The 21st Century ushered in a sea change for HK’s Chinese medicine (CM) industry’s business environment. The CM Ordinance is now fully implemented and the registration of pCM (proprietary Chinese Medicine中成藥) has also been instituted. The government is now promoting the improvement of CM manufcturing through a new set of guidelines and the founding of a new TCM hospital is now a certainty.
Meanwhile, the Mainland CM market has vastly expanded and its sophistication has improved to be practically at par with Hong Kong and Taiwan. This new situation is favorable for the merger of the 4 regions’ markets into a Greater China Region Chinese Medicine Common Market so that HK CM enterprises could tap into the gargantuan Mainland market, leading to a stronger and more modernized CM industry.
To prepare HK’s CM industry to meet these new changes and challenges, MCMIA recommends that the following steps should be taken jointly by the government and the industry:
1. Conducting a Comprehensive Survey on HK’s CM Industry, its Uses and Services
A full survey of for HK’s CM has never been conducted. Knowing the basic facts will enable the government to formulate more realistic policies for the HK’s CM industry and to rectify some of missteps in the past.
2. Forging a Greater China Region CM Common Market
As the 2nd largest economy, China will soon become the 2nd largest medico-pharmaceutical market in the world also. Meanwhile, the mainland is already the largest pCM market. The HK government should attempt to persuade the other 3 regions to jointly create a Greater China Region Chinese Medicine Common Market 大中華區中藥共同市場so that HK CM enterprises could tap into this market that is about 90 times HK’s own market. Such a prospect will help attract investments and talents to HK to make quality and efficacious CM products.
3. Reviewing and Reforming CM Ordinance and Regulations
After a dozen years’ implementation, a number of legal loopholes, inconsistencies with CM, incompatibilities with scientific principles and inhibitions of free trade were uncovered in the CM Ordinance and its associated regulations. It is time to review and reform some of these laws so that HK’s rule of law can be better applied to foster the prosperity of the CM industry. As a new CM hospital has been proposed, a new Chinese Medicine Hospital Ordinance should be enacted as the current hospital ordinances were mostly written for western hospitals.
4. Establishing a Hong Kong Chinese Medicine Development Commission
HK CM industry is transforming from a traditional industry to a modernized industry. A pan-department commission 中醫藥發展專署should be instituted to provide guidance for the development of the industry until the industry becomes robust enough to be sustainable.
5. Establishing a Hong Kong Chinese Medicine R&D Institute
The Jockey Club Institute of Chinese Medicine was abolished in 2011 under dubious circumstance. This left a huge “scientific void” in the CM industry when it needed scientific support the most to transform itself into a fully modernized evidence- and scientific-base industry. Hence it is imperative to establish a new CM R&D institute 香港中醫藥研究所to help get the industry back on a right track.
6. Creating a Chinese Medicine Research Fund
Current research funding is inadvertently and inevitably biased against CM research because the committees lack competency in CM knowledge. Hence, a new CM dedicated research fund 中醫藥研究基金 should be established to enable the proper academic and industrial research for CM.
7. Setting up New Practical GXP Guidelines for HK Chinese Medicine
“GXP” is an acronym representing a series of internationally accepted guidelines (Good Practices) for the R&D of pharmaceuticals such as GMP, GCP, GLP, GSP, GAP etc. with “M” standing for manufacturing, “C” for “clinical” etc. Currently the authority adopted the international GXP discriminately without due consideration for their compatibility with the Chinese medicine paradigm nor for the HK CM enterprises’ capability to conform. A new set of stepwise GXPs should be devised with the participation of the stakeholders to ensure their relevancy and the conformance of the industry.
8. Constructing a Science/Industry Park for Environmentally Clean Industries
A new “science and industry park” should be constructed by the government on behalf of HK’s emerging environmentally clean industries that include the western pharmaceutical and TCM industries. Lantau Island, being the most unpolluted land in HK, should be a suitable area to construct this park under the auspices of the HK Science and Technology Park Corporation. The Lantau location should also be ideal for the transportation of raw materials and finished CM goods by air, sea and by the new bridge for both domestic and international markets.
9. Implementing and Refining the HK CM Testing and Certification Scheme
The HK CM Testing and Certification Scheme 香港中藥材檢測認證計劃is scheduled to be launched this fall. The Scheme will enable HK to add values to TCM herbs, especially when it is linked up with the upstream herbal tracking, quality control, and digitalization systems, under development at the various TCM herbal market centers in the Mainland such as AnGuo安國, BoZhou亳州, Gilin吉林and Chengdu成都. Being the first version, the Scheme is not expected to be perfect. Its robustness should be strengthened as experiences are gained.
10. Expanding the HK Materia Medica Standards
The current HK Materia Medica Standards 香港中藥材標準are set up only for raw herbs 生草藥as used in the western pharmacognosy生草藥學 context. A new set of standards for processed herbs 中藥飲片needs to be set up for the CM industry’s use. As China is also investing tens of millions of RMB in the Chinese Pharmacopeia to set up similar standards, HK should join forces with Mainland, Macau and Taiwan to prepare common TCM herbal monographs for all 4 regions. This could become the first step to harmonize TCM standards and regulations for the Greater China Region, leading ultimately to the Greater China Region Chinese Medicine Common Market.