Regulatory Affairs · Short notes

Import and Export Control: Short Notes & Cheat Sheet

Rules for importing finished drugs and raw materials, controlled substances, and the certificates used for exporting medicines.

Short notes

Read these before you attempt the topic's MCQs.

Import and export at a glance

Registered importsNormal route for finished drugsSpecial permissionNamed patient, trials, emergenciesRaw materialsImported against manufacturingneedsControlled drugsCNSA 1997 authorisation, INCBestimatesExport certificatesCoPP, free sale, GMP certificateTestingConsignments sampled beforereleaseCross-border control
Registration is the usual gateway; everything else is an exception needing special permission.

Imports

  • Imports are governed by the Drugs (Import and Export) Rules made under the Drugs Act 1976.
  • Normally only registered drugs may be imported for sale.
  • Unregistered drugs can be imported only with special DRAP permission, for example for personal use by a named patient, clinical trials, or urgent public-health needs.
  • Active ingredients and excipients for local manufacture are imported with DRAP permission against the licensed manufacturer's needs.
  • Imported consignments can be sampled and tested before release.

Controlled substances

  • Narcotic and psychotropic substances are also controlled by the Control of Narcotic Substances Act 1997.
  • They need separate import and export authorisations, within annual estimates reported to the International Narcotics Control Board (INCB).
  • Precursor chemicals (e.g. ephedrine and pseudoephedrine) are also tightly controlled, with quotas and records.

Exports

  • Pakistani manufacturers export to many countries, which usually require registration in the importing country.
  • DRAP issues a Certificate of Pharmaceutical Product (CoPP) under the WHO certification scheme, confirming the product's status and the site's GMP compliance.
  • Other export documents include a free sale certificate and a GMP certificate.
  • Exported products must meet both Pakistan's rules and the importing country's standards.

Cheat sheet

High-yield facts in one place. Cover the right-hand column and test yourself.

Documents

DocumentPurpose
CoPP (WHO scheme)Confirms product status and GMP of the maker
Free sale certificateProduct is legally sold in the home country
GMP certificateSite complies with GMP
Import permissionUnregistered drug for a special purpose
Narcotic import/export authorisationControlled substances within INCB estimates

Laws and bodies

ItemRole
Drugs (Import and Export) RulesFramework for drug imports and exports
Control of Narcotic Substances Act 1997Narcotics and psychotropics
INCBInternational estimates for controlled drugs
DRAPPermissions, CoPP, testing of imports

Memory aids

CoPP = Certificate of Pharmaceutical Product
The WHO-scheme certificate that importing countries ask for; DRAP issues it for Pakistani exports.

Exam traps

  • Importing an unregistered drug for sale is not allowed without special permission.
  • Narcotics need authorisation under the Control of Narcotic Substances Act, not just DRAP registration.
  • A CoPP is issued by the exporting country's regulator, not the importing country's.
  • Precursor chemicals such as pseudoephedrine are controlled even though they are not narcotics.

Revised? Now test yourself.

Attempt the Import and Export Control MCQs while the notes are fresh. Anything you get wrong is saved to your incorrect list for the next revision round.

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