Vietnam’s pharmaceutical market has been experiencing rapid growth in recent years, attracting the attention of foreign drug companies eager to tap into this emerging market. However, navigating the regulatory landscape for clinical trials in Vietnam can be complex. This article aims to provide a comprehensive guide to clinical trial regulations for foreign drug companies in Vietnam, helping them understand the process and unlock opportunities in this promising market.

1. Introduction

At the end of 2023, the pharmaceutical market in Vietnam valued at $7.6 billion, and projections indicate it will reach $12.12 billion by 2029, growing at a compound annual growth rate of 7.96%. The aging population, increasing healthcare awareness, and government initiatives to improve healthcare access are driving this growth. For foreign drug companies, conducting clinical trials in Vietnam offers access to a large patient pool and potentially lower costs compared to developed markets.  For further information related to Vietnam’s pharmaceutical market, you can refer to this study on Globe News Wire. 

2. Regulatory Framework for Clinical Trials in Vietnam

The primary regulatory body overseeing clinical trials in Vietnam is the Ministry of Health (MOH). Key regulations include:

• Circular No. 29/2018/TT-BYT on clinical trials of drugs and medicinal ingredients
• Law on Pharmacy (2016)
• Decree No. 54/2017/ND-CP on the implementation of the Law on Pharmacy

These regulations align with international standards, including ICH-GCP guidelines, ensuring that clinical trials conducted in Vietnam meet global quality and ethical standards.

3. Clinical Trial Application Process

According to the Law on Pharmacy 2016 and its Circular No. 03/2012/TT-BYT, Foreign drug companies must follow these steps to conduct clinical trials in Vietnam:

1. Submit a clinical trial application to the Administration of Science, Technology and Training (ASTT) under the MOH (Article 10.1, 10.3 and 31.1 of Circular No. 03/2012/TT-BYT)
2. Obtain approval from the ethics committee of the proposed study site (Article 94.1.a of Law on Pharmacy 2016 and articles 10.8 and 17 of Circular No. 03/2012/TT-BYT)
3. Register the trial with the Vietnam Clinical Trials Registry (VNCT) (Article 95.2.a of Law on Pharmacy 2016 and Article 14 of Circular No. 03/2012/TT-BYT)
4. Obtain import licenses for study drugs and other necessary materials 

The entire process typically takes 3-6 months, depending on the complexity of the trial and the completeness of the application.

4. Ethical Considerations and GCP Compliance

Vietnam places a strong emphasis on maintaining ethical standards in clinical trials. Key requirements include:

1. Approval from a recognized ethics committee:

The ethics committee plays a critical role in ensuring that clinical trials comply with ethical principles governing medical and pharmaceutical research. Upon submission of the clinical trial application, the ethics committee evaluates the study to ensure that it aligns with these ethical principles and that the safety and welfare of participants are protected. The committee also assesses the risks, benefits, and overall scientific validity of the trial. (Article 3.2 and 10.8 of Circular No. 03/2012/TT-BYT)

2. Informed consent from all trial participants:

All participants must voluntarily agree to participate in the clinical trial, with no coercion. The consent is valid only after participants receive complete and accurate information about the trial, including its objectives and potential risks. This ensures that participants are fully informed and that their safety and welfare are prioritized. (Article 91.1.a of the Law on Pharmacy 2016, supported by Articles 12.1 and 29.1 of Circular No. 03/2012/TT-BYT)

3. Adherence to Good Clinical Practice (GCP) guidelines:

Clinical trials must adhere to Good Clinical Practice (GCP) guidelines, which are internationally and locally recognized standards for ensuring the ethical and scientific quality of research. These guidelines, endorsed by the Ministry of Health, aim to protect participant rights and safety while ensuring the credibility of the data collected during the trial. (Article 94.2.d of the Law on Pharmacy 2016, supported by Article 11 of Circular No. 03/2012/TT-BYT)

4. Regular monitoring and reporting of adverse events:

Given the risks posed to participants’ safety and well-being, clinical trials require close monitoring. It is mandatory to have systems in place to monitor and promptly report any adverse events or medical occurrences. This ensures that any risks to participants are addressed immediately and that the trial can be adjusted or terminated if the risks become unacceptable. (Article 95.2.c of the Law on Pharmacy, supported by Articles 23, 24, 27, and 33.3 of Circular No. 03/2012/TT-BYT)

Foreign pharmaceutical companies must ensure that their clinical trials meet these ethical standards to remain compliant with regulations and protect the rights and safety of participants.

5. Challenges and Opportunities for Foreign Drug Companies

Challenges:

• Language Barriers:
  Foreign companies often encounter difficulties with language in both documentation and communication. Many regulatory documents and communications with local authorities are conducted in Vietnamese, requiring translation and localization efforts to ensure accuracy and compliance.
• Limited Infrastructure:
  In some regions, healthcare infrastructure may be underdeveloped, which can impact the implementation of clinical trials. This includes a lack of modern facilities, equipment, or trained personnel in certain areas, which may slow down research activities.
• Variability in Healthcare Standards:
  The quality of healthcare services can vary significantly between facilities. Some hospitals or clinics may lack the resources or protocols necessary to maintain consistent standards, posing potential risks to trial integrity and patient safety.

Benefits:

1. Access to a Large, Treatment-Naive Patient Population:
   Vietnam’s population offers a significant pool of treatment-naive patients—individuals who have not previously participated in clinical trials or been exposed to advanced treatments. This diversity enhances the reliability of trial data and the potential for successful outcomes.
2. Lower Operational Costs:
   Conducting trials in Vietnam is generally more cost-effective than in developed markets. Lower labor costs, facility expenses, and other operational efficiencies make Vietnam an attractive option for pharmaceutical research.
3. Growing Network of Qualified Investigators and Research Sites:
   Vietnam is rapidly developing its clinical research capabilities, with an increasing number of qualified investigators and modernized research facilities. This growing network supports high-quality trial execution and fosters collaboration between international sponsors and local researchers.

6. Future Outlook and Trends

The outlook for clinical trials in Vietnam is highly optimistic, driven by several encouraging trends:

1. Enhanced government support for clinical research:
Vietnam’s government is increasingly prioritizing clinical research, introducing policies and incentives to streamline regulatory processes and foster collaboration between domestic and international stakeholders. This support is aimed at boosting the country’s reputation as a reliable hub for clinical trials.

2. Growing integration of digital health technologies:
The adoption of digital health tools, such as electronic data capture (EDC) systems, telemedicine, and wearable devices, is revolutionizing how clinical trials are conducted in Vietnam. These technologies improve trial efficiency, enhance data accuracy, and enable remote monitoring, making trials more accessible and effective.

3. Expansion of clinical trial infrastructure beyond major cities:
Traditionally, clinical trials in Vietnam were concentrated in major cities like Hanoi and Ho Chi Minh City. However, there is a growing effort to expand clinical research capabilities to other regions. This expansion provides access to a more diverse patient population, enabling more inclusive trials.

Vietnam is poised to become an increasingly attractive destination for clinical trials, offering a blend of government support, technological innovation, and improved infrastructure with these advancements. These factors position the country as a competitive player in the global clinical research landscape.

7. Conclusion

Understanding and navigating clinical trial regulations in Vietnam is crucial for foreign drug companies looking to tap into this growing market. While challenges exist, the opportunities for conducting high-quality, cost-effective clinical trials in Vietnam are significant. By staying informed about regulatory requirements, embracing ethical practices, and leveraging local partnerships, foreign drug companies can successfully conduct clinical trials in Vietnam, contributing to the advancement of medical research and improving healthcare outcomes for patients worldwide.

Harley Miller Law Firm “HMLF”

Address: 14th floor, HM Town Building, 412 Nguyen Thi Minh Khai, Ward 05, District 3, Ho Chi Minh City.

Phone: +84 937215585

Website: hmlf.vn

Email: miller@hmlf.vn