (TV, Radio, Internet, Printed materials). Japan No regulatory permission is needed. But the Japanese OTC industry has self-imposed guideline on advertisement as well as a committee to survey member companies’ advertisements as to their adherence to the guidelines and to recommend rectification when there are any violations. Korea Need of regulatory permission for advertisement in all media (TV, Radio, Internet, Printed materials). Philippines Need of regulatory permission for advertisement in all media (TV, Radio, Internet, Printed materials).
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Thailand Need of regulatory permission for advertisement in all media (TV, Radio, Internet, Printed materials).
5. Regulatory permission on revising labelling of OTCs China Necessary Chinese Necessary Taipei Indonesia Necessary Japan Necessary, but only for the essential part on the drug’s indication, dosage, and caution on use. Other parts to provide information of more promotional nature can be revised without permission. Korea Necessary Philippines Necessary Thailand Necessary
6. Standards and Guidelines applicable to OTC drugs (1) GMP China GMP applied to OTC is aligned to PIC/S GMP Chinese GMP applied to OTC is aligned to PIC/S GMP Taipei Indonesia GMP applied to OTC is aligned to PIC/S GMP Japan GMP applied to OTC is aligned to PIC/S GMP Korea GMP applied to OTC is aligned to PIC/S GMP Philippines GMP applied to OTC is aligned to PIC/S GMP Thailand GMP applied to OTC is aligned to PIC/S GMP
(2) Pharmacopoeia China The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees. Chinese The authority applies its domestic pharmacopoeia to OTC. Other Taipei countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees. Indonesia The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees.
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Japan The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees. Korea The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees. Philippines The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees. Thailand The authority applies its domestic pharmacopoeia to OTC. Other countries’ pharmacopoeia e.g. USP, EP) are also used as reference to varying degrees.
(3) ICH guidelines applicability
i. Q1, 3, 6, 7 China Basic ICH Q Guidelines (Q1, Q3, Q6, and Q7) are generally applicable to both Rx and OTC. Chinese Basic ICH Q Guidelines (Q1, Q3, Q6, and Q7) are generally Taipei applicable to both Rx and OTC. Indonesia Basic ICH Q Guidelines (Q1, Q3, Q6, and Q7) are generally applicable to both Rx and OTC. Japan All ICH Q Guidelines are applicable to RX and direct OTC (new chemical entity approved first as OTC). Other OTC are exempted from application of ICH guidelines but subject to simpler domestic guidelines. Korea Basic ICH Q Guidelines (Q1, Q3, Q6, and Q7) are generally applicable to both Rx and OTC. Philippines Basic ICH Q Guidelines (Q1, Q3, Q6, and Q7) are generally applicable to both Rx and OTC. Thailand Relevant ASEAN guidelines apply. ICH Guidelines are used as reference. Q1 : Stability Q3: Impurities Q6 : Specifications Q7 : GMP for Active Pharmaceutical Ingredients
ii. S4 (Chronic Toxicity Testing)
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China S4 Guideline is applicable to both Rx and OTC. Chinese S4 Guideline is applicable to OTC that is new drugs (direct Taipei OTC). Indonesia S4 Guideline is not applicable to OTC. Japan All ICH S Guidelines are applicable to RX and direct OTC (new chemical entity approved first as OTC). Other OTC are exempted from application of ICH guidelines but subject to simpler domestic guidelines. Korea S4 Guideline is applicable to OTC. Philippines S4 Guideline is applicable to OTC. Thailand S4 Guideline is applicable to OTC.
iii. E2B, E2D, E6 China E2B, E2D, E6 are all applicable to Rx and OTC. Regarding ADR reporting, OTC and Rx undergo the same regulation. Chinese E2B, E2D, E6 are all applicable to Rx and OTC. Regarding ADR Taipei reporting, OTC and Rx undergo the same regulation. Indonesia E2D and E6 are all applicable to OTC. Japan E2B, E2D, E6 are all applicable to Rx and OTC. Regarding ADR reporting, OTC and Rx undergo the same regulation. Korea E2B, E2D, E6 are all applicable to Rx and OTC. E2B is partly applicable. Philippines E2B, E2D, E6 are all applicable to Rx and OTC. Thailand E6 Applies to OTC. E2B and E2D are not implemented in Thailand (for Rx or OTC). E2B : Individual Case Safety Reports E2D : Standards for Expedited Reporting E6 : Good Clinical Practice iv. M1 and M4 China Pilot of M1 and China CTD (similar to M4) are implemented. Chinese M1 and M4 are applicable to OTC. Taipei Indonesia M1 and M4 are applicable to OTC. Japan M1 is applicable to both Rx and OTC. M4 is applicable to direct OTC. Other types of OTC are exempted from M4 application. Korea M1 is being applied to OTC in stages. M4 is not applicable to OTC. Philippines M1 is not applicable to OTC. M4 is applicable to OTC.
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Thailand M1 and M4 are not applicable to OTC. M4 is applicable only to new drugs. M1 : MedDRA - Medical Dictionary for Regulatory Activities M4 : Common Technical Document
7. Rx-to-OTC Switch China The process starts when applicants make applications for manufacturing OTC version of a Rx. The authority has an OTC switch guideline, with which to judge switch-ability. Chinese The process starts when applicants make applications for Taipei manufacturing OTC version of a Rx. The authority publishes the checklist of required documents as well as review principles. The assessment is made by an advisory committee. Indonesia There is no switching scheme. Japan There is an official scheme to promote switching. An advisory committee to the Ministry of Health Labor and Welfare assesses Rx ingredients for switch-ability based on requests from the public. If judged appropriate, the ingredients are recommended for switching to the Minister. Based on the publicized recommendation, any applicants make approval applications for the recommended ingredients. Korea The process starts when applicants make applications for manufacturing OTC version of a Rx. The authority publishes an OTC switch guideline, with which to judge switch-ability. Philippines The authority publishes the conditions and requirements regarding switch. But there has been no Rx-to-OTC switch. Thailand The process starts when applicants make applications for manufacturing OTC version of a Rx. The authority defines clear criteria of switching as well as a guideline for Patient Information Leaflet user study. The assessment is made by an advisory committee taking the result of public hearing into consideration.
8. Drug Master File (DMF) China DMF for active pharmaceutical ingredients (API). is mandated for OTC
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Chinese DMF and API GMP certificate are mandatory for OTC. Taipei Indonesia DMF is applicable for API in new product OTC. Japan DMF is not applicable for OTC. Korea DMF for API are mandated for some OTC Philippines DMF is not applicable for OTC. Thailand DMF is not mandated for OTC.
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II. Activities to promote Self-Medication by member
Associations
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1. China 1. Research and studies conducted by the member organization or in which the member organization has been involved in: On-going researches carried on for the following topics 1) Twin spans products (RX/OTC) management topic research 2) Non-prescription drug registration regulation research 2. Publications by organization or publications in which the organization was involved (please list the number of copies published, the target readers as specifically as possible) "China Non-Prescription Drugs Industry Development Blue Book 2018" will be published in 2019. The blue book is target to related regulatory agencies, industry and the media. Over 2,000 copies were provided to the industries and to the general public via a publishing agency. 3. Events for promotion of self-medication, hosted by the organization or in which the organization was involved 2017/2018/2019 International Self-Care Day promotion activities and events supported by CNMA. 4. Advertising activities utilizing media, in which the organization was involved 1) Through the mass media to promote “International Self-Care Day". 2) Through the mass media to launch the activity of OTC Brand promotion month in 2018 and 2019. 5. Utilization of organization website CNMA’s website included more information on OTC formulation and members activities. 6. Activities for government and regulatory authorities, lobbying activities Continue to be involved in many government research activities on OTC regulations. 7. Joint activities with other organizations NA
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2. Chinese Taipei 1. Events for promotion of Self-Medication, hosted by association or in which the association is involved TPMMA hold several events to establish the plate form for OTC industry to share information and learning, including: 1) OTC Brand Marketing Forum: to share the marketing best practice from leading brands to the industry and highlight the importance of a brand image. 2) OTC Stakeholders Summit (Experience from Japan): speakers from Dentsu (pharmaceutical market overview), Santen (new entry to Taiwan market from brand point of view), Matsumotokiyoshi Drug Store (opportunity in Taiwan from channel point of view) and AC Nielson (OTC market overview) to share the view and opportunity in Taiwan. 2. Activities for Government and Health Authority, lobby activities 1) OTC Task Force (composed by regulators, academics, pharmacists and industry representatives) was working with TFDA to update and expand the OTC monograph from 10 categories to 16 categories. Expanding the dermatological category in to 7 sub-categories, including anti-fungal, anti-biotic & disinfectant, antipruritic & anti- inflammatory, anti-acne, diaper rash and dry skin. 2) Simplified DMF requirement for OTC registration: to exempt full dossier of DMF for OTC registration and only requires basic CMC documents. 3) Guidance for switch application (1st applicant): in order to encourage industry to apply for switch application, TFDA published a reference guidance (Rx-to-Pharmacy only) to outline basic requirements for switch application. In which, in addition to the overview of approval status in major countries, it requires the “Training materials to Pharmacists” for such application which is important to support the consultation to the pharmacists once the product is switched from Rx- to-OTC. An example of “pharmacist training” was established by TFDA and published in TFDA website. 4) TFDA announced Refuse to File (RTF) for new drug and accepted to exclude OTC New Drug from this requirement. In addition, industry submitted the proposal for “simplified requirements for OTC New Drug registration” and pending TFDA consideration.
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5) Worked with Rx group to exempt the legalization requirements for: - API GMP (original copy) issued by 10 major countries - CoPPs issued by 10 major countries 3. Promotion of Self-medication with other associations _ International Network 1) Japan―Taiwan Workshop on the Regulation of OTC Medicine (OTC workshop) hold in December 2017 to exchange experience on OTC policy and regulatory requirements between Taiwan and Japan. 2) 6th Japan-Taiwan Joint Symposium (OTC section): to discuss the advertisement challenge in Taiwan (Oct 2018) 3) Support APSMI to host the 4th Self-CARER meeting in Taipei (March 2018) This meeting included a pilot training programme _ Self-CARER university (supported by TSMIA), closed part and open part. There were 32 regulators from 10 health authorities attended the meeting. Key topics were focus on “promotion of self-medication”, “switch” and “increase efficiency on registration/review process”.
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3. Indonesia 1. The Smart Community Movement Program On Drugs Usage (GEMA CERMAT) A joint effort between the government and the community through a series of activities in order to create awareness, well understanding and community skills in using drugs appropriately and correctly. This movement aims to increase public understanding and awareness about the importance of using drugs properly, increasing independence and changing people's behavior in choosing and using drugs correctly, and ultimately will increase the rationality use of drugs. 2. Promotion of : “Let's Live Healthy, It Starts with Us” The national movement initiated by the President of the Republic of Indonesia announced in the context of strengthening health development which puts forward promotive-preventive efforts as first priority, without ruling out rehabilitative and curative efforts by involving all components of the nation in promoting paradigm of healthy with support from pharmaceutical industry. 3. Guidelines on the Use of OTC Guidelines on the Use of OTC is compiled to assist the public in conducting self medication. The purpose of this guideline is to guide people who wants to do self medication and Pharmacists as guideline to help communities in self medication. 4. Promotion of Self Medication at Communities and Pharmacies Education Care Of Medicine And Food Safety from National Agency of Drug and Food Control (NADFC), National movement to correctly GET, USE, SAVE, DISPOSE drugs. The first is GET, which means getting the medicine in the right place, so that its benefits, safety and quality are guaranteed. The right place means that there is legality, for example a pharmacy, hospital, licensed drug store, clinical pharmacy. Second, USE means to use drugs in accordance with the indications diagnosis of disease), according to the dosage, according to the rules of use, and according to the way of administration. Third, SAVE, i.e. store medicine as written on the package, except if it has to be stored in special condition. Generally the drug is stored in a cool place (15-25 ° C), not exposed to direct sunlight, not in a humid place, and keep out of reach of children.
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Fourth is DISPOSE. Disposing of drugs must also be with the correct procedure. Drugs that are damaged or expired must be removed immediately, so that they can no longer be used. Disposal of over-the- counter drugs (green circle logo), limited over-the-counter drugs (blue circle logo) and prescription drugs (letter K with red circles) can be done by the communities themselves. In order not to be abused by other parties, the drug should be disposed of in a certain way so that it is completely out of shape. 5. Switch Rx to OTC Climate Switch will be done by Ministry of Health under the recommendation of National Agency of Drug and Food Control (NADFC) 6. Healthy Living Community Movement Program (GERMAS) GERMAS is a movement from Ministry of Health (MOH) that aims to promote a habit of healthy living and leave the habits and behavior that are less healthy. GERMAS action was also followed by promoting hygienic behavior and support for infrastructure programs on a community basis. This program focuses on several agendas such as: 1. building access to fulfill drinking water needs, 2. public health installations and 3. build of habitable settlements. These are the basic infrastructure that forms the foundation of the healthy living community movement. Changes in community life patterns that are becoming more modern are one of the bases of the GERMAS or the Healthy Living Community Movement launched by the Ministry of Health of the Republic of Indonesia. 7. Healthy Indonesia Program with a Family Approach Guideline Program from Ministry of Health (MOH) to ensure the state of well being of families. This program is developed by defining: a. Recognize developmental disorders on the health of each family member, b. Make decisions for correct action to achieve proper health, c. Provide care to sick family member, d. Maintaining an atmosphere at home, that is beneficially for the health of each family members, e. Good communication between families and health service facilities.
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4. Japan 1. Self-Medication Tax deduction Consumers spending more than JPY 12,000 in a year on OTC drugs that were switched from Rx are eligible for tax deduction; the cost exceeding the limit is deducted from the consumer’s taxable income. Japan Self-Medication Industry (JSMI) has been promoting this system since its inception in 2016, by publishing booklets and posters, sponsoring newspaper articles and advertising. JSMI has been negotiating with the government to expand the scope of the eligible OTC drugs as well as to lower the minimum consumption. JSMI analyzes the statistics on the consumers receiving the deduction as well as the financial benefits they enjoy to suggest improvements to the mechanism to the authority.
2. Communication with Health Authority Japan Self-Medication Industry has been having periodical formal meetings with high-rank officials of Ministry of Health Labor and Welfare (MHLW). The topics discussed usually include those on promotion of self- medication. In 2018 there were held two such meetings. 3. Promotion of Self-medication at community pharmacies JSMI supported the Japan Pharmacist Association, in its training the pharmacists at the specially designated “Health Support Pharmacies” in 2016. 4. Promotion of Rx-to-OTC Switch In the new Rx-to-OTC switch mechanism established in 2016, JSMI has been playing an important role of provided MHLW with the information on the switch candidates. 5. “Self-medication” Handbook Since 2002, JSMI has been publishing the Handbook (2019 version: A5 size, 40 pages) issuing about 200,000 copies. The Self-Medication Handbook is an information booklet on OTC medicines and self- medication designed to be understandable for wide age groups, from 10- year-olds to the elderly. The handbook is distributed in pharmacies and at consumer events across Japan. 6. Press Conference JSMI organizes Press Conferences after major annual events, including New Year Celebration Party in January and JSMI General Assembly in May. The Conference covers JSMI policies including those
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related to promoting Self-medication 7. Enlightenment on “Self-medication” (1) Self-Medication Day Symposium Twenty-fourth of July is the International Self-Care Day. JSMI with a help from the Ministry of Health, Labor and Welfare as well as JFSMI, organized a half-day symposium open to the public on the day in 2018 and 2019, inviting speakers from the regulatory authority, academia, Japan Pharmaceutical Association, and a chain pharmacy association. (2) Kids’ School how to use drugs right JSMI has been organizing enlightenment seminars in cooperation with educational institutes for parents and children to promote understanding of OTC drugs as well as the value of self- medication since 2011. In 2019, the seminars are held at 4 locations from the northern-most island of Hokkaido to the southern-most Kyushu for the total of 7 days. The seminars are held with supports from school of pharmacies of multiple universities. (3) Jamboree at Fukutoku Forest “Accurate knowledge on OTC drugs for proper use” JSMI has been organizing two-day outdoor event to encourage exact knowledge on and proper use of OTC drugs. The Jamboree takes place in the yard of “Fukutoku Shrine”, which worships a god of drug in the Japanese myth. The shrine in Tokyo has a yard of about 25m by 40m, which houses about 30 booths by OTC manufacturers, that disseminate information on their products. The event also features mock-pharmacies where one can experience compounding of drugs. The event in 2018 enjoyed more than 12,000 visitors. 8. Home Page JSMI maintains various information in Japanese and English on OTC drugs and self-medication on its Website. The information is categorized and indexed according to drug classes as well as symptoms. Japan Self- Medication Data Base Center (JSM-DBC) was established in 2000 to provide an on-line database covering all the OTC drugs sold in Japan. The Website carries frequently asked questions on OTC drugs and self- medication and their answers. The questions have been continuously replenished from those received by the member companies.
9. Helping Self-diagnosis Measurements
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Since 2014, some of Japanese pharmacies started a service of measuring the HbA1c level. Consumers visiting pharmacies take a tiny volume of their blood by themselves and hand it to the pharmacist, who measures the blood level of the protein. When the measurement is high enough to justify medical intervention, the pharmacist recommends the consumer to see doctors. JFSMI has organized “Council for Self-diagnosis Measurements” to offer to help the self-diagnosis efforts. The Council has been offering lectures on the relevant regulations and helping the pharmacies calibrate the analytical devices. As of 2019 there are about 360 pharmacies throughout Japan, offering in total around 80 measurements per month. 10. Advertisement Guidelines and Seminars JFSMI periodically revises its voluntary guidelines that help understand and abide by the regulation issued by the regulatory authority. In 2019 the JFSMI guidelines were revised, whereupon the organization organized 2 seminars on OTC advertisements in Tokyo and Osaka in July. The seminars invited MHLW’s responsible officials and officers from JSMI Advertisement Committee as well as Japan Advertising Review Organization (JARO), overlooking Japan’s advertising in general.
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5. Korea 1. Operating Drug Advertisement Pre-Review Committee In Korea, OTC drug is defined as a subject for preliminary review in public advertising, and The KPBMA has organized and operates a ‘Drug Advertisement Pre-Review Committee’ under the Pharmaceutical Affairs Act. In addition to the reviewing activities, KPBMA advises the industry to make sure that the advertisements and promotions of OTC items are not curtailed by the pre-review system, and encourages the industry to make full use of new media such as SNS. The KPBMA also regularly hold seminar for drug advertisement pre-review system and case studies, discussion sessions for stakeholders to improve the review system. 2. Conducting study to revitalize OTC drug market The KPBMA has commissioned relative academia to study on expanding the market of OTC drugs in Korea. The main contents are the expansion and improvement of Korean monograph items through the analysis of the domestic OTC drug status and comparative analysis with overseas cases. 3. Supporting the consumer enlightenment campaign by academic society Various domestic societies disseminate information to consumers about the treatment of diseases and the proper use of drugs, and domestic pharmaceutical companies provide financial funding for the societies. The KPBMA runs the Code Deliberation Committee, which considers and approves such funding to support the proper operation of the society. 4. Supporting stable operation of the full ingredient labeling system As of December 2017, the full ingredient labeling system has been implemented to provide the correct drug information to consumers. The KPBMA participates in a committee composed of governments, associations, companies, etc. to encourage stable settlement of the system and present industry opinions to the government.
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6. Philippines 1. Events for promotion of self-medication, hosted by the organization or in which the organization was involved Member companies have participated in the Pilot Project on the Review of Over-the-Counter Applications of Philippine Food and Drug Administration. 2. Advertising activities utilizing media, in which the organization was involved Meeting with Ad Standards Council regarding updates on new advertising regulations and lobbying concerns of member companies. 3. Activities for government and regulatory authorities, lobbying activities 1) Review of the Philippine Code of Ethics 2) Review of OTC guidelines 3) Review of Pharmacy Law (in partnership with Philippine Healthcare Association of the Philippines) 4) Created initial list of Pharmacist Only Medicines (in partnership with Philippine Pharmacists Association) 5) Active participation in the Pilot Project on Review of Over-the-Counter Applications (ROTCA) with Philippine Food and Drug Administration 6) Submitted position papers on the increased of fees and evaluation of permit applications 4. Joint activities with other organizations 1) Review of Pharmacy Law (in partnership with Philippine Healthcare Association of the Philippines) 2) Created initial list of Pharmacist Only Medicines (in partnership with Philippine Pharmacists Association) 5. Current situations and issues regarding the permeation of self-medication October 2018: FDA issued Guidelines on the submission of application for the pilot project on ROTCA. Member companies of chosen associations had participated in the said project. After the pilot project on ROTCA, there is no significant update yet from FDA on the full implementation on tier 1 and tier 2 systems application in the aim to reduce the processing timeline.
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7. Thailand 1. Self-CARER participation TSMIA participated in the 4th self-CARER meeting during 20 – 22 March 2018, in Taipei, as industry observer / expert to support regualtors’ discussion. TSMIA also work in collaboration with Thai FDA in designing and delivery of Self-CARER University (SCU), which is the module training on self-CARE medicines to regulatory authorities (total 38 participants from 10 countries). TSMIA is also the leader in the workshop “Simplified registration in action”, in the SCU program. 2. Partnership with Pharmacist Group TSMIA regularly supported the speaker and lecture for community pharmacist, and regulatory pharmacist groups, to build the network & partnership. The recent topics include: Medicine reclassification requirement and industry experience, OTC regulation updates etc. 3. Partnership with Thailand FDA TSMIA provided technical/regulatory support to Thai FDA in revision of the Medicine Reclassification guideline (2nd revision) (year 2017), and related documents including standard process, timeline and evaluation fee. TSMIA also initiate the proposal in OTC regulatory reform to Thai FDA, such as abbreviated dossier for OTC, advertising guideline, which is being progressed in FDA discussion stage. 4. Annual TSMIA technical conference TSMIA arranged the annual TSMIA technical conference “self-CARE: Keep Pace with self-care, OTC Drugs regulation and market trend” on 4th July 2019, in Bangkok. The conference provides the update on regulation, self-care policy and consumer health care market trend. There are about 100 persons attending the conference, with also the speaker from Thai FDA and industry. The aim is to promote self-CARE sector awareness within pharmaceutical industry.
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III. OTC Market in Asia-Pacific Region
By courtesy of Nicholas Hall
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Global OTC Overview 2018 provided by Nicholas Hall Europe in July 2019
All quoted data is for full year 2018 at manufacturers’ selling price from Nicholas Hall’s DB6 Global OTC Database. Does not include e-commerce and mail order sales unless otherwise stated
Global overview: OTC growth continues to slow There was little change in the retail CHC market during 2018, with sales growing by 4.0% vs the 4.1% recorded in 2017. Factors behind the disappointing result include a relatively poor year for CCA (+3.7%) and a lack of switch, most notably in the US. Growth slowed in both Europe (+2.6% vs +2.8%) and N America (+2.7% vs 3.2%), while there were only modest increases in Asia-Pacific (+4.6% vs +4.5%), LatAm (+9.5% vs +9.1%) and Rest of World (+7.2% vs +7.0%). GIs (12.2% share of global sales) was the only major category to break the 5.0% growth barrier in 2018, buoyed especially by antinauseants (+10.5%) and antidiarrhoeals (+9.2%) following double-digit growth in China, the largest market for these subcategories. We are seeing an increase in use of certain types of GIs globally as eating habits change, such as consuming food on-the-go amid hectic lifestyles and stressful work environments. No.1 major category by revenue, VMS (30.5% share) advanced by 4.3%, with below-average growth for leading subcategory multivitamins (+3.0%) partially offsetting the continued expansion of No.2 probiotics (+10.8%); six of the Top 10 global markets for this subcategory recorded double-digit increases (all 10 were positive), as product positioning widened beyond traditional use for GI disorders into other areas such as immunity and feminine intimate health. Our industry is heavily reliant on seasonal factors, and an unremarkable year for CCA (20.6% share) played a significant part in the poor global trend. Only cough remedies (+5.3%) and chest rubs & inhalants (+7.5%) performed above average, while a terrible year for allergy remedies in the US (-1.2%, 57% share of global allergy revenue) dragged down the overall result for that subcategory (+2.6%). Combined growth of allergy remedies excluding the US was 8.0%.
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Derma (13.6% share) endured the lowest growth of all major categories (+2.7%), with below-average results in seven of the Top 10 global markets (including all of the Top 5). Haemorrhoid preparations and antiseptics & disinfectants performed best, advancing by just over 5%. Analgesics (+4.0%; 13.4% share) and Lifestyle OTCs (+4.0%; 9.8% share) both slowed marginally vs 2017; the former was impacted by a notable drop-off in growth of topical treatments, caused mainly by the US. Looking at the “all channels” version of the DB6 dataset – new for 2019 – which reports on topline figures of direct sales, internet & mail order plus key brands in selected leading markets, total OTC sales are worth US$174bn, of which store-based sales account for 78%, with direct sales generating 14%. Internet & mail order currently accounts for 9% of the “all channel” universe, with sales dominated heavily by VMS supplements in China and the US. However, this channel has seen a CAGR of 20% since 2014 and will continue to increase dramatically over the next decade.
Global: Sales and growth by major OTC category 2018
US$mn Growth US$mn 2017 Market share 2018 2018/2017 GLOBAL TOTAL OTC SALES 130278.634 135436.415 4% 100.0 Vitamins, Minerals & 39585.107 41280.157 4.3% 30.5 Supplements Cough, Cold & Allergy 26881.036 27881.484 3.7% 20.6 Dermatologicals 17912.807 18389.111 2.7% 13.6 Analgesics 17419.722 18114.299 4% 13.4 Gastrointestinals 15736.155 16521.133 5% 12.2 Lifestyle OTCs 12743.807 13250.232 4% 9.8
Source: Nicholas Hall’s DB6 Global OTC Database (MSP)
Key trends by region 2018
• Asia-Pacific’s OTC market grew by 4.6%, with a strong cold & flu season in leading market China (+5.8%) partially offset by a weak performance
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from key TCMs. Japan remained sluggish (+0.8%), while India (+9.3%) was the main growth driver among the core regional markets once again • N America increased by 2.7%, closely mirroring the result of the key US market (+2.6%), which was hindered by a weak allergy season (allergy remedies -1.2%) and a lack of switch • Europe advanced by 2.6%; W Europe continued to disappoint with a 1.6% increase, not helped by France remaining negative (-0.3%); CEE slowed to +5.2% following a lacklustre performance in key market and long-term growth driver, Russia (+1.7%) • The best growth once again came in LatAm (+9.5%), although price inflation played a significant role in a number of markets, not least regional No.1 Brazil (+10.1%) • Rest of World maintained its above-average performance (+7.2%)
Global: OTC sales & growth by region 2018
US$mn US$mn Growth Market Share % 2017 2018 2018/2017 GLOBAL TOTAL OTC SALES 130278.634 135436.415 4% 100 North America 35383.099 36334.142 2.7% 26.8 E & SE Asia 31233.943 32879.302 5.3% 24.3 Western Europe 24782.444 25176.814 1.6% 18.6 C & E Europe 10172.566 10701.212 5.2% 7.9 Rest of World 8305.457 8899.672 7.2% 6.6 Japan 7901.918 7967.131 0.8% 5.9 Latin America 6488.125 7102.22 9.5% 5.2 Indian Subcontinent 3306.029 3606.351 9.1% 2.7 Australasia 2705.054 2769.571 2.4% 2
Source: Nicholas Hall’s DB6 Global OTC Database (MSP)
Marketers: M&A to shake-up the rankings GSK retained the No.1 spot in the CHC leader board in 2018 and the company’s share is set to increase significantly once it assumes majority ownership of the j-v company incorporating Pfizer’s CH business. The all- equity agreement, announced in December 2018 and expected to complete in
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H2 2019, will see the new GSK Consumer Healthcare potentially generate around 7% of global OTC sales, although brand divestments may reduce this. GSK CH will be the No.1 marketer in all four major global DB6 regions (Asia, Europe, Americas and RoW), including all subregions with the exception of Japan and LatAm, and the No.1 player in four of the global Top 10 markets, including No.1 US (it will rank 2nd in global No.2 market, China). RB, which grew by 2.2% in 2018 (2.4% share), will take Pfizer’s place in the Top 5, followed by P&G, which now encompasses the CH business of German-based Merck following completion of that deal in December 2018 for around €3.4bn (US$3.8bn) cash, but excludes Teva sales from the dissolved PGT j-v (effective 1st July 2018). P&G was the only Top 10 player to post above-market growth in 2018, boosted by flagship cough & cold brand Vicks (+6.3%), which recorded especially strong results in its No.2 market India (+13.9%), No.3 Brazil (+16.5%) and No.5 Mexico (+12.6%). J&J leapfrogged Sanofi and Bayer into 2nd place, aided by continued growth from Tylenol (+6.3%) and the acquisition of natural products specialist Zarbee’s (announced in August 2018 for an undisclosed sum). Despite a sales increase of 3.1%, Sanofi lost share owing to the spin- off of its Zentiva European generics business (split out of our 2018 annual sales total for the company) to Advent International for €1.9bn (US$2.1bn), which completed in October 2018. Bayer was held back by poor performances in the US (-3.3%) and China (-9.3%); its operations in the latter market were hit by the reverse switch of Kang Wang antifungal and scalp treatments in September 2017, although the scalp product has now been reformulated and re-launched OTC and Bayer mentioned the brand as a contributing factor in strong A-P regional growth in Q3 2018.
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Asia-Pacific overview 2018 provided by Nicholas Hall Europe in July 2019
All quoted data is for full year 2018 at manufacturers’ selling price from Nicholas Hall’s DB6 Global OTC Database. Does not include e-commerce and mail order sales
Asia-Pacific is the world’s largest region for OTC sales and growth was modestly above the global average in 2018 (+4.6% vs +4.0%). Its performance is heavily dependent on China (+5.8%), where over 50% of regional sales are generated, while India was once again the most dynamic of the key markets (+9.3%). However, as in previous years sluggish growth in No.2 market Japan (+0.8%) and underwhelming results in Australia and S Korea (both below 3%) dampened the overall increase. While China continued to perform above average, growth was down vs 2017 (+6.2%), impacted mainly by a significant decline (-7.6%) in the US$1.5bn tonics & cure alls subcategory. Donkey hide gelatin brands, including the country’s No.1 OTC Dong-e E-Jiao (Dong-e E-Jiao / China Resources Pharmaceutical), have seen prices rise owing to a lack of raw materials (making them less affordable), while negative press reports over safety resulted in sales of No.3 tonic Hong Mao Medicated Wine (Neimenggu Hong Mao) falling by around 43%. Meanwhile, the reverse switch of compound ketoconazole in September 2017 also seriously impacted general antifungals (-13.5%) and scalp treatments (-12.9%), with overall derma revenue increasing by only 2.0%. Positive growth factors included a strong cold & flu season buoying No.2 major category CCA (+7.7%); marketer investment in TCM brands; development of paediatric / maternal healthcare products following the introduction of a two-child policy; and general recovery from the transition to China’s new two-invoice system. The declining trend among tonics & cure alls saw total VMS growth fall to 4.7% (vs +7.6% in 2017), while growth also slowed in No.2 and No.3 subcategories calcium (+5.9% vs +7.4%) and multivitamins (+2.4% vs +5.4%). Probiotics continued to star however (+19.4%) thanks to product launches
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(especially brands aimed at paediatric development). A flu outbreak early in the year boosted CCA, with systemic cold & flu growth rising to 8.8% (vs +2.4% in 2017), while cough remedies advanced by a similar margin. Sore throat remedies & medicated confectionery also enjoyed a turnaround in fortunes (+5.7% vs -0.2% in 2017), owing mainly to category leader Golden Throat (Guangxi Golden Throat) rebounding following completion of distribution restructuring in 2018. GIs recorded a healthy increase once again (+7.9%) and was China’s best-performing major category in 2018, driven by antidiarrhoeals (+18.4%), where marketers are investing in A+P and increased distribution to take advantage of higher demand resulting from rising incidence of irregular and unhealthy eating patterns. Liver & bile remedies also had a strong year (+17.4%) thanks to academic marketing and consumer education for key brands, while the switch to full OTC status of several key brands in early 2018 boosted antinauseants (+15.7%). Analgesics growth was in line with the previous few years (+7.1%), with both topicals and systemics largely matching this rate. Derma disappointed, although things are looking more positive for scalp treatments as Bayer reformulated and relaunched OTC Kang Wang in July 2018, and there were some strong results in other subcategories, including haemorrhoid preparations (+6.9%), antiseptics & disinfectants (+7.7%) and wound healers (+9.1%), while the more modest hair loss treatments enjoyed the best result (+19.1%) thanks to a rebound for category leader Bawang (Bawang) and A+P that aims to attract the younger generation.
Japan’s OTC market has been sluggish for many years, held back by issues such as health insurance coverage encouraging consumers to visit a doctor instead of buying OTCs. Largest category VMS, which generates almost 40% of total sales, declined slightly (-0.5%) as the leading tonic drinks subcategory (-1.6%) continued to face competition from other sectors (such as energy drinks). The crucial vitamin B segment also fell (-9.5%), following a decline at a similar rate for dominant brand, Alinamin (Takeda). Analgesics (+3.6%) performed best, benefiting from premium line extensions and the ageing population using pain-relieving OTCs to alleviate
29 aches & pains, with systemics especially dynamic (+6.0%). Future sales could benefit from the MHLW recommending the Rx-to-OTC switch of systemic naproxen in August 2018. CCA (+3.1%) also did well, especially allergy remedies (+9.6%). The subcategory was buoyed by a high incidence of seasonal allergies in 2018 and could be further boosted following the registration as Instruction-required Drugs in November 2018 of Rohto’s Alguard Clear Nose Seasonal Allergy and GSK’s Flunase Nasal Spray. The former launched in December 2018 and is the first flunisolide-based OTC allergy remedy in Japan. While derma growth of 1.4% appears low, this was actually the best result for the major category in several years, aided by a strong level of NPD. GIs (-1.6%) and lifestyle OTCs (+0.5%) could not emulate this level of improvement.
India remained the main regional growth driver, with major categories contributing towards the positive result. No.1 by sales revenue, VMS (+9.3%) was aided by growth of over 12% for leading subcategory iron, while chyawanprash (+8.0%) recovered from a flat result in 2017; Dabur’s dominant entry reaped the benefits of strategic pricing implemented to mitigate the threat from a lower-cost mid-tier product from Patanjali, as well as enhanced efforts to encourage wider use throughout the year (such as to reduce the effects of pollution). GIs (+10.8%) recovered from lower consumer spending power resulting from demonetisation in Q4 2016, particularly in largest subcategory antacids (+12.5%). Demand for antacids has been boosted by the growing incidence of dyspepsia, particularly in urban areas, which is linked to modern hectic lifestyles and diet. Growth in laxatives continued to improve (+12.1%), boosted by marketers’ efforts to reduce the taboo associated with constipation. CCA sales were up by 10.4% in 2018; air pollution has boosted demand in product categories such as sore throat remedies & medicated confectionery (+12.2%) owing to the increased incidence of respiratory ailments in recent years. No.1 subcategory cough remedies grew by 9.7%, driven by the strong performance of No.1 entry Phensedyl (Abbott). Several cough remedies have been affected by the decision to ban over 300 fixed dose combination
30 medicines in early 2016. The Delhi High Court quashed the order in December of that year but it was reinstated in September 2018, although some affected CCA brands such as Phensedyl and Piriton Expectorant (GSK) were granted exemption by the Supreme Court as they were being manufactured prior to 1988 (the government’s cut-off date beyond which FDCs were not being assessed). Meanwhile, in February 2019 the government rescinded a ban on the sale of FDCs formulated with paracetamol, caffeine, phenylephrine + chlorphenamine, with immediate effect. The formulation is used in systemic cold & flu remedies (+9.0%) such as Alex Cold (Glenmark), Zedex Cold (Wockhardt) and Hatric 3 (Aristo). An 8.1% increase for analgesics was driven by a 10.2% upturn for the larger topicals category, where faster-acting formats such as sprays and gels are becoming more popular owing to rising numbers of fitness-conscious consumers in urban areas looking for fast and convenient pain relief. There is also a burgeoning topical menstrual pain relief niche, with Redcliffe Hygiene launching Pee Safe Feminine Cramp Relief Roll On in November 2018 and Sanfe Period Pain Relief Roll on (Sanfe) launched in March 2019. The systemics category has struggled in recent years, however factors such as worsening dengue fever outbreaks helped sales to grow by 5.2% in 2018. Derma and lifestyle OTCs were the only major categories to record slower growth vs 2017, although both remained relatively buoyant (+8.4% and +6.2% respectively).
Although Australia’s growth remained well below average in 2018, the 2.4% advance was its best result for several years, as largest major category VMS recovered from a slight decline in 2017 with an increase of over 5%. A resurgence in daigou sales to China was an important factor. Probiotics was the best-performing subcategory (+18.8%), while vitamin C (+14.1%) and iron (+13.8%) also impressed. However, a sluggish result from CCA (+0.8%) and a decline for analgesics (-3.7%), which has struggled since the reverse-switch of codeine- based brands in February 2018, offset the overall result.
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S Korea performed slightly better than Australia. All major categories recorded growth of around 2-3% with the exception of lifestyle OTCs, which declined by almost 1%.
In Indonesia, growth improved slightly to 2.0% in 2018 vs 1.4% in 2017 but this is still below the regional average as Indonesia is recovering from recent economic challenges that have reduced consumer spending power. As such, all major categories grew by low single digits.
Asia-Pacific: OTC sales & growth by country 2018
US$mn US$mn Growth Market
2017 2018 18/17 Share % OTC Sales - Asia 45146.944 47222.355 4.6% 100 China 23777.243 25157.883 5.8% 53.3 Japan 7901.918 7967.131 0.8% 16.9 India 2985.453 3263.838 9.3% 6.9 Australia 2375.791 2432.596 2.4% 5.2 South Korea 2152.456 2210.471 2.7% 4.7 Indonesia 1487.94 1518.316 2.0% 3.2 Philippines 801.934 845.153 5.4% 1.8 Thailand 785.83 821.061 4.5% 1.7 Taiwan 674.532 701.526 4.0% 1.5 Hong Kong 541.973 569.152 5.0% 1.2 Vietnam 432.088 449.502 4.0% 1 Malaysia 350.038 366.597 4.7% 0.8 Pakistan 320.576 342.513 6.8% 0.7 New Zealand 329.263 336.975 2.3% 0.7 Singapore 229.909 239.639 4.2% 0.5
Source: Nicholas Hall’s DB6 Global OTC Database (MSP)
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Asia-Pacific: OTC sales & growth by major category 2018
US$mn US$mn Growth Market
2017 2018 18/17 Share % OTC Sales - Asia 45146.944 47222.355 4.6% 100 Vitamins, Minerals & 15532.85 16122.4 3.8% 34.1 Supplements Cough, Cold & Allergy 8564.576 9085.398 6.1% 19.2 Gastrointestinals 5822.552 6189.441 6.3% 13.1 Analgesics 5476.71 5769.722 5.4% 12.2 Dermatologicals 5551.948 5695.094 2.6% 12.1 Lifestyle OTCs 4198.307 4360.299 3.9% 9.2
Source: Nicholas Hall’s DB6 Global OTC Database (MSP)
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Annex 1: Dossier Requirements for OTC Registration
1 Country: Indonesia Country: Indonesia
X: Required, Y:Required depending on the drug, Blank: Not required. New Mono- New New New Chemical graph- Data Switch administra dosage combi- test/description Entity compatible, Category OTC tion route form nation (Direct generic OTC OTC OTC OTC) OTC Origin and XXXXX Background Use in foreign General/ XXXXX Background countries Comparison with XXXXXX other drugs
Chemical Structure Manu-facture and Physico-chemical X XX and Speci- properties fication Manufacture XXXXX Specification XXXXXX long-term X Y1 Y1 Y1 Y1 Y1 Stability stress X XXX accelerated XXXXXX efficacy X XXX Pharma- safety X XXX cology others X XXX Absorption XXXXX Distribution X Metabolism X ADME Excretion X Bioequivalence X Others X single-dose XYY Y repeated dose XYY Y genotoxicity X
Toxicity carcinogenicity X reproductive toxicity X local irritation XYY Y others XYY Clinical clinical X X1 X1 X1 X2 Labelling Package insert XXXXX
X1: more than 5 trial sites, more than 150 cases X2: more than 3 trial sites, more than 60 cases Y1: For drugs whose stability for 3 years cannot be estimated with the stress test, long-term stability test is required.
2 Country: Japan Country: Japan
X: Required, Y:Required depending on the drug, Blank: Not required. New New Mono- New Chemical administ New graph- Switch combi- Data Category test/description Entity ration dosage compatible, OTC nation (Direct route form OTC generic OTC OTC) OTC OTC Origin and XXXXX Background of drug Use in foreign General/Backgr XXXXX ound countries Comparison with XXXXXX other drugs Chemical Structure Manufacture and Physico- X and chemical properties Specification Manufacture X Specification XXXXXX long-term X Y1 Y1 Y1 Y1 Y1 Stability stress X accelerated X Y1 Y1 Y1 Y1 Y1 efficacy X Pharmacology safety X others X Absorption XYYYY Distribution X
ADME Metabolism X Excretion X Bioequivalence X Others X single-dose XYY Y repeated dose XYY Y genotoxicity X Toxicity carcinogenicity X reproductive toxicity X local irritation XYY Y others XYY Clinical clinical X X1 X1 X1 X2 Labelling Package insert XXXXX
X1: more than 5 trial sites, more than 150 cases X2: more than 3 trial sites, more than 60 cases Y1: For drugs whose stability for 3 years cannot be estimated with the stress test, long-term stability test is required.
3 Country: Korea Country: Korea
X: Required, Y:Required depending on the drug, Blank: Not required. New New Mono- New New Chemical administr graph- Switch dosage combi- Data Category test/description Entity ation compatible, OTC form nation (Direct route generic OTC OTC OTC) OTC OTC Origin and X XXXX Background of drug General/Backgr Use in foreign X XXXX ound countries Comparison with X XXXX other drugs Chemical Structure and Physico-chemical X YYY Manufacture properties and Specification Manufacture X XXX X
Specification X XXX
long-term X XXX Stability stress X accelerated X XXX efficacy Y Y Pharmacology safety Y others Absorption Y Y Distribution Y Y Metabolism Y Y ADME Excretion Y Y Bioequivalence Y Others single-dose Y Y Y
repeated dose Y Y Y
genotoxicity Y
Toxicity carcinogenicity Y reproductive toxicity Y Y local irritation Y others Y Y Y Clinical clinical Y XYX Labelling Package insert
4 Country: Philippines Country: Philippines 1
X: Required, Y:Required depending on the drug, Blank: Not required. New Chemical Entity (Direct Data Category test/description Switch OTC New administration route OTC OTC)
X X Origin and X classification of product from country Justification for the changes Background of drug of origin proposed
X General/Backgr X List of countries where product is ound Use in foreign approval letters from reference X marketed and corresponding countries regulatory authorities or the classification of the product, approval country of origin letters
Comparison with other drugs
X Chemical Structure unit dose formulation, tech specs X and Physico-chemical Manufacture raw materials, COA raw description, formulation properties and materials, analytical procedures Specification
Manufacture X Specification X long-term X Stability stress accelerated X efficacy X Pharmacology safety X others X Absorption X Distribution X Metabolism X
ADME Excretion X X Bioequivalence where applicable X Others dissolution profile single-dose X repeated dose X genotoxicity X Toxicity carcinogenicity X reproductive toxicity X local irritation X others X X X Part IV as per ACTD Clinical X Part IV as per ACTD Clinical Clinical clinical expert reports and/or clinical Part IV as per ACTD expert reports and/or clinical trial trial reports reports X X X Labelling Package insert including all other impacted including all other impacted labels including all other impacted labels labels (e.g. carton) (e.g. carton) (e.g. carton)
Other ADR report showing low occurrence of approved SmPC/PIL from country Requirements CPP drug interaction (clinically of origin or approved reference (PH specific) insignificant) regulatory agency
5 Country: Philippines Country: Philippines 2
X: Required, Y:Required depending on the drug, Blank: Not required.
New combi-nation Mono-graph-compatible, generic Data Category test/description New dosage form OTC OTC OTC Origin and Background of X X drug Justification as line extension
General/Background Use in foreign countries X
Comparison with other drugs
X X unit dose X Chemical Structure and unit dose formulation, tech specs raw formulation, tech unit dose formulation, tech specs Physico-chemical materials, COA raw materials, specs raw materials, raw materials, COA raw materials, Manufacture and properties Specification analytical procedures COA raw materials, analytical procedures analytical procedures
Manufacture X X X Specification X X X long-term X X X Stability stress accelerated X X X efficacy X Pharmacology safety X others X Absorption X Distribution X Metabolism X
ADME Excretion X X X X Bioequivalence where applicable where applicable where applicable X X X Others dissolution profile dissolution profile dissolution profile single-dose X repeated dose X genotoxicity X Toxicity carcinogenicity X reproductive toxicity X local irritation X others X
X Part IV as per ACTD Clinical clinical Clinical expert reports and/or clinical trial reports
X X X including all other Labelling Package insert including all other impacted labels including all other impacted labels impacted labels (e.g. (e.g. carton) (e.g. carton) carton)
Other Requirements CPP CPP CPP (PH specific)
6 Country: Taiwan
Country: Taiwan
X: Required, Y:Required depending on the drug, Blank: Not required.
New Mono- New New administr New graph- Data Chemical Switch combi- test/description ation dosage compatible, Category Entity OTC nation route form OTC generic (Direct OTC) OTC OTC OTC Origin and X XXXX Background of drug Use in foreign General/Back X XXXX ground countries Comparison with X XXXX X other drugs Chemical Structure and Physico-chemical X Manufacture properties and Specification Manufacture X XXXX X
Specification X XXXX X
long-term X XXXX X Stability stress Y YYYY Y accelerated X XXXX X
efficacy X XX X Pharmacology safety X XXYX others Y YY Y Absorption X X X Distribution X X X Metabolism X X X ADME Excretion X X X Bioequivalence Y Y2 Others Y1 Y1 Y1 single-dose X XYX repeated dose X YYY genotoxicity X Toxicity carcinogenicity X reproductive toxicity X Y Y local irritation X Y Y others X Y Y Clinical clinical X YX Y2 X Labelling Package insert X XXXX X
Y1: BA is required. Y2: Either BE or BA with Clinical is required.
7 Annex 2: Rx-to-OTC Switch Products in Member Countries
8 Country: China
Note: China had no OTC active ingredient monography, HA approved switch based on product case by case.
Ingredients & Dosages Transferred From Rx-to-OTC Status Authorized No. Product Name Ingredient Name Dosage Form Drug Efficacy Maximum Dose / Day Note Year 0.8g calculate as 1 Ibuprofen Arginine granule Ibuprofen Arginine Oral antipyretic/analgesia ibuprofen VitaminA 5000IU, VitaminD400IU, VitaminE 10mg, VitaminB1 5mg, VitaminA , VitaminD, VitaminE , VitaminB2 5mg, VitaminB6 VitaminB1, VitaminB2, 0.5mg, VitaminB12 1ug, VitaminB6, VitaminB12, iron, iron 10 mg, copper 1mg, Zinc Prevention and treatment copper, Zinc, magnesium, 0.5mg, magnesium 1mg, Vitamins and Mincrals of various diseases 2 nicotinamide, calcium Oral nicotinamide 15mg, calcium Dispersible Tablets caused by the lack of pantothenate, calcium pantothenate 5mg, calcium vitamins and minerals. hydrophosphate, L-Lysine, hydrophosphate 558mg, L- lipotropin , inositol, VitaminC, Lysine 25mg, lipotropin iodine, manganese, potassium 50mg, inositol 50mg, VitaminC 50mg, iodine 100ug, manganese 1mg, potassium 10mg
hydroxypropyl methylcellulose 1 2 drop per time,3 3 hydroxypropyl methylcellulose Eye drop eliminate Eye discomfort 8ml 24mg eye drop times per day 4 Bacillus subtilis capsule Bacillus subtilis Oral diarrhea relief 2.25g 5ml:2.5mg calculate as 1 2 drop per time, 4 5 Ketotifen Fumarate eye drop ketotifen fumarate Eye drop allergic conjunctivitis ketotifen times per day patch 15mg/16h nicotine Patch/ 6 nicotine Patch smoking deterent transdermal patch nicotine transdermal patch 21mg/24h Levocabastine Hydrochloride 400ug calculate as 7 Levocabastine Hydrochloride Nasal antiallergic Nasal Spray Levocabastine per nostril
8 caffeine cold/influenza 90mg 9 kalium sulfoguajacolicum; Oral cold/influenza 180mg Compound Paracetamol and 10 mephedrine Oral cold/influenza 28.8mg Sulfogaiacol Oral Solution 11 chlorpheniramine maleate Oral cold/influenza 7.2mg 12 acetaminophen Oral cold/influenza 720mg cold/influenza/anaphylacti 13 pseudoephedrine sulfate Oral 240mg c rhinitis Loratadine Paracetamol and cold/influenza/anaphylacti 14 Pseudoephedrine Sulphate acetaminophen Oral 2g c rhinitis 2011 Sustained -release Tablet cold/influenza/anaphylacti 15 loratadine Oral 10mg c rhinitis 16 dl-camphor Patch analgesic 28.4mg 17 Compound Methyl Salicylate Vitamin E Patch analgesic 48mg 18 and Menthol Patch l-menthol Patch analgesic 132mg 19 methyl salicylate Patch analgesic 144mg
20 Guaifenesin