Title
Classification of Cough Syrups Regulations
Law
Bfad Memorandum Circular No. 7
Decision Date
May 23, 1990
The BFAD Memorandum Circular No. 7 classifies cough syrups based on their active ingredients, outlining prescription requirements and regulatory jurisdiction to ensure compliance with safety and efficacy standards.

Purpose and regulatory coverage

  • The circular provides a general classification of cough formulations by active ingredient category, prescription requirement, and the agency exercising jurisdiction over regulatory requirements.
  • The classification links each active ingredient category to the corresponding prescription form and licensing framework, and to the agency responsible for compliance.
  • The circular directs concerned entities to apply the classification to cough syrups by their active ingredients.
  • The circular requires compliance monitoring based on the attached active ingredient category, prescription, and agency jurisdiction.

General classification framework

  • The classification table lists Active Ingredient and assigns each to:
    • an Active Ingredient Category,
    • a Prescription requirement, and
    • the Agency with Requirements Jurisdiction.
  • The circular applies to cough formulations and regulates how they are classified and dispensed through the prescribed regulatory and prescription requirements.
  • The circular treats dangerous drugs differently from non-dangerous drugs by prescribing different prescription categories and different agency jurisdiction.

Prohibited drugs and yellow prescription

  • Hydrocodone or Dihydro-codeinone is categorized as Prohibited Drugs.
  • Hydrocodone or Dihydro-codeinone requires a Yellow Prescription (DDB Form 1-72).
  • Regulatory jurisdiction for Hydrocodone or Dihydro-codeinone rests with DDB.
  • Hydrocodone or Dihydro-codeinone is governed by dangerous-drug compliance coverage including registration, record-keeping, production, distribution, retail, import and export by DDB.

Regulated drugs and yellow prescription

  • Ephedrine & Pseudo-ephedrine is categorized as Regulated Drugs.
  • Ephedrine & Pseudo-ephedrine requires a Yellow Prescription (DDB Form 1-72).
  • Regulatory jurisdiction for Ephedrine & Pseudo-ephedrine rests with DDB.
  • DDB is in charge of compliance regulatory requirements covering registration, record-keeping, production, distribution, retail, import and export of dangerous drugs.

Exempt preparations and ordinary prescription with S-2

  • Codeine Exempt (BR No. 1, s. 1973) is categorized as Preparation.
  • Codeine Exempt (BR No. 1, s. 1973) requires Ordinary Prescription with S-2 license.
  • Regulatory jurisdiction for Codeine Exempt (BR No. 1, s. 1973) rests with DDB.
  • Ephedrine & Pseudo-ephedrine in combination with other ingredients is categorized as Exempt Preparation.
  • Ephedrine & Pseudo-ephedrine in combination with other ingredients requires Ordinary Prescription with S-2 license.
  • Regulatory jurisdiction for Ephedrine & Pseudo-ephedrine in combination with other ingredients rests with DDB.
  • DDB in charge of compliance regulatory requirements covers registration, record-keeping, production, distribution, retail, import and export for the dangerous-drug aspects identified in the classification.

Prescription and jurisdiction for BFAD-regulated drugs

  • Dextrome-torphan (single component) is categorized as Prescription Drug.
  • Dextrome-torphan (single component) requires an Ordinary Prescription.
  • Regulatory jurisdiction for Dextrome-torphan (single component) rests with BFAD.

OTC categories with no prescription

  • PhenyIpro-panotamine is categorized as OTC.
  • PhenyIpro-panotamine requires NONE as its prescription requirement.
  • Regulatory jurisdiction for PhenyIpro-panotamine rests with BFAD.
  • Mucolytic and Expectorant is categorized as OTC.
  • Mucolytic and Expectorant requires NONE as its prescription requirement.
  • Regulatory jurisdiction for Mucolytic and Expectorant rests with BFAD.
  • Antihistaminic is categorized as OTC.
  • Antihistaminic requires NONE as its prescription requirement.
  • Regulatory jurisdiction for Antihistaminic rests with BFAD.

Agency jurisdiction explained in the circular

  • DDB exercises requirements jurisdiction for cough formulations involving dangerous drugs, including registration, record-keeping, production, distribution, retail, import and export.
  • BFAD exercises requirements jurisdiction over registration, licensing, etc. focused on efficacy, purity and quality of both dangerous drugs and non-dangerous drugs.
  • The classification system assigns the administering compliance function between DDB (dangerous-drug operational/regulatory compliance) and BFAD (registration/licensing and product quality controls) based on the active ingredient category and prescription requirement.

Cross-referenced classification note

  • Codeine Exempt is linked to BR No. 1, s. 1973 for exemption treatment within the classification scheme.
  • Ephedrine & Pseudo-ephedrine in combination with other ingredients is treated as an Exempt Preparation under the classification scheme when combined with other ingredients.
  • The prescribed prescription and jurisdiction outcomes apply to the designated active ingredient entries in the classification table.

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