Considerations on Relevant Technical Requirements for Listing Application of Over-the-counter Traditional Chinese Medicine / 中国实验方剂学杂志

ABSTRACT

In this paper， a comparative analysis is carried out on the policy of listed drugs in Australia， the policy of over-the-counter drugs in Japan， the policy related to the conversion of Chinese patent medicines to over-the-counter drugs， and the policy related to health food. The focus is on one of the possible situations for the registration of over-the-counter traditional Chinese medicines （TCMs）， namely new prescription-composed over-the-counter TCMs. This paper discussed separately from the three parts of the scope of Chinese medicinal materials in the prescription medicines， the scope of indications， and the technical requirements， in order to provide references for the technical requirements related to the registration of over-the-counter TCMs. Recommendations on the marketing and registration of new prescription-composed over-the-counter TCMs：①It is recommended to formulate a list of medicinal materials for the use of Chinese herbal medicines， and consider including raw materials of health food. On this basis， a batch of safe Chinese medicinal materials/decoction pieces was added. And consider dynamic supervision， such as allowing the addition or recall of Chinese medicinal materials/decoction pieces in the list of medicinal materials. ②The scope of indications is recommended to consider the scope of indications for the conversion of Chinese patent medicines to over-the-counter TCMs in China， and the selection of medium-risk indications can reflect the characteristics and advantages of TCM treatment. ③Efficacy evaluation needs to provide high-quality scientific evidence， including clinical research data， and consider relaxing the requirements for non-clinical pharmacodynamic trials.