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Simplified Registration Procedure

Simplified Registration ProcessTraditional herbal registration (THR)

The new scheme:
The Traditional Herbal Medicines Registration Scheme (THMRS) was introduced to protect public health. It demands much more information regarding safety, quality and efficacy than is currently required for unlicensed herbal products, thus bringing them more in line with any other licensed medicines.

 

Which products will need to meet the requirements and when?
Unlicensed manufactured herbal medicines that were placed on the market under section 12(2) of the Medicines Act before April 30th 2004 (when the new Directive came into force) will have until April 30th 2011 to meet the requirements of the scheme. Herbal medicines, placed on the market after April 30th 2004 do not qualify for the transitional protection phase and will need to meet the requirements of the THR scheme or apply for a Market Authorisation (MA).

 

Eligibility
You will only be able to register your product using the THR scheme if it is intended and designed for use without the supervision of a medical practitioner for diagnostic purposes or for prescription or monitoring of treatment. In addition, the product must be an oral, external and/ or inhalation preparation.

 

The data requirements can be summarised as:

 

• Bibliographic or expert evidence demonstrating 'traditional use'.

• Authoritative literature on herbalism.

• Testimony of recognised experts on herbalism.


What are the requirements?
The normal requirement to produce data to prove efficacy is replaced by a requirement to demonstrate 30 years traditional use for the required medicinal indication. Normally, at least 15 years of this usage must have been within the EU.

 

Safety requirements
In addition to the above, you will also need to provide a bibliographic review of safety data together with an expert report. An important aspect of safety is that the products, including their indications, must be suitable for over the counter sale and use without medical supervision.

Quality requirements
The normal quality requirements applicable to licensed medicines will apply. Compliance with Good Manufacturing Practice (GMP) will be required. There will also be a requirement to hold a manufacturer's licence, a wholesale dealer's licence or a wholesale dealer's (import) licence where appropriate.

 


Do not leave the accumulation of these data until the last minute. The application process itself is a time consuming process, taking 210 days as a minimum.


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