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  • Main Subject - Documentation for Representative Offices in China

    An application letter signed by the foreign head office’s Chairman of the Board or General Manager requesting per
    According to USFDA, a combination product is one composed of any combination of a drug and device; biological product and device; drug and biological product
    mission to establish a Representative Office must be prepared and must include the proposed Representative Offic
    ; or drug, device, and biological product and fixed dose combination would include two or more combinations of drug.

    Examples of combination products may in
    ’s proposed name, purpose, scope of business, duration, and the term of office of the Chief Representative. It m
    lude drug-coated devices, drugs packaged with delivery devices in medical kits, and drugs and devices packaged separately but intended to be used together.

    ust also include the historical background of the head office, the names of the General Manager, the Chairman of
    here is enormous increase in the number of combination products entering the market in the recent years. Combination products have proven advantages but fixe
    the Board, and the other directors of the head office, the names of the head office’s primary trading partners i
    d dose combinations are still in the process of convincing regulatory authority on their advantages over the single ingredient formulations.

    Combination pro
    China, and its business volume.

    Supporting documents include (but are not necessarily limited to):

    A completed
    ucts have become life saving products for the pharmaceutical companies who doesn’t have many innovative molecules in their product pipeline and have been inc
    SAIC application form

    The foreign head office’s incorporation documents, including certified copies of the Cert
    easingly used in the product life cycle management. Even the companies having product patents are trying to extend their product life cycle through the combi
    ficate of Incorporation, business registration certificate, Articles of Incorporation (or equivalent), etc.

    An
    nation products and maximize the revenues. But the companies involved in this practice are overlooking that they are burdening the patients both economically
    original of a letter from the head office’s bank attesting to the head office’s financial standing (amount on dep
    and physically. They need to rightly judge the benefits of the combination products and they have to even look at the risks involved when combining the produ
    sit and other details pertinent to the company’s financial reputation)

    A letter appointing the Representative Of
    ts. Some of the combination products were well accepted by physicians while others suffered. Companies involved in development of combination products are fi
    ice’s Chief Representative and any other representatives, along with their resumes and copies of their IDs (pass
    ding difficulty in defining their combination products and facing various challenges from selecting a combination to marketing it.

    Following aspects would a
    ports for non-Chinese nationals) and photos

    Copies of the lease agreement for the Representative Office’s offic
    dd to the challenges in developing combination products:

    Which markets to tap where the combination products can do fairly well?
    Which combination prod
    premises from an approved unit (such as a commercial building or hotel)

    Permit use certificate (required in som
    cts are meaningful and rational?
    Which therapeutic categories to select?
    Which Combinations can address unmet needs of the patients?
    Do combin
    e jurisdictions), to be completed and signed by the landlord and tenant

    An “Approval Certificate for Premises to
    tions increase the patient compliance?
    What would be the developing cost?
    How to tackle the risks encountered during combination product developmen
    be Occupied by a Foreign Company” (required in some jurisdictions)

    Other possible documentary requirements inclu
    t?

    As combination products don't fit into the traditional categories of drugs, medical devices, or biological products, the USFDA is in the process of devel
    e:

    (1) Board resolutions authorizing the establishment of the Representative Office and appointing the Chief Rep
    ping new procedures for reviewing their safety, efficacy and quality.

    Professional from academic institutions, pharmaceutical industries, health care indust
    resentative;

    (2) Proof of more than US$10,000 in paid-in capital;

    (3) Certification in both English and Chinese
    y and representatives from various regulatory agencies are working out to design the regulatory requirements for manufacture and sale of combination products
    f the head office’s Articles of Incorporation (or equivalent), and tax registration certificate.

    All of the for
    .

    As there is an increasing trend of the combination products companies manufacturing such products should be able to tackle the problems involved in the de
    egoing documentation should be prepared in both Chinese and English. Please note that certain jurisdictions requ
    elopment. They need to be wiser in analyzing the market trends and the regulatory requirements.

    Companies that provide selfless information through particip
    re additional documentation and that industry-specific requirements apply in certain industries (such as finance)


    tion in industry events and feedback to regulatory authorities would be able to face the challenges and will be successful in developing combination products

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