Regulating Hyaluronic Acid: Medical vs. Health Use in Taiwan - Plastic Surgery

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How is hyaluronic acid classified as either medical use or health care use?


Hello, doctor.
I would like to inquire about how to differentiate between medical and health uses of hyaluronic acid under regulation.
There are many commercially available skincare products and oral mucopolysaccharide drinks that contain hyaluronic acid, which can be purchased without health insurance.
There are oral supplements, joint injection solutions, and postoperative anti-adhesion gels.
What standards are used to distinguish whether these are controlled substances? Are products like Restylane and research-based joint supplements and anti-adhesion gels available for the general public to purchase, or are they prescription medications and classified as controlled substances?

Chen Chen Chen, 20~29 year old female. Ask Date: 2021/06/20

Dr. Lu Daokuan reply Plastic Surgery


What you are actually asking about is the issue of drug certification.
Whether it is natural or synthetic hyaluronic acid, it can be ingested as long as it meets food safety regulations.
However, for medical use, it must comply with pharmaceutical standards, and to be injected into the body, it requires Class II medical device approval.
Yes, it should be regulated, and the Food and Drug Administration (FDA) will have specific guidelines for this.

Reply Date: 2021/06/20

More Info


In Taiwan, the regulation of hyaluronic acid (HA) is a nuanced topic that distinguishes between medical and health uses. Hyaluronic acid is a naturally occurring substance in the body, primarily found in connective tissues, skin, and synovial fluid. It has gained popularity in both medical and cosmetic applications, leading to a diverse range of products available on the market.

Regulatory Framework:
1. Medical Use vs. Health Use: The distinction between medical and health use of hyaluronic acid is primarily determined by its intended purpose and the claims made by the manufacturer. Medical products, such as injectable HA for joint pain relief or surgical applications, are classified as medical devices or pharmaceuticals and require approval from the Taiwan Food and Drug Administration (TFDA). These products must meet stringent safety and efficacy standards, and their use is typically overseen by healthcare professionals.

2. Health Products: On the other hand, products marketed as health supplements or cosmetics, such as oral HA supplements or topical creams, fall under different regulatory standards. These products are often subject to food safety regulations rather than pharmaceutical regulations, which means they can be sold without a prescription and do not require the same level of clinical evidence for safety and efficacy. As long as they comply with food safety standards, they can be marketed to consumers.

Classification Criteria: The classification of a product as a medical or health product depends on several factors:
- Intended Use: If the product is intended to treat, prevent, or diagnose a medical condition, it is likely classified as a medical product. For example, HA injections for osteoarthritis are considered medical use.

- Claims Made: The claims made by the manufacturer regarding the product's effects can also influence its classification. If a product claims to provide therapeutic benefits, it may be scrutinized more closely by regulatory authorities.

- Formulation and Delivery Method: Injectable forms of HA are generally classified as medical devices, while oral supplements or topical applications may be classified as health products.

Examples of Products:
- Injectable HA: Products like those used for joint injections or post-surgical adhesion prevention are typically classified as medical devices and require a prescription. They are regulated under stricter guidelines due to their invasive nature and potential risks.

- Oral Supplements: Products that contain hyaluronic acid marketed for skin hydration or joint health can be purchased over the counter without a prescription. These are generally considered dietary supplements and are not subject to the same rigorous testing as medical products.

Consumer Awareness: It is essential for consumers to be aware of these distinctions when purchasing products containing hyaluronic acid. While many health products are safe and effective, the lack of stringent regulation means that not all products are created equal. Consumers should look for products that have been tested for safety and efficacy, and ideally, consult with healthcare professionals before starting any new supplement, especially if they have underlying health conditions or are taking other medications.

In summary, the regulation of hyaluronic acid in Taiwan is governed by its intended use, claims made by manufacturers, and the formulation of the product. Medical products require more stringent oversight and are typically available only through healthcare providers, while health products can be purchased over the counter. Understanding these distinctions can help consumers make informed choices about the products they use.

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