In more detail

There are three forensic classifications for therapeutic products in Singapore, as follows, which determine the corresponding level of access controls for such products in Singapore:

• Prescription Only Medicines (POM): This refers to therapeutic products available only with a prescription from a doctor or dentist. The condition being treated must be diagnosed and managed by a doctor. Additionally, use of such therapeutic products can have significant side effects that necessitate a doctor’s supervision or follow-up.
• Pharmacy Only Medicines (P): This refers to therapeutic products that are available from pharmacists at retail pharmacies. They are suitable for self-limiting conditions and can be assessed and treated by pharmacists.
• General Sale List (GSL): This refers to therapeutic products that can be freely obtained from retailers. They are safe for public use without medical supervision and are only intended for short-term self-treatment.

For pharmacy only medicines, pharmacists are legally obliged to keep sufficient records when dispensing such products over the counter. Members of the public may be required to provide their name, identification number (e.g., NRIC/FIN No.) and contact details when purchasing pharmacy only medicines from their pharmacists. This ensures that there are adequate safeguards for proper use of therapeutic products.

The HSA recently reclassified a list of medicines based on the three levels of access controls set out above. The full list of reclassified medicines may be found here.

The reclassification exercise shows that the HSA is active across the therapeutic products available in the Singapore market, and it will not hesitate to take necessary steps to ensure that all therapeutic products in Singapore are compliant with applicable laws and fall under the appropriate classification. 

The HSA has broad powers to, on its own volition, recategorize or reclassify therapeutic products and cause such amendments to be made in its register. Before such recategorization or reclassification, the HSA must give written notice to the registrant of the therapeutic product. If the registrant agrees to the recategorization or reclassification of the therapeutic product, fails to show cause within the prescribed period, or fails to show sufficient cause as to why the therapeutic product should not be recategorized or reclassified, the HSA may proceed with the recategorization or reclassification.

Registrants who fail to take the steps specified by the HSA to secure the necessary changes to the presentation and advertisement of the therapeutic product so as to bring them in conformity with the new category or class may be liable on conviction to a fine of up to SGD 20,000 and/or imprisonment for up to 12 months. Registrants who do not wish to have their health product recategorized or reclassified may apply to the HSA to cancel the product registration.

* * * * *

© 2024 Baker & McKenzie.Wong & Leow. All rights reserved. Baker & McKenzie.Wong & Leow is incorporated with limited liability and is a member firm of Baker & McKenzie International, a global law firm with member law firms around the world. In accordance with the common terminology used in professional service organizations, reference to a "principal" means a person who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. This may qualify as "Attorney Advertising" requiring notice in some jurisdictions. Prior results do not guarantee a similar outcome.