Title
IRR of RA 8203 on Counterfeit Drugs
Law
Bfad
Decision Date
Nov 19, 1996
The Special Law on Counterfeit Drugs in the Philippines aims to protect public health by preventing the distribution and sale of counterfeit drugs, establishing procedures for monitoring and identifying counterfeit drugs, and imposing administrative sanctions and criminal charges for violations.
A

Interpretation and Definitions (Rule I)

  • Rules cited as "IRR of RA 8203."
  • Interpretation consistent with the intent of RA 8203 to protect health from counterfeit drugs.
  • Key definitions include:
    • Bureau or BFAD: Bureau of Food and Drugs.
    • Constructive knowledge: Awareness or reasonable suspicion regarding the counterfeit nature of drug products.
    • FDRO: Food and Drug Regulation Officer.
    • LICD: Legal, Information and Compliance Division of BFAD.
    • Life-saving drugs: Drugs indicated for life-threatening conditions.
    • LSD: Laboratory Services Division of BFAD.
    • PSD: Product Services Division of BFAD.
    • Unregistered imported drug product: Unregistered imported drug without a registered counterpart; if counterpart exists, considered counterfeit.

Prohibited Acts and Parties Liable (Rule II)

  • Prohibited acts mirror those under Section 4 of RA 8203.
  • Administrative sanctions apply for prohibited acts.
  • Parties liable under Section 5 of RA 8203 also liable under these rules.

Procedures for Monitoring and Identifying Counterfeit Drugs (Rule III)

  • FDROs conduct inspections without prior notice in factories, warehouses, establishments, or vehicles.
  • Inspection includes raw materials, finished products, containers, and labeling.
  • Suspected counterfeit stocks are inventoried, segregated, sealed, and samples collected for examination.
  • Owners must produce sales invoices or delivery documents from BFAD licensed establishments.
  • Samples submitted to LSD or PSD for examination to determine authenticity.
  • BFAD has 20 working days to complete examination.
  • Physical examination without lab testing allowed if product authenticity can be determined visually by PSD.
  • Certification from the registered brand-owner may be required and validated by PSD.
  • Positive counterfeit findings forwarded to LICD for investigation.
  • If not counterfeit, product release procedures involve notification and unsealing by FDRO.
  • Complaint desks accredited by BFAD may receive and refer complaints.
  • Trademark owners must report and surrender counterfeit drugs within 10 days of acquisition, or face legal presumptions.

Filing of Administrative Complaints (Rule IV)

  • Complaints may be filed with BFAD LICD or accredited complaint desks.
  • Registered brand owners must file affidavits detailing product information, respondents, violations, and relief sought, with product samples.
  • Consumers, physicians, or interested parties may file letters of complaint stating suspected product details and reasons for suspicion.
  • Affidavits required if sufficient evidence and direct accusation exist.

Administrative Proceedings (Rule V)

  • Initiated by FDROs submitting violation reports to LICD.
  • LICD prepares memorandum of evidence and gives respondents 15 days to respond.
  • Preventive closure orders for 30 days may accompany charges against establishments.
  • Summary hearings conducted if factual disputes arise; cross-examination permitted.
  • Administrative cases decided within 30 days after submission.
  • Decisions become final 15 days after receipt by parties.

Appeal Process (Rule VI)

  • No interlocutory motions for reconsideration allowed; one motion for reconsideration on final decisions permitted.
  • Grounds for appeal include abuse of discretion, lack of substantial evidence, and procedural irregularities.
  • Appeals filed within 15 days to the Secretary of Health.
  • Filing an appeal does not stay execution unless a bond of PHP 100,000 is posted.

Administrative Sanctions (Rule VII)

  • Minimum penalty: PHP 100,000 to PHP 500,000 fine.
  • Medium penalty: PHP 100,000 to PHP 300,000 fine, permanent closure of establishment, license revocation.
  • Maximum penalty: PHP 300,000 to PHP 500,000 fine, permanent closure, license revocation.
  • Accessory penalties include forfeiture, confiscation and destruction of counterfeit products and related equipment.
  • Permanent disqualification from operating businesses under BFAD supervision applies with maximum penalties.
  • Registered pharmacists with knowledge of violations face professional license cancellation proceedings.
  • Criminal charges possible when evidence shows probable cause, especially for life-saving drugs or large volumes.
  • Penalties graduated based on drug type (life-saving or not) and volume/value of counterfeit drugs.

Final Provisions (Rule VIII)

  • Separability clause preserving unaffected provisions if some parts are invalidated.
  • Sanctions apply prospectively; not retroactive before enactment.
  • Rules may be amended to improve enforcement.
  • Effective 30 days after publication in newspapers.

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