31 August 2017

Government Registration Requirement for Medical Representatives in Shanghai

On August 22, 2017, the Shanghai Municipal Food and Drug Administration published the Draft Trial Measures for the Registration and Management of Medical Representatives in Shanghai (《上海市医药代表登记管理试行办法(征求意见稿)》) (the “Draft Measures”), soliciting public comments until September 30, 2017.

The Draft Measures require all medical representatives in Shanghai to be registered online with the Shanghai Medical Representative Registration System.

The Draft Measures further clarify that a medical representative will be deregistered if he or she (a) engages in commercial bribery, (b) violates rules regarding meeting with healthcare institutions, or (c) intentionally provides false registration information or fails to keep registration information updated. If a pharmaceutical company engages in the misconduct listed above or five or more of its employees were found to engage in such misconduct in a year, all medical representatives of that company shall be deregistered. Re-registration is not allowed within two years of such deregistration.  

The new Draft Measures directly link medical representatives’ misbehavior to their employers.  Pharmaceutical companies’ commercial interests can be negatively affected once their medical representatives’ misconduct reaches a certain level. 

David Shen +852 2974 6938 / +86 21 2036 7000
Head of the China IP Practice, Hong Kong / Shanghai david.shen@allenovery.com
Sen Liang +86 10 6535 4309
Associate, Beijing sen.liang@allenovery.com

This ePublication is for general guidance only and does not constitute definitive advice.

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