You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

October 25, 2023

Healthcare in Cambodia: Crackdown on Illegal Advertising and Noncompliant Services

Subscribe to Updates

Cambodia’s Ministry of Health (MOH) continues to increase awareness among the public and private sector of the need for strict healthcare regulations and strict enforcement to advance the quality of the country’s healthcare sector.

In April 2023, the MOH issued a notification letter reminding advertisers of health products that they need to obtain a permit before advertising their products in Cambodia.

On October 12, 2023, the MOH issued two press releases on continued noncompliance in the healthcare sector. The two press releases address the illegal advertising of both healthcare products and private healthcare services. The releases also address unlicensed healthcare professionals and general noncompliance by private healthcare services.

These releases indicate that the MOH, in cooperation with local authorities, will substantially increase its enforcement efforts across Cambodia. Since October 12, several private healthcare clinics have had their operations closed and licenses suspended or revoked, signaling the ministry’s intent to enforce the legal framework.

Noncompliant Advertising of Health Products

The first press release focuses on the continued illegal advertising of health products and the advertising of unregistered health products. Health products include modern medicines, traditional medicines, health supplements, medical devices, cosmetics, and other products that prevent or treat diseases.

The release highlights that the MOH has noticed ongoing unauthorized and illegal advertising, commenting that these are often found online and on social media. The noncompliant advertising referenced in the release includes advertising of health products without the required advertising permit, advertising products that are not properly registered with the MOH, and advertising by unlicensed companies and individuals.

The MOH also states in the release that some advertisements are using inappropriate and noncompliant content that is not based on medical science and exaggerates the qualities of the health products—specifically mentioning skin-whitening cosmetics.

The ministry’s press release also informs the public of the dangers of noncompliant products and advertising, asking them to avoid purchasing these products. It reminds consumers to look for the MOH product registration or notification number, which registered products bear on their label. Further, it emphasizes that businesses and individuals advertising and trading health products must abide by the law.

Illegal Advertising of Healthcare Services and Noncompliant Healthcare Services

The second press release addresses noncompliant advertising of private healthcare services.

Private healthcare services include private hospitals, polyclinics, health clinics, dental clinics, and any other type of private healthcare service that requires a license from the MOH in order to operate legally.

The press release addresses illegal advertisements, such as those with content that is not approved by the MOH and the relevant professional council, or with content that is not supported in medical science, which is prohibited by each Code of Ethics that applies to professionals in the healthcare sector in Cambodia.

The second press release further addresses prohibited advertising of services by healthcare professionals who are not licensed by the MOH, do not meet the MOH’s education requirements, or are not registered with the relevant professional council.

The MOH also warns the public of the dangers of such noncompliant healthcare services and professionals and reminds the healthcare sector that it has a duty to comply with all laws and regulations.

The press release instructs local and provincial authorities to inspect all private healthcare services that fall under their purview and to act against services and professionals that do not comply with the law. It also instructs all professional councils to implement the laws and the relevant Code of Ethics, followed by instructions to strengthen their management of the healthcare professionals that fall under each council’s scope.

Concluding Remarks

The MOH’s two press releases are a reminder and warning to those active in the private healthcare sector, and to purchasers of healthcare products and services. The releases do not set out a new framework; they merely urge the healthcare sector to implement and follow the rules that have been in place for many years.

Strict enforcement of the existing legal framework will create a level playing field for businesses in the private healthcare sector and will eventually lead to better healthcare for the Cambodian people. Enforcement across the board is therefore warmly welcomed by the private sector.

Related Professionals

Industries

Life Sciences

Practices

Regulatory Affairs

Location

RELATED INSIGHTS​ 

September 9, 2026
On August 5, 2026, the Consumer Case Division of Thailand’s Civil Court rendered a judgment in a case involving a beauty clinic that advertised acne scar treatments using claims that the clinic was operated by a specialist physician and that the treatment, allegedly involving stem cell technology, could permanently remove acne scars. The plaintiff brought a claim against both the physician-owner and the clinic company, alleging that the advertisements were false and induced her to purchase the treatment. The court found that the clinic was liable for the false representations and that the physician-owner, as both the authorized director of the company and the medical practitioner who provided treatment, was jointly responsible. Although the plaintiff could not fully prove all damages claimed, the court awarded compensation of THB 20,000, together with interest. While the judgment arose from a consumer protection dispute, it serves as a valuable reminder that medical facility advertisements in Thailand are regulated and may expose clinics and healthcare providers not only to regulatory enforcement but also to civil liability from patients who rely on misleading promotional claims. Regulatory Framework Governing Medical Facility Advertisements Medical facility advertising in Thailand is governed by the Medical Facility Act B.E. 2541 (1998), as amended by the Medical Facility Act (No. 4) B.E. 2559 (2016). The principal secondary legislation is the Department of Health Service Support (DoHSS) Notification Re: Rules, Procedures, Conditions, and Fees for an Advertisement or Publication Concerning a Medical Facility, which came into force on November 25, 2019. Under this notification, “advertising” includes any act, by any means, that causes members of the public to see, hear, or otherwise become aware of a message, sound, or image for the commercial benefit of a medical facility. This broad definition covers not only traditional media but also clinic websites, social
Read More
September 9, 2026
On June 30, 2026, Indonesia’s National Agency of Drug and Food Control (BPOM) issued BPOM Regulation No. 11 of 2026 on Food Packaging, which expands the list of approved food-contact substances and recognizes a broader range of permissible functions for those substances. The new regulation, which revokes BPOM Regulation No. 20 of 2019, reflects developments in packaging technology and materials science. Although the new regulation provides more advantages to business actors by adding more food contact substances to the approved list for use in food packaging, there are more stringent rules and restrictions for testing. One of the most significant changes is a comprehensive migration-testing framework that sets out requirements for packaging materials, testing conditions, food simulants, and specific migration limits. Overall and Specific Migration Under BPOM Regulation No. 20 of 2019, migration requirements were primarily set out within the lists of approved food-contact substances and packaging materials. BPOM Regulation No. 11 of 2026 instead expressly requires packaging materials that come into direct contact with food to meet both overall and specific migration limits. These are defined as follows: Overall migration: The total quantity of all substances that migrate from the packaging, regardless of whether the substances are hazardous or nonhazardous to health. Specific migration: The quantity of a particular identified substance known to be hazardous to health that migrates from the packaging. Stricter Limits on Heavy Metals The overall migration limit for plastic packaging remains unchanged under both regulations at 60 mg/kg or 10 mg/dm². However, the new regulation introduces significant changes to the regulation of heavy metals. Under the 2019 regulation, four heavy metals—lead, cadmium, chromium VI, and mercury—were subject to a single combined limit of 1 mg/kg. The 2026 regulation, however, requires each heavy metal to meet its own individual specific migration limit, adds arsenic as
Read More
September 7, 2026
Indonesia’s Constitutional Court (Mahkamah Konstitusi) has reinstated a key provision limiting pharmaceutical patent protection, signaling a renewed commitment to balancing patent rights with public access to medicines. In its ruling to Case No. 255/PUU-XXIII/2025, the court partially granted a petition for judicial review of Law No. 65 of 2024, which had amended the country’s Patent Law, and ordered the restoration of a provision that had excluded certain pharmaceutical inventions from patentability. The decision took effect immediately upon its pronouncement at the court’s plenary session on August 28, 2026. Background The petition challenged the removal of article 4(f) from Law No. 13 of 2016 concerning Patents (Patent Law), as amended by Law No. 65 of 2024. Article 4(f) had excluded from patentability certain inventions relating to new uses of known substances. The petitioners argued that removing this provision would open the door to patent protection for second medical use inventions and facilitate patent evergreening—practices that can extend exclusivity periods, delay generic market entry, and reduce public access to affordable medicines. The petitioners included several patient advocacy and public-interest organizations: the Indonesian Dialysis Patients Community Association, the Indonesian Association of Drug Abuse Victims (PKNI), the Indonesian Pulmonary Hypertension Foundation (YHPI), the Rekat Peduli Indonesia Foundation, and the Indonesian Positive Women’s Association (IPPI), along with the Indonesia for Global Justice Association and four individual petitioners. The petitioners also challenged the constitutionality of the phrase “interested party” in article 70(1) of the Patent Law, arguing that it should be construed expressly to clarify who has standing to appeal a decision to grant a patent before the Board of Patent Appeal, and to allow a broader range of parties—such as patent holders, licensees, consumer organizations, prosecutors, aggrieved third parties, and others who may suffer direct or indirect harm from the grant of a patent—to
Read More
September 4, 2026
Blind boxes and collectibles have become increasingly popular, driven by the excitement of not knowing which character or design will be revealed until the package is opened. While most visible in the art toy market, the same concept is also used in the food industry. Confectionery, snacks, and other food products are sometimes sold with toys, character figures, cards, or other collectibles. A package might, for example, contain one of ten possible characters, with consumers knowing that an item is included but not which one they will receive. Some collections may also feature rare or “secret” items. For food businesses, however, adding a randomized toy or collectible involves more than a marketing decision. The food, the nonfood item, and the randomized mechanism may each raise different regulatory considerations in Thailand. Thai FDA Requirements for Nonfood Objects Packaged with Food The main food regulatory consideration is Ministry of Public Health Notification No. 310 B.E. 2551 (2008), which regulates food packaged together with things or objects that are not food. Under Notification No. 310, certain nonfood objects may be packaged together with food where they fall within specified exceptions, including objects that serve the following purposes: Maintaining the quality or standard of the food, such as a desiccant or oxygen absorber; Serving as a seasoning or as part of food preparation, such as chili powder sachets or seasoning sachets contained in instant noodle packages; or Functioning as an eating or food-preparation utensil, such as a spoon or fork included with instant noodles. Other nonfood objects that do not fall within these categories generally should not be placed inside the food container together with the food. Where a toy, collectible, or other nonfood object is intended to be sold together with a food product, businesses should therefore carefully consider the nature of
Read More