The medicine regulator said it was planning to halt the sale of “Unlicensed Herbal Products”,or Chinese patent drugs, in Britain next year.
The plan will have a huge impact on the traditional Chinese medicine community in Britain.
Chinese medicine doctors called on the leaders of the TCM community in the UK to jointly petition the MHRA to drop the plan.
Do you think government may change their mind?
Hundreds of Chinese medicine clinics will out of business, more and more Chinese medicine practitioners will lose their live hood.
· Due to the delay of statutory regulation for herbal practitioners which denies our access to unlicensed herbal products under Article 5.1 of EU Directive, practitioners have no any other way to use unlicensed herbal products expect retail allowed by MHRA since.
· Economic downturn is not over yet. Many practitioners have suffered big business loss since 2008 and it is still ongoing. Early end of sell through will only make this situation worse.
· So far no any TCM products are THR registered, and all THR products are not for TCM use. The only way for TCM practitioners to use herbal medicine products is “sell through” allowed by MHRA until the end of their shelf life.
· End of “sell through” by 31/12/2013 will definitely stop a large portion of our practice, as the stock is the only source for TCM practitioners to use unlicensed herbal products.
· Early end of “sell through” will also cause immense waste of stock and financial loss, as most practitioners did their stockpile prior to April 2011 for up to 5 years, after MHRA gave a green light for the retail of unlicensed herbal products until their shelf life ends. Most practitioners still have a considerable amount of stock which cannot be sold through by the end of 2013.
· 5 year shelf life of TCM products were in place in 2010 when MHRA published its new guidance to allow retail until shelf life. Based on MHRA’s guidance of “retail until shelf life” in 2010, practitioners did stockpile at the time for up to 5 years. MHRA should keep the consistency of its policy and this 5 year period should stay or thousand pounds worth of stock will be wasted, which will cause a huge financial loss to practitioners.
· Early end of “sell through” will hit TCM practitioners particularly hard as we do not have THR products to use and we have stock for up to 5 years. This could cause issues related to equality such as Competition Assessment, Small Firms Impact Test, and Sustainable Development.
· Based on all above mentioned, especially MHRA guidance in 2010 to allow retail until self life, we suggest that the “sell through” of unlicensed herbal products” should be allow to continue until the end of 2015.
What's your opinion ?