Review Article

Advancing the Regulation of Traditional and Complementary Medicine Products: A Comparison of Five Regulatory Systems on Traditional Medicines with a Long History of Use

Table 2

Comparison of the terminology and description of TM/CM products featured with a long history of use.

ChinaTaiwanHong KongJapanKorea

The general concept of TM/CM products
TerminologyaTraditional Chinese medicines (TCMs)Kampo medicinesTraditional Korean medicine
DescriptionaThe traditional medicine that originated in China and is characterized by holism and treatment based on pattern identification/syndrome differentiationSystem of herbal medicine practiced in Japan by both herbalists and practitioners of modern medicine. They are extracts or dry powders made from a mixture of naturally derived herbal medicines. They originated from ancient Chinese medicine and have evolved to the Japanese original style over a long period of timeMedical practice or discipline that is based on the knowledge, cultures, and beliefs of the people of Korea

The specific concept of TM/CM products with a long history of use
TerminologyClassic Chinese medicine formulationStandard formula of Chinese medicineEstablished medicineKampo medicineHerbal drug
古代經典名方中藥複方製劑基準方劑固有藥漢方製劑
DescriptionIt refers to the prescription recorded in the ancient Chinese medical book, which is still widely used, with definite curative effect and obvious characteristics and advantages [46]It refers to a formulation selected and published by drug regulatory authority that has unified specification and determination in the dosage form and formula contents [47]It refers to (1) an ancient prescription documented in Chinese medicine bibliography in, or before, the Qing dynasty; (2) a modified ancient prescription based on an ancient prescription with reasonable and rational modifications; (3) a pharmacopoeia prescription documented in the Pharmacopoeia of PRC; or (4) any other prescriptions originating from the National Drug Standards of the PRC and accepted by the Chinese Medicines Board [48]It refers to traditional Japanese herbal medicine used in Japan for more than 1500 years [49]. It includes ethical Kampo formulations and OTC Kampo formulations [50]. Ethical Kampo formulation is synonymous with Kampo formulation for prescription.It refers to plant-derived materials and preparations with therapeutic or other human health benefits, which contain either raw or processed ingredients from one or more plants, inorganic materials, or animal origin [51]
Regulatory agencyNational Medical Products Administration of ChinaThe Department of Chinese Medicine and Pharmacy, the Ministry of Health and Welfare(1) Registration authority: Chinese Medicine Council of Hong Kong, Chinese Medicine Division of the Department of Health
(2) Postmarketing: Drug office of the Department of Health
The Ministry of Health, Labour and Welfare; the Pharmaceuticals and Medical Devices AgencyMinistry of Food and Drug Safety of Korea
(1) Market authorization: Herbal Medicine Product Division, Biopharmaceuticals and Herbal Medicine Bureau
(2) Registration authority: Herbal Medicines Products Division, Biopharmaceuticals and Herbal Medicines Evaluation Department
LegislationLaw of the People's Republic of China on Traditional Chinese Medicine, 2016;
Pharmaceutical Administration Law, 2019;
Provisions for Drug Registration, 2020;
Administrative Regulations on Simplified Registration Evaluation and Approval of Classic Chinese medicine Formulation, 2018
Chinese Medicine and Pharmacy Development Act, 2019; Pharmaceutical Affairs Act, 2018;
Regulations for Registration of Medicinal Products, 2020;
the Regulation on the Preparations of Inherited Formulation and Over-the-Counter Drugs, 2018
The Chinese Medicine Ordinance (Cap. 549 of the Laws of Hong Kong), 1999Pharmaceutical Administration and Regulations in Japan, 2020; the Guidebook of the Approval Standards for OTC Kampo Products, 2017Pharmaceutical Affairs Act, 2016;
Regulation on Safety of Pharmaceuticals, 2018;
Regulation on Approval and Notification of Herbal (Crude) Medicinal Preparations, 2015

aThe terminology TM/CM was retrieved from the medical subject headings (MeSH) of PubMed.