What is a clinical trial
A clinical trial is a research study of a health product to investigate any of the following in humans:
- Discover or verify its clinical, pharmacological or pharmacodynamic effects
- Identify any adverse effect that may arise from its use
- Study its absorption, distribution, metabolism and excretion
- Ascertain its safety or efficacy
Regulation of clinical trials
All clinical trials of therapeutic products, Class 2 cell, tissue and gene therapy products (CTGTPs) and medicinal products (e.g. Chinese Proprietary Medicines, health supplements that are being investigated for the treatment or prevention of disease), are regulated by us except for observational clinical trials.
Medical device clinical trials, observational clinical trials and Class 1 CTGTP trials are required to comply with the requirements of the Human Biomedical Research Act, regulated under the Ministry of Health.
More information on medical device clinical trials could be found here.
Regardless of whether HSA regulates the clinical trial, the manufacture, import and supply of therapeutic products, CTGTPs, medicinal products or medical devices used as a clinical research material (CRM) in Singapore must comply with the regulatory controls for clinical research materials.
The table below summarises the key regulations and submission routes:
Refer to our guide on how to submit an application for CTA, CTN or CTC for more information.
To determine whether a clinical trial is regulated by us, please refer to our Guidance on Determination of Whether a Clinical Trial Requires CTA, CTN or CTC498 KB. If still unsure, the sponsor may send an enquiry to HSA_CT@hsa.gov.sg.
Regulation of Clinical Research Materials
What are clinical research materials
Clinical Research Materials (CRM) refer to any registered or unregistered therapeutic product, medicinal product, medical device, applicable cell, tissue and gene therapy product (CTGTP)* or placebo, that is manufactured, imported or supplied for the purpose of being used in clinical research, by way of administration to a trial participant in accordance with the research protocol or for a clinical purpose.
Regardless of whether we regulate the clinical trial, the manufacture, import and supply of CRM in Singapore must comply with the respective regulatory controls for CRM, which are described in the table below:
CRM notification
To facilitate access to CRM, dealers' licences for the manufacture, import and wholesale supply of CRM, and product registration for the supply of CRM are not required. This is provided a CRM notification is made before:
- Import of CRM for local clinical research use
- Supply by the local manufacturer of CRM for local clinical research use, including CRM compounded at the local trial site
You do not need a CRM notification for the following scenarios:
- Locally registered CRM obtained from local commercial sources
- Import of locally registered CRM for local clinical research use if the importer already has a valid importer’s licence for the import of CRM
- Supply of a locally registered CRM by its local manufacturer for local clinical research use if the manufacturer has a valid manufacturer's licence
- Supply of CRM by a local manufacturer if the manufacture of the CRM being supplied comprises solely of the packaging or labelling of the CRM
- Import of a minimally manipulated CTGTP CRM for local clinical research use by a known importer
- Supply of a minimally manipulated CTGTP CRM by its known manufacturer for local clinical research use
For products imported solely for export to overseas trial sites, CRM notification is not applicable. You would need to apply for an approval to import these products accordingly:
The table below summarises various routes for importing therapeutic products (TP), CTGTP and medical devices (MD) for local research use versus overseas research use.
For import of unused therapeutic products from overseas trial sites for local disposal, CRM notification is not applicable. You will need to apply for an importer's licence for therapeutic products for restricted activity, and comply with duties and obligations outlined in the Health Products (Therapeutic Products) Regulations (e.g., record-keeping and ensuring that the product is not supplied to the public). You may also wish to check with the National Environment Agency (NEA) for any other applicable requirements.
Additional requirements
If a CRM comprises any of the following substances, there will be additional requirements as indicated in the table below.
| Substances |
Additional requirements |
| Controlled drugs and psychotropic substances |
Licences for controlled drugs and psychotropic substances
Note: CTA/CTN/CTC and/or CRM notification acknowledgement (as applicable) should be provided in the application for the above licences.
Upon trial completion, any leftover CRM must be destroyed, and the procedure witnessed by a HSA inspector. If the CRM is to be exported, a corresponding export licence should be applied and issued before the export is made.
|
Poisons
|
Form A Poisons Licence
Note: CRMs which are therapeutic products are excluded from this requirement.
|
| Radiopharmaceuticals |
The import, export, possession, use, transport and disposal of radioactive material is regulated under the Radiation Protection Act by the National Environment Agency. |
In addition, import of telecommunication devices (e.g. tablets or mobile phones) into Singapore is regulated by the Infocomm Media Development Authority (IMDA). Importers will need to provide information regarding proposed use of devices via the TradeNet's online declaration form or email to IMDA. Please refer to our letter713 KB and IMDA's presentation slides619 KB for more details.
Dealer's duties and obligations
The CRM regulations are intended to ensure supply chain integrity, and prevent the inadvertent or deliberate release of unregistered CRM into the market for use other than in clinical research.
It is critical for all local manufacturers, importers and suppliers of CRM (including local sponsors and investigators) to maintain the integrity of the CRM supply chain through proper record keeping, labelling and disposal.
All local manufacturers, importers or suppliers of CRM must only supply the CRM for use in a clinical research, unless the CRM is locally registered and is manufactured, imported or supplied with a valid dealer's licence. The local sponsor of the clinical research must also ensure that the CRM is only used in a research study approved by an Institutional Review Board (IRB), and in accordance with the research protocol, and must ensure that any unused CRM is disposed or exported within 6 months of study conclusion.
If the local sponsor wishes instead to put such unused CRM to other uses after the clinical research is completed, the sponsor must obtain written permission from us via email to HSA_CT@hsa.gov.sg.
Refer to the following for more information:
Regulation of Active Ingredients Used in the Manufacture of Clinical Research Materials
The import and supply of active ingredients for use in the manufacture of clinical research materials (CRM) for use in local clinical research / clinical trial is regulated by us.
Under the Health Products (Active Ingredients) Regulations, dealer licences are not required for the manufacture, import and wholesale supply of active ingredients for use in the manufacture of CRM for use in local clinical research / clinical trial. This is provided an active ingredients notification is made to HSA prior to the import or supply of active ingredients, as summarised in the table below:
| Activity |
Who should submit active ingredients notification |
When active ingredients notification should be submitted |
Import of active ingredient(s)
- for the purpose of manufacturing (including compounding) a CRM in Singapore, and
- the CRM is intended for local clinical research / clinical trial use
|
Importer of the active ingredient(s) |
Before importing the active ingredient(s) |
Supply of active ingredient(s) by a local manufacturer of the active ingredient(s)
- for the purpose of manufacturing (including compounding) a CRM in Singapore, and
- the CRM is intended for local clinical research / clinical trial use
|
Local manufacturer of the active ingredient(s) |
Before supply of the active ingredient(s) by the local manufacture of the active ingredient(s) |
You do not need to make an active ingredients notification if you are an importer or manufacturer who already holds a valid licence that allows you to import or supply the active ingredients for use in the manufacture of a health product.
You do not need an active ingredients notification for the following scenarios:
- Import of active ingredient(s) for use in the manufacture of CRM for use in local clinical research / clinical trial, if the importer already has a valid importer's licence for active ingredients
- Import of active ingredient(s) by the local manufacturer of CRM for use in local clinical research / clinical trial, if the manufacturer has a valid manufacturing licence for the relevant health product
- Supply of active ingredient(s) by its local manufacturer for use in the manufacture of CRM for use in local clinical research / clinical trial, if the manufacturer has a valid manufacturing licence for the active ingredients
- The local manufacturer of the active ingredients is also the local manufacturer of the CRM, and the active ingredients is used for the manufacture of CRM for use in local clinical research / clinical trial
Click here to find out more information on the application process and documents required for active ingredients notification.