Advertisements and Promotions of Medicinal Products

Advertisement of medicinal products

You will require a valid permit from us before publishing any medical advertisements or conducting any sales promotion activities directed to the general public for the following types of medicinal products:

• Chinese Proprietary Medicines

• Traditional Medicines

• Homoeopathic Medicines

• Quasi-medicinal products, such as medicated soaps, medicated plasters, medicated beverages, medicated toothpastes, lozenges, and vitamin and mineral preparations

• Medicated oils and balms

• Medicinal products not subject to licensing requirements, such as topical antiseptics

The permit number must be included in the advertising and sales promotion materials.

The advertisement and sales promotion activity is published or conducted in accordance with the permit and no amendments should be made without prior approval by HSA.

Advertisements of traditional medicinal materials

You will require a valid permit from us before publishing any medical advertisements of traditional medicinal materials that contain medicinal claims and is directed to the general public.

• The permit number must be included in the advertising and sales promotion materials.

• The advertisement and sales promotion activity is published or conducted in accordance with the permit and no amendments should be made without prior approval by HSA.

Advertisements with no medicinal claims do not need prior permit approval. This is also applicable for advertisement solely to announce the sales promotion methods of traditional medicinal materials. (E.g. discounts). However, dealers must adhere to these requirements:

• General health claims, such as claims on health maintenance, must be based on traditional or long-standing use, as documented in traditional medicine literature.

• Only accurate and factual product information may be advertised. All claims must be substantiated.

• Do not:

  • Make comparative claims against another product or brand.

  • Use scientific language and data which the public may not understand or be able to verify.

  • Use exaggerated terms.

  • Suggest guaranteed results and no side effects.

  • Include any endorsement by healthcare professionals or public authority without their permission.

  • Use the names or logos of HSA and any of our professional groups.

Types of advertisements and sales promotion

The different categories of advertisements and sales promotions are listed below. Applicants should select the appropriate category when submitting their permit application. The examples provided are not exhaustive. 

1.      Advertisement using light and sound projection

• Examples: Television commercials, cinema advertisements, videos, videos on the Internet.

2.      Any other advertisement

• Using still media

  • Examples: Newspapers, magazines, brochures, posters, shelf wobblers, stickers, display stands, illuminated boxes, mail order announcements, calendars, static display on the Internet.

• Using sound only

  • Examples: Radio broadcasts, audio recordings, audio content.

3.      Sales promotion

• Examples: Activities intended to promote the sale or use of the product, such as price discounts or multiple pack offers, without any product claims. This includes both in-store promotional activities and sales promotion announcements communicated through any medium (still, sound, or light & sound).

Number and type of applications required

Note: For application of sales promotion permit, a copy of Sales Promotion Mechanics is to be submitted as an attachment in the application using the following format:

1. Name of product(s) (maximum 5).

2. Sales promotion activity (multiple activities may be submitted) - To provide details, e.g. price discount and its discount quantum.

3. Sales promotion announcement or messages - To provide details on how the above activities will be communicated, e.g. 'Special discount'. 

4. Promotion venue - Venue(s) where the above activities will be carried out, e.g. retail pharmacy, shopping centre.

An amendment is an application for a minor alteration made to an approved advertisement or sales promotion.

Minor alterations may include change of text, inclusion or omission of some words, and change in the visuals along the same concept of the approved advertisement or addition of sales promotion activities such as new banded offers.

If the alterations proposed are major, applicants would need to apply for a new permit instead. Application fees for amendment applications are not refundable.

Amendment applications are not required for changes which do not affect the product claims. For example:

• Re-arranging the text and visual.

• Updating the company's contact details, such as address and telephone numbers.

• Updating retailer's logo.

• Updating the product's usual selling price. 

A renewal application is for an advertisement which has a permit nearing its expiry date. A renewed permit is valid for one year from its previous expiry date.

A system generated renewal notification and reminder will be sent to you via the selected mode of contact indicated in your permit, 60 days and 45 days respectively, before the expiry date of the permit.

For GIRO linked companies, the permit will be automatically renewed unless you opt out from the renewal by the given date stated in the renewal notification. You must use the online ‘Auto Renewal Preference’ function to opt out of auto-renewal.

Note: If the opt out is successful, an acknowledgement statement will be displayed after clicking the "Save" button.

For non-GIRO linked companies, the permit will not be renewed unless you submit a renewal application before its expiry date. The permit will expire and become invalid if it is not renewed before its expiry date.

You will need to submit your permit application through the PRISM.

If this is the first time that you are applying for a license or permit with the HSA, you are required to submit a one-time CRIS registration via CRIS - ‘Client Registration and Identification Service’ function under e-Services on the HSA’s website (cris@hsa).

Please login the PRISM online system to submit your application. The modes of payment include GIRO and credit card.

Application Procedures for Advertisement and Sales Promotion Permits:

1. Go to PRISM under e-Services on HSA’s website.

2. Select 'PRISM (Medical advertisements and sales promotions)’.

3. Go to ‘Make an application – apply@prism’.

4. Click [View guide] to preview the online application form in plain text.

5. Click ‘Apply for Advertisements and Sales Promotion Permit’ to submit a new application.

6. Complete the form with the required information and submit.

7. Upon successful submission of an application, an acknowledgement with an application number will be generated. The application number is not a permit number. You may use the application number for enquiry before the approval of the application.

8. The processing time for each application is 14 working days, excluding time taken by applicant to make required changes.

9. If the application is approved, a permit number will be issued with an endorsed copy of the approved specimen, i.e. ‘MAHPxxxxxxx’ for approved advertisement, ‘MAHSxxxxxxx’ for approved sales promotion.

All medical advertisement and sales promotion permit applications will be evaluated upon submission for compliance to the requirements and appropriateness for advertising to the general public.

Q1: Do I need to apply for an advertisement and sales promotion permit?

A: First, determine whether your product is classified as a medicinal product, as medicinal products are subject to advertisement and sales promotion permit requirements. You may use the Self-help Classification Tool or submit a Health Product Enquiry Form which is available on HSA’s website, to determine your product’s classification and applicable regulatory controls.

You will require a valid permit from HSA before publishing any medical advertisements or conducting any sales promotion activities for medicinal products directed to the general public. Please refer to the section on ‘What are advertisements and sales promotions’ for more information.

Q2: How do I apply for an advertisement or a sales promotion permit?

A: Submit your application via PRISM (Medical advertisements and sales promotions). Refer to Advertisements and promotions of medicinal products on HSA's website for more information on advertising guidelines, permit requirements, application procedures and fees.

Q3: How do I check the status of my applications and permit details?

A: Check your application status via Track@PRISM and your permit details via Enquire@PRISM. You need to log in to view the information and must be authorised by your company’s CRIS administrator for the relevant access.

Q4: Can I transfer my company’s existing permits to another company?

A: Yes. Your company may submit a transfer application via Transfer@PRISM available on PRISM (Medical advertisements and sales promotions).

Transfer applications are chargeable. Please refer to 'Permit validity, fees and turnaround time' for the application fees.

Q5: Can I cancel my company’s existing permits that I do not need anymore? How do I cancel a permit?

A: Yes. You may cancel existing permits via Cancel@PRISM.

Please note there is no refund for cancelled permits.

Q6: Can I make changes to applicant’s details, such as name and contact details, for my company’s existing permits? How do I make these changes? What is the fee payable for such updates?

A: Yes. You may update applicant's details such as name and contact information for your company’s licences and applications via Amend@PRISM (‘Amend applicant's details for licences and applications’) and no fee required for this service.

Q7: Can I make minor changes to the content of my approved advertisements or sales promotion mechanics? Do I need prior approval?

A: Minor changes to approved content will require an amendment application. Refer to Advertisements and promotions of medicinal products for more information on requirements for amendment applications, including the application procedures and application fees. Submit your amendment application via Amend@PRISM (‘Amend medical advertisement and sales promotion permit’).

You do not require prior approval for minor changes to approved advertisements that do not affect product claims, such as:

• Re-arranging text and visuals.

• Updating the company's contact details, such as address and telephone numbers.

• Updating retailer logos.

• Updating the product's usual selling price.

The proposed advertisement and sales promotion materials should not:

• Make any false or misleading claims or representations.

• Make unsubstantiated claims.

• Make comparative claims against another product or brand.

• Use scientific language and data which the public may not understand or be able to verify.

• Use exaggerated terms.

• Contain any language or image that causes fear, alarm, distress to the public of any disease or condition.

• Encourage inappropriate or excessive use.

• Suggest guaranteed results without side effects.

• Encourage incorrect use or self-treatment of serious diseases or discourage from seeking a medical professional's advice.

• Include any endorsement by healthcare professionals or public authority.

• Make use of names, logos and trade service marks of other institutions, companies without their permissions.

• Use the names or logos of HSA and any of our professional groups.

• Offer refunds, in full or partial amounts, to users of the product.

In addition, sales promotion activities directed at the general public should not:

• Offer a medicinal product free of charge with the purchase of a non-medicinal product.

• Offer prizes through lucky draws or contests with the purchase of the medicinal product with terms such as "win a prize" or "get a lucky draw" or equivalent.

• Use terms such as "free", "complimentary", "get a gift" or equivalent.

• Distribute samples of Chinese Proprietary Medicines, Traditional medicines, and Homoeopathic Medicines.

You are not allowed to claim or indirectly suggest that the product will prevent, alleviate or cure any of the following diseases and conditions which are specified in the legislation:

1. Blindness

2. Cancer

3. Cataract

4. Drug addiction

5. Deafness

6. Diabetes

7. Epilepsy or fits

8. Hypertension

9. Insanity

10. Kidney diseases

11. Leprosy

12. Menstrual disorder

13. Paralysis

14. Tuberculosis

15. Sexual function

16. Infertility

17. Impotency

18. Frigidity

19. Conception and pregnancy

This prohibition does not apply to any advertisement or publication which is directed at:

• Practitioners.

• Pharmacists.

• Nurses and midwives.

• Persons undergoing training with a view to becoming practitioners, pharmacists, or nurses and midwives.

However, care must be taken to ensure that these advertisements are not distributed to the general public.

All medical advertisement and sales promotion permit applications will be evaluated upon submission for alignment with the requirements and appropriateness for advertising to the general public.

This section outlines the requirements and principles for medical advertisements and sales promotion activities directed to the general public. It serves as a guide to assist advertisers in preparing advertising and promotional materials.

False or Misleading Advertisements and Representations

You must ensure that all advertised information is accurate and truthful. Claims relating to a particular medicinal product must align with its approved uses or label recommendations, as well as any prevailing guidance for the category of medicinal product to which it belongs.

You must not make false or misleading advertisements or representations relating to medicinal products of any particular description to a practitioner, patient, or person for the purpose of inducing them to prescribe, supply, request, or purchase the product of that description.

An advertisement is considered false or misleading if it:

(a) falsely describes the description of medicinal products, or

(b) is likely to mislead as to the nature, quality, uses, or effects of medicinal products of that description.

Additional Guidelines for Medical Advertisements

(a) Truthfulness

 Advertisements must truthfully represent the nature, quality, and properties of the medicinal products. They must not directly or indirectly mislead readers or create unrealistic expectations regarding the products’ safety, quality, or properties by:

• implication

• selective emphasis

• omission of information

• ambiguity

• exaggeration (such as "the only", "longest lasting", "works the fastest")

• comparisons with other product categories

Recommendations for product use must be accurate and relevant to the product's properties.

(b) Substantiation of assertions of uniqueness and prominence

All advertised information must be substantiated. Any text, emphasis, certification, award, unique feature or prominence of the advertised product must be substantiated by facts or robust objective evidence from credible sources, such as peer-reviewed journal articles. It must be presented in a balanced, objective, and accurate manner with appropriate citations (where relevant).

Claims such as "most popular" or "number one sales" must be supported by market data from credible sources, for example, third-party research companies. Supporting data must be available and must be provided upon request. Advertisements containing such claims must indicate the reference source, the identity of the certifying or awarding body, and the study or award date.

Testimonials, including "user experiences" or "user reviews", must be current, genuine, authenticated (for example, through signed testimonials), and represent typical experiences that an average user would likely attain. Supporting evidence must be provided upon request.

(c) Comparative Claims

Advertisements must not denigrate any other products, services, or industry sectors. Advertisements must not contain comparative claims against named products or brands, for example, "works faster and better than Brand X". However, comparisons among products within the same brand by the same company to highlight differences between the products are permitted.

(d) Language

Advertisements should use simple, easily comprehensible language and avoid confusing medical jargon. Any scientific terminology used should be readily understood by the target audience. Scientific terminology and irrelevant information should not be used to make claims appear to have a scientific basis they do not possess.

Advertisements must not directly or indirectly cause fear, alarm, or distress to consumers or exploit their lack of knowledge through alarming words such as "danger", "caution", "beware", or disturbing images.

(e) Use of Scientific Data

Advertisements must not exploit general public ignorance or credulity by including scientific data that the public cannot verify.

Advertisements must also not misuse research results or make unnecessary quotations from technical and scientific publications.

(f) Superlatives and Exaggerated Terms

Advertisements should not use superlatives or exaggerated terms that imply properties the medicinal product does not possess. Examples of unacceptable terms include “most effective", "miracle", "100% safe", "instant cures", "clinically proven", "increase memory power", and "improve study grades".

(g) Encouraging Inappropriate or Excessive Use

Advertisements must not directly or indirectly encourage indiscriminate, unnecessary, or excessive use of medicinal products. Terms suggesting trial use, such as "try", "free", or "complimentary", are unacceptable. 

(h) Guaranteed Results and Side Effects

Advertisements must not suggest that medicinal products are magical, infallible, or that results are guaranteed or extraordinary. Since all medicinal products have the potential to cause side effects as individual responses may vary, claims suggesting products are free from side effects are unacceptable.

(i) Discourage from medical advice

Advertisements must not discourage seeking professional medical advice. They must also not directly or indirectly promote self-diagnosis or self-treatment of serious diseases. Additionally, they must not suggest that consumers do not need to consult a physician or pharmacist when using the product.

Serious diseases refer to chronic or life-threatening diseases or conditions, which cannot be self-diagnosed or managed and where a delay in treatment would lead to death, hospitalisation, serious injury or irreversible deterioration of the disease or condition.

Examples of serious diseases include cardiovascular disease, dengue, hepatitis, fatty liver disease and osteoporosis.

(j) Recommendations and Endorsements

All advertisements must ensure that they do not contain healthcare professional recommendations or create perceptions of professional endorsement, such as featuring models in white coats or with stethoscopes.

Advertisements of Chinese Proprietary Medicine and Traditional Medicine must not contain celebrity recommendations or endorsements or create the impression of celebrity advice or support. "Celebrity" encompasses personalities from all fields, including media, sports, politics, and culinary arts, whether or not identified in the advertisement. 

In this context, "recommendations" include, but are not limited to, testimonials, support, endorsements, compliments, accolades, or positive reviews.

(k) Government or Public Authority Endorsement

You must not publish any advertisements that falsely claim or suggest that the Government or any public authority promotes, supports, or endorses any product or its use.

(l) Logos, Initials, and Trademarks

Advertisements must not use names, initials, logos, or trademarks of other firms, companies, or institutions without written permission.

The names or logos of HSA and its professional groups must not be used in product advertisements and sales promotions in any media.

(m) Refund offers

Advertisements must not offer refunds, money-back guarantees, or any forms of monetary compensation, whether full or partial, to consumers.

(n) Guidelines for specific groups of products

In certain instances, additional requirements or advisories may apply to identified groups or types of products. Examples: