Regulatory overview of Chinese Proprietary Medicines
Understand the requirements to import, wholesale, manufacture or assemble Chinese Proprietary Medicines in Singapore.
What is a Chinese Proprietary Medicine
In Singapore, a Chinese Proprietary Medicine (CPM) refers to a medicinal product that:
Is in the form of a finished product, such as a capsule or tablet, and
Contains one or more active ingredients from any plant, animal or mineral, or any combination of sources. All of the active ingredients have to be documented for use in traditional Chinese medicine.
The following are not considered as CPM:
Products to be injected into the human body.
Products containing any chemically-defined isolated constituents as an active ingredient.
Food and supplements of food nature come under the purview of the Singapore Food Agency (SFA). View the interactive Food-Health Product Classification Tree for more information.
Is my product a complementary health product (CHP)?
Answer a few questions in our self-help tool to find out if your product is considered a complementary health product (e.g. Chinese Proprietary Medicine, Health Supplement, Traditional Medicine) in Singapore. You can also get a print-out of your product classification outcome from the tool.
Want to know more about CHP product classification? Click here for our FAQ.
Regulatory requirements of CPM
You will need to have a product listing approval and a dealer's licence to import, wholesale, manufacture or assemble CPM for sale and supply in Singapore.
If you are importing the CPM solely for export, product listing and dealer licences are not required, but you will need to apply for a permit for the import of CPM solely for re-export.
Click here for Guidelines on CPM Product Listing
Prohibited ingredients
CPM manufactured or imported and sold here cannot contain these substances:
Synthetic drugs.
Substances listed in the Poisons Act, except for the list of allowable naturally occurring substances within limits (see below).
Limits for naturally occurring substances
A CPM may contain the following naturally occurring substances within the stated acceptable limits and conditions.
List of substances and acceptable limits or conditions
Substances | Acceptable limits or conditions |
|---|---|
Aconite and its alkaloids | Dosing of no more than 60 mcg per day. |
Amygdalin | No limit. |
Berberine, its quaternary compounds and its salts | No limit. |
Boric acid, sodium borate | Not more than 5% boric acid or 5% sodium borate or 5% of a combination of both. |
Ephedra and its alkaloids | Less than 1%. |
Lobelia and its alkaloids | Less than 0.1%. |
Lovastatin | Less than 1%. |
Methoxsalen | No limit. |
Phenethylamine and it's salts | Not more than 300ppm. |
Tetrahydropalmatine | Dosing of no more than 19 mg per day. |
Labelling requirements
Full labelling in English is required for all CPM. Chinese or other languages, if any, may be used in addition to English. The information in languages other than Chinese and English, if applicable, should be the same as the English version of the approved labels.
Bilingual Reference List for Herbal Ingredients in CPM Preparations
A comprehensive bilingual reference list of common CPM ingredients has been developed to help applicants in their preparation of product labels, especially for single-ingredient CPM preparations.
The list includes standardised English and Chinese names, intended use, dosage and cautionary statements for each ingredient.
Inner label
The inner label must state:
Trade or brand name.
Product name.
Batch number.
Expiry date.
Names and quantities of ingredients.
If inner label is too small, the information may be stated on the outer label.
Outer label
The outer label must state:
Trade or brand name.
Product name.
Batch number.
Expiry date.
Importer's, wholesaler's, manufacturer's and assembler's (if any) name and address.
"Allowed for sale as a Chinese Proprietary Medicine based on information submitted to the Authority. Consumer discretion is advised. 根据向当局提呈的资料允许作为中成药销售。谨慎选用。".
The words must be clearly legible and printed in an indelible manner.
The English words should not be less than 1.5mm in height and the Chinese characters not less than 2mm in height.
The words must be enclosed in a boxed area and clearly visible. Nothing else should appear in this boxed area.
The label must appear conspicuously in a prominent position.
Note: If there is no outer label, the information above must be stated in the inner label.
Package insert
The package insert must state:
Trade or brand name
Product name.
Manufacturer's name and address.
Names and quantities of ingredients.
Dosage, indication, contraindication and side effects.
The frequency and method of administration.
Note: If there is no package insert, the information above must be stated either in the inner label or outer label.
Guidelines on Electronic Labelling (E-labelling)
E-labelling refers to product information which is distributed via electronic means, such as through a machine-readable code (e.g. QR code) or URL on the product packaging, linking to product information in digital format. Presently, e-labelling for CPM is applicable to the product leaflet only.
Dealers who are interested to use e-labelling for their CPM have to inform HSA. For more details, please refer to this guideline.
Prohibited diseases and conditions
You are not allowed to claim or indirectly suggest that the product will prevent, alleviate or cure any of the following 19 diseases and conditions:
Blindness
Cancer
Cataract
Drug addiction
Deafness
Diabetes
Epilepsy or fits
Hypertension
Insanity
Kidney diseases
Leprosy
Menstrual disorder
Paralysis
Tuberculosis
Sexual function
Infertility
Impotency
Frigidity
Conception and pregnancy
Toxic heavy metal limits
Your product must not exceed the following:
List of permissible heavy metal limits
Heavy metal | Permissible limits |
|---|---|
Arsenic | 5 parts per million (ppm) |
Cadmium | 0.3ppm |
Lead | 10ppm |
Mercury | 0.5ppm |
Dealers may wish to take note of the following suggestions in controlling the heavy metal contents of their products:
Identify starting materials (e.g. certain herbs, minerals) that may contribute to higher heavy metal content in their product;
Source for starting materials which have been tested to contain heavy metals below stipulated limits;
Ensure that herbal materials are free from soil particles before use (e.g. by washing thoroughly, if applicable); and
Incorporate relevant extraction processes in the manufacturing workflow to remove heavy metals in the product, if necessary.
Microbial limits
CPM must be tested to comply with the following microbial count:
Oral CPM
List of microbe and microbial limits
Microbe | Microbial limits |
|---|---|
Total aerobic microbial count | Not more than 105 CFU per g or ml |
Yeast and mould count | Not more than 5 x 102 CFU per g or ml |
Escherichia coli, Salmonellae and Staphylococcus aureus | Absent in 1g or ml |
Topical CPM
List of microbe and microbial limits
Microbe | Microbial limits |
|---|---|
Total aerobic microbial count | Not more than 104 CFU per g or ml |
Yeast and mould count | Not more than 5 x 102 CFU per g or ml |
Pseudomonas aeruginosa and Staphyloccocus aureus | Absent in 1g or ml |
Diethylene glycol and ethylene glycol limits
Oral liquid CHPs must not exceed the following:
Diethylene glycol and ethylene glycol limits
Substance | Quantity (by weight) |
|---|---|
Diethylene glycol | 1000 parts per million (ppm) |
Ethylene glycol | 1000 ppm |
Transmissible Spongiform Encephalopathy (TSE)
Animal derived ingredients
Transmissible spongiform encephalopathy (TSE) refers to a group of progressive diseases including scrapie in sheep and goats, chronic wasting disease in mule, deer and elk, bovine spongiform encephalopathy (BSE) in cattle, as well as Kuru and Creutzfeldt-Jakob Disease (CJD) in humans.
The infectious agents causing these diseases replicate and cause neurological disorders and eventual death in the infected individuals. There are currently no early diagnostic tests or known therapies for these diseases.
If your product contains animal derived ingredients, you must comply with our TSE guidelines to minimise the risk of TSE transmission.
Substances from endangered species
If your product contains substances from endangered species listed under the Endangered Species (Import & Export) Act, you should contact the Wildlife Management Group of NParks to obtain the necessary Convention on the International Trade in Endangered Species of Wild Fauna and Flora (CITES) import and export permits.
Advertisements and promotions
You will require a valid permit from us before publishing any medical advertisements or conducting any sales promotion activities directed to the general public.
Refer to our advertisements and promotions guidelines for more information on what is required before you run any advertisements and promotions for your products.
