Journal of Traditional Chinese Medical Sciences (Apr 2020)
Integrating traditional Chinese (herbal) medicines into risk based regulation - With focus on non-clinical requirements to demonstrate safety
Abstract
Within the public health sector of Hong Kong (China), there is a consensus around the important role of traditional Chinese medicines. For Hong Kong (China) to play a bridging role to bring Chinese medicines to the global market requires a concerted effort from the government, academic institutes and industries. The release of the final version of the European Medicines Agencies guidance document, which details the acceptance of minimum requirements to nonclinical package in bibliographical applications, grants the opportunity for well-established and traditional herbal medicines to demonstrate an ‘acceptable safe’ status for registration in the European Union. It is anticipated that this minimum nonclinical package can be applied to demonstrate the safe use of many traditional Chinese medicines regardless of their eligibility to be registered under the simplified procedure within the European Union. This paper conceptualizes an integration of a simplified evaluation route for eligible proprietary Chinese medicines (pCm) with long history of use into the existing drug regulatory framework in Hong Kong (China). Such integration utilizing the minimum nonclinical package, based on bibliographical data or expert report, as proof of evidence to demonstrate safety for pCm with long history of use requires less demand in scientific resources. With Hong Kong (China) conducting ‘first hand’ review for eligible pCm, it provides an option for overseas and local pharmaceutical companies to register their products in Hong Kong (China) without the need to rely on issuance of Certificate of Pharmaceutical Product from other countries. This could bring eligible pCm with long history of use to reach international risk-based standard and to be marketed globally as ‘medicines’ to reach their full therapeutic potential. An important process to positioning Hong Kong (China) to compete with other countries in promoting importation and exportation of pCm to better serve the global health.
