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Regulatory & Market Profile of Sri Lanka: Pharmaceuticals Export Promotion Council of India
Regulatory & Market Profile of Sri Lanka: Pharmaceuticals Export Promotion Council of India
3 Capital Colombo
65 years $ above:9.98%
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SRI LANKA- PHARMA MARKET REPORT
Introduction:
Though there is rising demand for Pharmaceuticals especially of chronic nature due, slow progress of
Govt health care programs and Local currency’s devaluation imports of Pharma is slightly behind the
demand supply ratio.
Pharmaceutical expenditure during 2017 is estimated at $ 642 million with a growth of 5%. This
expected to touch $664 Million with a growth of 3.3% in 2018.
Strengths
Robust pharmaceutical market growth.
Sri Lanka has a national health service, and consultation and treatment are provided free at all
public hospitals.
Government's commitment to improving access to healthcare.
Opportunities
Sri Lanka depends total on imports for their requirement of Bulk Drugs
Local industry is yet o catch up with the needs of the country
Latest updates
In October 2018, the Sri Lanka Chamber of Pharmaceutical Industry (SLCPI) said that despite
persistent appeals, the government has failed to address the urgent issue of a fair and proper
pricing mechanism for pharmaceutical products in light of the depreciating Sri Lankan rupee
against the US dollar.
In addition, SLCPI highlighted that eleven imported medicines are being or have already been
withdrawn from the Sri Lankan market due to the absence of a pricing formula and the drug price
ceilings introduced in 2016.
Industry Forecast:
Sri Lanka's pharmaceutical market likely to expand over the coming years. The country's growing and
ageing population will act as key drivers of market growth. Additionally, there is a latent and growing
demand for the treatment of chronic diseases, which will be supported by government efforts to upgrade
healthcare services. Government's pro-generic medicines policies, as well as low per-capita spending
on medicines, will be an added advantage to generic producers like India.
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In 2017, pharmaceutical expenditure in Sri Lanka (hospital and pharmacy medicine sales at consumer
prices) reached a value of USD642 mn, and this is estimated to touch $ 664 million in 2018.
By 2022, the market is expected to reach a value of USD787 mn, posting a five-year compound annual
growth rate (CAGR) of 4.1 % .
The decision by the health ministry, in July 2018, to reduce the price of nearly 25 medicines used to
treat diabetes, respiratory disorders and other chronic diseases will support the development of the
country's pharmaceutical and healthcare industry together with increasing the population's access to
affordable medicines.
Earlier, the Sri Lanka's health minister reduced the price of 48 essential drugs in 2016 providing greater
accessibility to the patients. Prices of 272 drugs from various brands were reduced. Most of the
medicines were for chronic illnesses that requires long-term treatment.
Around 85% of pharmaceutical products are imported and the exchange rate impacts significantly on
pricing. While capping prices has increased the affordability of certain drugs, the risk of making imports
unsustainable has become a major concern for the industry, in light of the depreciation of the Sri Lankan
rupee.
Market
A proper distinction between Prescription and over the counter products market is difficult to make due
to lax enforcement of Drug rules. Estimated Patented market is only 15-18% of the total $ 642 mn
market. The rest consists of generics and over the counter products.
The government in its 2014 budget announced incentives to promote local pharmaceutical industry
through an imposition of import duties on pharmaceutical products and making the import of certain
Ayurvedic medicines liable to VAT. However, at the same time, the government announced plans to
purchase medicines directly from the government of Bangladesh, excluding pharmaceutical companies
from mediation in these deals. This highlights the government's focus on the provision of affordable
generics.
The combination of drug price caps, import restriction of drugs that are produced locally and a
procurement system skewed towards local producers poses as a disincentives to our exporters. The
promotion of local drug production will continue to attract some level of interest by foreign investors,
given the market's long-term development potential. However, given the country's limited commercial
rewards, multinational firms have little incentive to invest and develop a large manufacturing presence
in Sri Lanka.
Ongoing improvements in healthcare access in Sri Lanka will be more beneficial to generic drug sales
than their patented peers. Section 38 of the National Medicine Drug, Devices & Cosmetic Authority Bill
passed in March 2015 necessitates that doctors prescribe medicines according to their international non-
proprietary name. Pharmacists are also required to inform patients if generic equivalents to a medicine
prescribed are available and to present the cost of each product to facilitate the patient's decision.
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Sri Lanka's regulatory environment will remain unfavourable for foreign pharmaceutical firms. While
the affordability of medicines was a key focus of the country's National Medicinal Drug, Devices and
Cosmetic Authority bill (passed in March 2015), it also has provisions that disadvantage companies
importing products into the country. Section 116 (2) of the national medicine policy states that the
Manufacturing Regional Division can advise the authorities to restrict the import of products which are
sufficiently supplied by local manufacturers. This has prompted the authorities to make ambitious plans
to leverage the bill to reduce the types of medicines imported into Sri Lanka from approximately 10,000
to 500.
Only 50% of a patients and 10% of hospitalized patients buy medicines out of their pocket expenses and
he rest is met from Public expenditure and/or insurance.
Pharmaceutical Trade:
Despite ongoing government efforts to boost local pharmaceutical manufacturing capacity, Experts
opine, Sri Lanka will continue to rely on imports to meet its domestic demand for medicines. Currently
90% of its Pharmaceutical needs are imported. In fact, the local drug industry remains underdeveloped
and pharmaceutical foreign investment in the country may remain subdued in the near term. Thus, Sri
Lanka is likely to observe an increase in drug imports over the next five years, especially to meet the
demand for more advanced treatments.
In 2017, pharmaceutical imports reached a value of USD445 mn, and this is expected to have touched
$ 460 mn in 2018. By 2022, pharmaceutical imports are expected to USD545mn observing a compound
annual growth rate of 4.1%.
Major sources of drug imports according to 2017 data include India (49% of total drug imports),
Pakistan (8%), the US (3%), Switzerland (3%), France (4%), the UK (3%), and Bangladesh (4%).
In June 2014, a subsidiary of India's Cipla acquired a 60% stake in a new company in Sri Lanka to
market Cipla's products locally. India is the largest importing partner of Sri Lanka with almost 50% of
its needs being met by imports from India.
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Statistics:
India’s exports to Sri Lanka:
2016- 2017-
Category 2015-16 17 18 GR% contbn%
BULK DRUGS AND DRUG
INTERMEDIATES 10.93 10.05 12.55 24.86 6.07
DRUG FORMULATIONS AND
BIOLOGICALS 180.78 187.19 179.36 -4.18 86.75
AYUSH 0.93 1.54 1.42 -7.59 0.69
Herbal Products 0.62 0.63 1.10 74.59 0.53
Surgicals 7.02 8.72 8.10 -7.06 3.92
Vaccines 4.72 9.12 4.23 -53.59 2.05
Total 205.02 217.24 206.76 -4.82 100.00
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REGISTRATION AND LICENSING REQUIREMENTS
Objectives
To ensure that all Pharmaceuticals available in Sri Lanka are of safe, efficacious and acceptable
quality
To ensure all Cosmetics available in Sri Lanka are of safe and acceptable quality
To ensure uninterrupted availability of Drugs, Cosmetics and Medicinal Devices
To ensure rational usage
Functions:
Regulation of Cosmetics, Medical Devices and Medicinal Drugs used in Sri Lanka through a
market authorization scheme and a post marketing surveillance system.
Inspection of manufacturing premises for compliance of Good Manufacturing Practices.
Inspection and licensing of retail and wholesale establishments of pharmaceuticals and vehicles
used to transport pharmaceuticals.
Monitoring of suspected adverse drug reactions.
Recalling of Cosmetics, Medical Devices and Medicinal Drugs from the market on safety
grounds.
Control of advertisement on medicinal drugs.
Control of Narcotics, Psychotropic substances, and Precursors used as medicines, industrial
chemicals or used for other scientific purposes.
Organogram:
According to the Act, Director General of Health Services (DGHS) is the Cosmetics, Devices and Drugs
Authority. For the purposes of implementation, the delegated Authority to the Director Medical
Technology & Supplies (D/MT&S).
DDG (LS)
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Director (Medical Technology & Supplies)
Pharmaceuticals &
Biologicals Unit Pharmacovigilance & Manufacturing & Enforcement
Compliance Division Quality Division Division
Medical Devices Unit
Pharmacovigilance Unit Company Profile Evaluation Unit
Cosmetics Unit
Controlled Substance Unit GMP Inspection Unit
Complementary
Medicines & devices Unit
Advertisements Unit Post marketing surveillance Unit
Director General of Health Services (DGHS): DGHS is the “Drug Authority” of the country
responsible for farming Drugs Therapeutic Committees. Functions of the committee would be to monitor
supply, distribution and consumption of drugs at national, provincial and institutional levels.
Director (Medical Technology & Supplies)- (D/MT&S): Issuing of certificate of registration of drugs
and licenses to import, distribute, sell and manufacture drugs under regulations of the Act, are
implemented by (D/MT&S).
Director (National Medicines Quality Assurance Laboratory- NMQAL): The primary function of
NMQAL is to conduct laboratory tests necessary for determining compliance with product safety and
quality requirements.
Medical Supplies Division: MSD of the Ministry of Health Nutrition and Indigenous medicine is
responsible for the consolidation of annual requirements of drugs for the institutions under the Central
Ministry and Provincial Councils.
State Pharmaceutical Corporation: Sole procurement agency for pharmaceutical and surgical
consumable items required by government health institutions.
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Drugs Registration Procedure
The manufacturer should submit registration applications to the Office of the Director of MT&S through
the local agent along with samples for quality testing. The Drug Evaluation Sub-Committee (DESC)
comprises specialists in medical and pharmaceutical fields and, with the administrative sector of the
Ministry of Health, makes recommendations on the registration of drugs. Quality, safety and efficacy
are the main criteria for registration.
The DESC makes use of the WHO's GMP certification scheme - regarding the quality of pharmaceutical
products moving in international commerce - when assessing GMP standards and the registration status
of a product in its country of manufacture. The Director of MT&S's approval (or rejection) of the
product's registration is based on the recommendations of the DESC.
Currently Sri Lanka does not inspect foreign manufacturing sites and evaluates them by their
international repute.
Sri Lanka uses several developed states - such as the US, Canada and the UK - as reference regulatory
authorities for its pharmaceutical matters, but not without consulting internal investigations.
Pricing structure is approximately 64% above the landing price. The breakup of 64% normally follows
the pattern as below.
Port Duty 4%
Importer Margin 25%
Whole saler 8-9%
Retailer 16.5%.
Since 2014 Sri Lanka requires BE data for antimicrobials, antiepileptic drugs and narrow therapeutic
index drugs as per a circular issued by the NMRA. However, NMRA, has not given a definition that it
uses for narrow therapeutic index drugs but the drugs that are generally considered to have a narrow
therapeutic index as given in standard text books are considered under this category during their
regulatory decisions on “case by case basis”.
Imported Drugs:
Approval of the manufacturer
The first step of registering drugs from a new manufacturer (whose drugs are not registered with the
DRA previously) is to submit the company information by the Authorized Local
Importer representing the manufacturer. If the company profile is found to be satisfactory, registration
applications will be accepted by CDDA.
Steps involved
Submission of information about the company
Receiving of company profile by a Pharmacist
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Assigning a serial number to the application.
Issuing of a letter to the applicant indicating the serial number.
Evaluation of company profile in the order of the serial number by a Pharmacist.
Check the evaluation report by Chief Pharmacist.
Submission of report to Director for a decision.
Communication of decision to applicant (Approval / rejection / require more information.
Registration of drugs
The authorized local importer representing the manufacturer of a respective drug has to submit an
application with drug samples to the Cosmetics Devices and Drugs Authority (CDDA) for the
registration of the drug. This application should be according to the format given in the Schedule IV,
Form A of CDD Regulations (Format is enclosed). A sample license should be obtained from the CDDA
in order to facilitate customs clearance when importing these into the country.
Once the registration dossier is handed over to the CDDA, it will be entered in a register allocating a
serial number to the application. An acknowledgement letter is issued to the importer with the serial
number which will be the reference number for the application. Importer should pay processing fee for
each application.
All applications (except new chemical entities) will have to go through the pharmaceutical evaluation
first.
New chemical entities first go to the Drug Evaluation Sub Committee (DESC) of the CDDA. Then the
dossiers subjected to a pharmacological evaluation. If the committee decides that it should be registered
in this country, then it is taken for thorough pharmaceutical evaluation.
Pharmaceutical quality of products is assessed through pharmaceutical data evaluated and information
on factors determining quality (starting materials/ formulation, manufacturing process, intermediate &
finished product controls, packaging, stability, bioequivalence data) are carefully considered.
If the pharmaceutical evaluation of the application is satisfactory, it will be submitted to the DESC. The
DESC comprises consultants from various specialties and a decision is taken at the DESC meeting
accordingly. If registration is recommended, DESC decides on the Schedule under which it should be
registered (i.e. I, IIA, 11B, or 111). The local agent will be informed of the decision (whether rejected
or approved).
If it is approved, the Certificate of Registration will be issued by the Director Medical Technology and
Supplies who is the Chairman of the DESC. Rejections will be informed giving reasons for the decision.
Registration is usually valid for 5 years. Under special circumstances (e.g. when the drug is a new
chemical entity, the manufacturer is new to this country) a provisional registration will be issued for one
year.
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Every importer should employ a registered pharmacist and should possess a whole sale license from
CDDRA in order to carry out the business. He should also get separate import license on annual basis
for each product from the CDDA
Steps involved
Import of registration samples
o Submission of application to import registration samples.
o Payment of sample import licence fee to the cashier of the Ministry of Health.
o Produce receipt at the CDDA.
o Issue the licence indicating the quantity permitted.
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Renewal:
The holder of certificate may make an application to the Authority, for renewal of such registration or
the licence six months prior to the date of expiry of such registration or the licence. After complete
evaluation of application and sample analysis, if requested may renew the registration or the licence
for a further period of not less than one year and not exceeding five years.
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Form A Regulation 5(3)
SCHEDULE IV
INFORMATION REQUIRED FOR REGISTRATION OF A DRUG.
1. Name of applicant...........................................
2. Address.....................................................
3. Status of applicant:
Manufacturer ………………..
Importer ..........................
If applicant is Importer, the name and address of the Manufacturer must be given.
4. Name of the drug..............................
(1) Brand name (if any):......................
(2) Official or approved name indicating the official body that has given the name
(whether B.P., U.S.P. etc.).
5. Dosage form of the drug. e.g. tablet, syrup, injection.
6. Composition.-
All ingredients, active and inactive, should be listed by their official or approved names and should
include their exact quantities as per unit dose or if it is not practical, as percentage of the total
formulation.
7. Main pharmacological group and ATC-class (if known) to which the drug belongs:
(e.g.diuretic etc. C 03 C A 01).
8. A certificate from the health authorities of the country in which it is produced, confirming that the
drug is in use there and the period of use and if not, reasons for not marketing it in the country of
origin (Free Sale Certificate, Certificate according to the W.H.O. Certification Scheme on
Pharmaceutical Products moving in International Commerce –the recommended format should be
used).
9. Published reports on controlled clinical trials.-establishing the therapeutic efficacy of the drug.
(Uncontrolled studies would be accepted only if controlled clinical trials are not necessary to prove
efficacy). In the case of combination drugs, evidence must be provided to justify the inclusion of all
the active constituents in the formulation.
10. Summary of toxicity tests and tests for teratogenicity indicating the safety of the drug.
11. Data sheet giving the following information:
A) Pharmacology
Pharmacological actions
Mechanism of action (if known)
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Relevant Pharmacokinetic data
Bioequivalence/Bioavailability data (when necessary)
B) Clinical Information
Indications
Contraindications
Precautions
Warnings
Adverse effects
Drug interactions
Dosage regimen
Average dose and dose range for adults and children
Dosing interval
Average duration of treatment
Dosage in special situations e.g. renal, hepatic and cardiac insufficiency
Over dosage:
Brief clinical description of symptoms
Treatment of over dosage
Post-marketing surveillance data for new drugs (new chemical entities)
C) Pharmaceutical Information
a. Dosage form and strength.
Separate applications have to be submitted for different strengths of the same product/dosage
form.
b. Description of the product.
Description of the physical characteristics of the product. This should include Where
applicable:- shape, size, superficial markings for identification purposes, colour, odour, taste,
consistency, type of tablet coating (e.g. sugar-coated, film-coated, enteric coated, delayed
release, etc.).
When describing liquids, state clearly whether it is in the form of a solution,
suspension, emulsion, etc.
c. Packing and Package sizes.
State here briefly the types of immediate container or packing and the pack sizes
e.g.
Tablets - bottles of 100's, 500's, blister pack - 50's etc.
d. Manufacturing formula.
Names, quantities and reference to quality standards of all ingredients including those which
will disappear during the manufacturing process (i.e. water, alcohol used for granulation etc.).
If the quality standard of an ingredient is not included in one of the official pharmacopoeias,
the manufacturers own specification and test method must be submitted.
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For injectable preparations total content in each unit container should be given.
Overage.
Where an overage is included, state name of the ingredient and amount. State also the reason
for including overage, i.e. whether overage is to cover loss of potency on storage, to permit
withdrawal and administration of labelled volumes, required doses, etc. supporting data for
inclusion of overage should be enclosed.
e. Manufacture of Product.
If desired, information required under this heading can be enclosed in a sealed envelope marked
"Confidential".
Complete Manufacturing Master Formula.
Give the actual batch manufacturing master formula with names and quantities of all ingredients
(active and inactive) Substances which are removed in the course of manufacture should be
included.
Manufacturing process.
A description of all stages involved in the manufacture of the dosage form is required,
eg. Manufacture of tablets:
Stage 1 : Mix ingredients
Stage 2 : Moist granulation
Stage 3 : Fluid bed drying at 60 C
Stage 4 : Rotary punching
In the full description of the manufacturing process (to be enclosed separately) there should be
sufficient details to cover the essential points of each stage of manufacture, such as steps in the
comminution of ingredients, method of mixing, order of incorporation of ingredients, fluid
media used in moist granulation, drying process, clarification process, formation of final
dosage form etc. including methodology, equipment, operating parameters (e.g. temperature,
pH adjustments, processing time, sterilization conditions) used in each stage of manufacture.
For sterile products, description should include preparation and sterilization of components
(i.e. containers, closures etc.).
Validation of important manufacturing operations.
Important production processes have to be validated and the relevant reports submitted.
Validation is defined as "the obtaining and documenting of evidence to demonstrate that a
method can be relied upon to produce the intended result within defined limits". Validation
should be able to prove that a process yields e.g. homogeneous tablets, capsules or
suppositories, or sterile drugs.
Packaging operations.
A description of the packaging of the product into the final containers (immediate and outer)
with information on any special precautions taken,
e.g.:
Stage 1 : bulk cream filled into 10 g jars by automatic dispensers.
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Stage 2 : automatic weight check
Stage 3 : automatic labelling
Stage 4 : manual transfer to cardboard boxes and sealed.
In details enclosed separately, describe the steps, equipment, flow and precautions for each of
the packaging operations.
f. Quality Control.
This section must give a complete account of the tests which will be carried out routinely on
each batch of product and its ingredients and must state the specifications with which any
sample (ingredient or finished product) would be expected to comply.)
Name(s) and address(es) of person(s)/organization(s) performing quality control tests, if not
done by the manufacturer's own quality control department must be given.
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Control of the finished product.
The quality specifications of the finished product must be submitted. These should include the
appropriate tests and requirements concerning the pharmaceutical properties of the dosage
form such as uniformity of mass, content uniformity, disintegration. In addition the following
tests should be considered: Particle size, dissolution rate, pH etc.
If bioavailability/bioequivalence studies for tablets and capsules are not performed, at least
dissolution tests must be performed on tablets/capsules contained in the USPXXII even though
the product is subject to a monograph which does not specify a dissolution test.
The specification should also cover:
- Identification of active ingredient(s)
- Quantitative determination of active ingredient(s) and preservatives.
- Tests for impurities
- Tests for degradation products
If a product is subject of a monograph in a current pharmacopoeia, it is expected to comply
with the specification for that product as well as the general requirements of the general
monograph for the dosage form.
Availability/Release rate of active ingredients (in-vitro tests):
Evidence of dissolution rates is particularly important for the following:
Where the drug is of sufficient potency and importance to warrant such investigation.
Where the therapeutic dose of the drug is close to its toxic dose.
Where solubility or other physicochemical properties of the drug indicate that any change in
formulation, or source of ingredient might alter the therapeutic efficacy or safety of the drug.
Where specific excipients, coating and other ingredients may affect or alter the dosage form
performance e.g. dissolution, disintegration, drug release rate, etc. special formulations e.g.
controlled release tablets, depot injections, etc.
g. Information concerning shelf-life, stability and storage conditions.
State proposed shelf-life of the product with recommended storage conditions (Temperature,
humidity, light, oxygen etc.)
The recommended storage conditions must be included on the label.
If the product is to be reconstituted before use, the shelf-life/expiry period of the original
product as well as the reconstituted product should be stated.
The manufacturer must provide evidence to the effect that the product retains acceptable
strength and pharmaceutical quality throughout its shelf-life.
Describe stability studies performed and completed on the product, outlining study protocols,
conditions and parameters, characteristics/degradation products monitored, results and
conclusion of studies.
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Results must be presented in an illustrative form, tables or graphs. Batch number, type of
container and storage conditions have to be stated in the reports.
The stability studies must be carried out on the product packed in the container in which it is
going to be marketed (sales container).
If the stability studies are carried out on product not packed in the sales container, evidence
must be given that the container used is equivalent to the sales container.
In view of the fact that sufficiently long experience of storage of new products has often not
been accumulated when an application is made, the results of accelerated tests may be accepted
for a preliminary shelf-life. Stability of the product must be followed up at suitable frequency
in relation to its shelf-life, on a suitable number of regularly produced batches.
The manufacturer must outline his programme for further stability studies (frequency, number
of batches, storage conditions etc.).
Analytical methods used in stability studies must be given, supplemented with documentation
of their ability to detect possible changes.
Changes in composition, the manufacturing process or the container or packaging material may
necessitate renewed stability studies and revised shelf-life.
h. Packaging materials.
The manufacturer should supply data on the material from which the container and the closure
are produced. For plastics, the name of the material, name of manufacturer, chemical structure
and physico-chemical properties must be submitted.
Detailed information is required about the technical construction of non-standardized
containers, e.g. aerosol containers, spray packs, syringes etc.
Quality specifications of the container and closure must be submitted.
12. List of countries in which the drug (the applicant's formulation/product) is approved or registered
for sale.
13. .Fully packed samples of the drug in the form that it will be offered for sale should also be sent, to
enable analysis of the product with Certificate of Analysis of the product.
14. A sample of the label(s) used on the container should be supplied.
15. Product information leaflet (PIL).
16. All data should be submitted in English, organized as this schedule IV, with an index in a hard file
cover. (A copy should be kept with the applicant.)
17. All pages should be numbered (starting from the last page).
18. A blank sheet should be pasted on the inner side cover to be used as a minutes sheet.
Format of Evaluation of Report by NMRA can be find at
http://nmra.gov.lk/images/stories/new/pdf/applications/new_evaluation_check_list.pdf
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Application Form for Licence to import drugs
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Registration and Licensing of Medicines (fees) Regulations
Republic of Sri Lanka revised the price structure of registration and licensing of medicines vide
Registration and Licensing of Medicines (fees) Regulations, No. 02 of 2017 and are effective from
14.06.2017.
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(iii) Fee for certificates:
Type of Registration Certificate Fee (USD)
Certificate of Registration for 5 years Foreign Manufacturer 400.00
Certificate of Registration for 5 years Local Manufacturer 200.00
Provisional Registration for 1 year for Foreign Manufacturer (will be 200.00
for a maximum of 2 years)
Provisional Registration for 1 year for Local Manufacturer(will be for a 100.00
maximum of 2 years)
Duplicate Copy of Registration Certificate 250.00
Amendment of Registration Certificate 100.00
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