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Product Regulation & Liability


In October 2023, the Health Sciences Authority (HSA) participated in a one-week INTERPOL-led, internet-based operation involving 89 member countries targeting the sale of illegal health products.
The HSA announced that it removed over 4,600 listings of illegal health products from local e-commerce and social media platforms and seized more than 60,000 units of illegal health products at the Singapore Customs during a week of intensified surveillance from 3 to 10 October 2023.

The United States Federal Trade Commission (FTC) has again shown that social media influencers, endorsements and testimonials remain an enforcement priority. The FTC sent warning letters to two trade associations and several dieticians and other online health influencers to make clear that failure to include clear disclosures that these are paid endorsements may violate the law.

On 6 November 2023, State Law No. 17,832 of 1 November 2023 was published in the Official Gazette of the State of Sao Paulo, creating the “Consolidation of the State’s Consumer Protection Laws,” which aims to unify the main laws that protect consumer rights in the state, bringing them together in a single document to facilitate legislative consultation.

Countries are approaching plastics regulation in different ways. Measures that have been proposed and adopted vary and include imposing plastic taxes, bans on single-use plastics, microbead bans, deposit return schemes, and consumer charges to discourage consumption (e.g., carrier bag charges). At an international level, in 2022, a UN resolution was endorsed to end plastic pollution and propose an international legally binding agreement by 2024.

In the first three parts of this series, we provided an overview of the new US Food and Drug Administration regulatory requirements under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA), the good manufacturing practices regulations FDA plans to establish, as well as the FDA draft guidance on the facility registrations and products listings. In this Part IV, we are providing an important update of FDA’s compliance policy – enforcement discretion for MoCRA facility registration and product listing until 1 July 2024, as well as the existing FDA resources to help industry prepare for MoCRA implementation.

The Ministry of Health has issued a note in which it promotes the use of QR codes to show the technical data sheet of medicinal products in promotional materials aimed at healthcare professionals. However, some information must remain in physical format to comply with the regulations on the advertising of medicinal products.

On 20 October 2023, the Cyber Security Agency of Singapore, in collaboration with the Ministry of Health, Health Sciences Authority and national health technology agency, Synapxe, launched the Cybersecurity Labelling Scheme for Medical Devices sandbox. Medical device manufacturers are invited to participate in the sandbox to gain a first-mover advantage in enhancing the security of their products.

On 29 September 2023, the Health Sciences Authority rolled out a one-year transition plan for companies to fully comply with the requirement for chemical drug substance manufacturers to provide Evidence of Good Manufacturing Practice Compliance. The HSA also provided clarity over the types of evidence that companies can submit as proof of GMP compliance.

On 3 July 2023, the UAE issued Cabinet Decision No. 66 of 2023 concerning the Executive Regulations of Federal Law No. 15 of 2020 on Consumer Protection. The most prominent changes in the Executive Regulations include the additional safeguards granted to customers and guidance on prohibited clauses and conditions to be included in contracts and Terms & Conditions with customers. With the widespread use of e-commerce globally, the Executive Regulations have also brought e-commerce providers under its remit and placed additional responsibilities on such providers.