Title
Regulation of dextromethorphan cough syrup size
Law
Memorandum Circular No. 2 S. 1993
Decision Date
Feb 9, 1993
To combat the abuse of dextromethorphan-containing cough syrups, the Bureau of Food and Drugs mandates that only 30 mL, 60 mL, and 120 mL packaging is permitted, requiring manufacturers to withdraw larger sizes within 45 days or face confiscation.

Policy basis and regulatory purpose

  • BFAD bases the regulation on surveys by the National Drug Policy (NDP) Office and reports received by BFAD.
  • BFAD finds that certain dextromethorphan cough syrup products have been abused.
  • BFAD states that the abuse potential of dextromethorphan cough syrup preparations is under study.
  • BFAD limits registration and allowance of dextromethorphan cough syrup to specified pack sizes to prevent abuse.

Covered products and packing-size limits

  • BFAD registers and allows cough syrup preparations containing Dextromethorphan only in the packing/presentation sizes of 30 mL, 60 mL, and 120 mL.
  • Cough syrup preparations containing dextromethorphan in commercial presentations larger than 120 mL are not registered and/or allowed.
  • Cough syrup preparations in sizes more than 120 mL should not be found in any drug outlet.
  • The packing-size restriction applies to manufacturers and traders producing dextromethorphan-containing cough syrup.

Prohibited market presence and retrieval period

  • Manufacturers and traders producing dextromethorphan-containing cough syrup in packing larger than 120 mL must retrieve the same from the market.
  • The retrieval must be completed within 45 days from the date of the circular.
  • If retrieval is not completed within 45 days, the affected products become subject to confiscation.
  • The circular treats products in presentations more than 120 mL as unauthorized for distribution through drug outlets.

Monitoring, enforcement, and reporting

  • All Food and Drug Regulation Officers must closely monitor the dispensing of dextromethorphan subject products within their respective jurisdictions.
  • Food and Drug Regulation Officers must report any indication or evidence of abuse.
  • Monitoring and reporting are directed to support enforcement of the packing-size limitations.

Confiscation consequence for non-compliance

  • Products of dextromethorphan-containing cough syrup in packing larger than 120 mL that are not retrieved within 45 days are subject to confiscation.
  • The circular ties confiscation directly to failure to comply with the 45-day retrieval requirement.
  • Confiscation functions as the consequence for continued market presence of unauthorized larger-pack presentations.

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