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Giuliana Miglierini

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Joint open letter of industrial associations on early mandatory availability of the EUDAMED database 

Several industrial associations, among which AESGP for the self-care industry and MedTech Europe for medical technologies, answered with a joint open letter to the call for early mandatory availability of the European Medical Devices Database (EUDAMED) made at the Employment, Social Policy, Health and Consumer Affairs Council meeting of 30 November 2023. The six associations highlight some preconditions which should be considered before any modules of EUDAMED would be made mandatory.

All the modules of the new database should be fully developed, tested, audited and ready for practical implementation, including the post-market surveillance and vigilance module and the public website. The database should enable the most efficient use of notified body and manufacturer resources. To this instance, the availability of a machine-to-machine communication functionality for the notified bodies and certificates module is expected, as well as the functionality for manufacturers to upload (non-validated and translated versions of) Summary of Safety and (Clinical) Performance reports.

The industry associations suggest a reasonable implementation timeline of at least 24 months from communication to starting mandatory use of any modules, in order to align procedures and build up resources, tools and infrastructure. Redundancy in national databases should be also eliminated.

Source: AESGP

How to boost R&I and attract more talents

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The political agreement reached on 8 December 2023 by the European Council on the final text of the Recommendation on a European framework to attract and retain research, innovation and entrepreneurial talents in Europe updates the 2011 R1-R4 profiles for researchers, and introduces the European Charter for Researchers, a revision of the 2005 European Charter for Researchers and the Code of Conduct for the Recruitment of Researchers.

The agreement is part of the actions to strengthen the European Research Area (ERA). The new provisions are focused on young and early-career researchers, to facilitate employability and careers and to attract more students and graduates to careers in research. Europe’s attractiveness for talents from around the world is also considered. The new framework will support the goals of the Commission Communication on a New European Innovation Agenda. The launch of several new instruments is also planned, including an ERA Talent Platform, an observatory on research and innovation careers, and a pension solution for mobile researchers.

MedTech Europe comments the political agreement on the PLD directive

After the political agreement on the revision of the Product Liability Directive (PLD), reached on 14 December 2023 by the European Council and Parliament, new concerns were expressed by MedTech Europe on behalf of the European medical technology sector. According to a note published on its website, the overall impact of the revised PLD on companies and consumers, and on the medical technology sector, would have not been properly considered.

According to MedTech Europe, the revised PLD resulting from negotiations would lack meaningful safeguards to ensure that a reversal of the burden of proof is only applied when very specific conditions are met. This could present issues for companies, as the newly introduced presumptions may lead to an increased volume of legal claims resulting in higher insurance costs, dampening innovation, and putting at risk smaller companies. The current wording would also not ensure the right to a fair trial for both sides. MedTech Europe identifies Recital 34 of the agreed text as particular critical and suggests co-legislators should consider the European Parliament’s position in the final text in order to ensure that innovative medical technology’s complexity is assessed fairly.

EMA’s 2022 annual report on medicines for children

As for scientific advice (SA) activities and protocol assistance (PA), in 2022 the European Medicines Agency provided 146 SA/PA on paediatric-only and combined adult and paediatric medicines development. The data are in line with those observed since 2016, with some decrement with respect to 2021 (220). The number of SA/PA without paediatric aspects remained almost stable (687 in 2022, vs 602 in 2020 and 632 in 2021). 

EMA’s 2022 annual report to the European Commission was elaborated on the basis of data made available from 26 national patent offices, and referred to the six-months extension of the  supplementary protection certificates (SPC) granted for paediatric development. In 2022, 44 active substances including fixed-dosed combinations (FDC) benefited from the six-month extension. No paediatric use marketing authorisation (PUMA) was granted, while four orphan medicines benefited from a two-year extension of their market exclusivity. 

According to the report, in 2022 a total of 129 Paediatric Investigation Plans (PIPs) received a positive opinion and 113 full product-specific waivers were granted.

AESGP, a study on the impact of self-care in Europe

Data from the Association of the European Self-Care Industry (AESGP) show 1.2 billion cases of minor illness are self-managed every year in Europe using non-prescription medicines. The resulting savings for healthcare systems and national economies are estimated in more than €36 billion. The study “Self-Care in Europe: Economic and Social Impact on Individuals and Society” was published in the scientific journal Thieme: Gesundheit Ökon Quality Management.

According to the study, future expansion of self-care (i.e. “the proactive management of minor and temporary ailments by a patient or consumer based on personal preference and with the use of a non-prescription medicine”) could potentially save more than €54 billion every year. Healthcare systems may reach an improved efficiency, avoiding the estimated need for additional 120,000 general doctors.

The study was presented on 15 November 2023 during a AESGP parliamentary event served as a platform for a roundtable discussion between the European Parliament, the research team, healthcare professionals, and patient representatives to explore strategies to incentivise and support the approach to self-care.

China applied for PIC/S membership

China’s National Medical Products Administration (NMPA) was granted by the PIC/S Committee, during its meeting on 6-7 November 2023, the status of Applicant to the Pharmaceutical Inspection Co-operation Scheme (PIC/S). The Chinese regulatory agency submitted its membership application on 22 September 2023, as a result of the successful completion and closure of the PIC/S pre-accession process.

The next phases of the procedure will be coordinated by the Rapporteur appointed by the PIC/S Committee, Jacques Morénas (France/ANSM), who will lead the PIC/S Audit Team in charge of managing and overseeing NMPA’s accession process. The NMPA will represent all Chinese authorities involved in the Chinese Good Manufacturing Practice Regulatory Compliance Programmes (GMPRCP) as defined by PIC/S.

Following confirmation of the Applicant status, NMPA will strengthen communication and cooperation with PIC/S. The final goal is to continuously improve China’s drug inspection system and standards, as well as its drug inspection quality management system. This is expected to support the development of Chinese inspectors’ team and the modernisation of the national drug regulation in China.

Data on sales of veterinary antibiotics

The fight to antimicrobic resistance is showing its first results, as demonstrated by the data on sales of veterinary antibiotics from 25 European countries released by the European Medicines Agency. According to the thirteenth annual report on the European Surveillance of Veterinary Antimicrobial Consumption (ESVAC): 2009 – 2023, overall sales of these medicines decreased by 53% between 2011 and 2022, a trend which translates into a lower risk of bacteria developing resistance in people and animals. Many classes of antibiotics considered critically important in human medicine due to their veterinary use showed a marked decrease of sales over the same period. Third- and fourth- generation cephalosporins dropped by 49%, polymyxins by 81%, fluoroquinolones by 25%, and sales of other quinolones dropped by 90%. These classes of antibiotics play an important role in mitigating the potential risk to public health, according to the Antimicrobial Advice ad hoc Expert Group (AMEG) categorisation. The ESVAC project was launched in 2009, with the participation of the first 9 volunteering European countries, and it counts today 31 participating countries. After the closure of the project in 2023, the ESVAC concept was integrated into the EU legislation, making the collection of data mandatory for all EU countries. The first comprehensive report based on sales data for 2023 will be published in 2025.

Source: EMA

Industrial associations comment the Commission’s Communication on shortages and strategic autonomy

Industrial associations comment the Commission’s Communication on shortages and strategic autonomy

EFPIA, on behalf of the innovator pharma industry, particularly welcomed the structural measures contained in the Communication to address the industrial dimension of medicines shortages in the medium and long term. In particular, the Critical Medicines Alliance “should provide a genuine platform for national authorities, industry, civil society, the Commission and EU agencies to develop coordinated action against shortages and provide structural solutions rather than treating symptoms”. Critics refer to the exclusion of the information stored in the European Medicines Verification System (EMVS) from tools to manage shortages.

Use of EMVS data has been indicated also by Medicines for Europe, representing the generic and biosimilar industry. Further developments towards a Critical Medicines Act should include also legal guidance on medicines public procurement and security of supply, a strategic EU reserve of essential medicines, EU funds and State aid projects to incentivise investments in greener and safer manufacturing processes for essential medicines and APIs. Regulatory flexibility to harmonise pack sizes and presentations and digitalisation of the regulatory systems are other  suggested points of attention.

The biotech industry represented by EuropaBio mentioned the need EU actions “are not limited to essential medicines but aim to address Europe’s growing dependency on third countries for innovation medicines”. To this instance, the European institutions are called to make mid- to long-term EU actions on shortages part of a true European industrial strategy. EuropaBio also recalled how the intricate processes involved in the manufacturing biological medicines, APIs, and intermediates require cutting-edge technologies that Europe can lead on.

Source: EFPIA; Medicines for Europe; EuropaBio

EU Commission’s solutions to address shortages and strategic autonomy

The European Commission published on 24 October the Communication detailing actions to prevent and mitigate critical medicine shortages in the EU, starting from this winter. The document is comprehensive of a series of short-term measures, and of mid- and long-term actions to improve the resilience and strategic autonomy of the European pharmaceutical supply chain. The focus of the Communication is on the most critical medicines, for which security of supply must be ensured at all times. The European Health Emergency Preparedness and Response Authority (HERA) and the European Medicines Agency (EMA) have already identified a list of key antibiotics (including specific paediatric formulations) potentially subjected to critical shortages ahead of the winter, and for which measures are already in place to ensure supply. The launch of the new European Voluntary Solidarity Mechanism for medicines by EMA has immediately followed the Communication. Under the MSSG Solidarity Mechanism, member states experiencing difficulties with the availability of critical medicines may ask support to other member states, which may voluntary share their available stocks. A Toolkit containing MSSG recommendations was also published by EMA. The end of the year should see the issuing of the new Union list of critical medicines, which should be followed in 2024 by the analysis of critical supply chains. Several forms of regulatory flexibility were also considered, i.e. regulatory exemptions, extension of shelf-life or the quick authorisation of alternatives. A dedicated Joint Action was announced for 2024 to promote effective use of these flexibilities. A new EU guidance on procurement of medicines to strengthen security of supply should be issued by early 2024, and a EU joint procurement should be activated to manage the 2023 winter season for antibiotics and treatments for respiratory viruses. Other elements of the proposed pharmaceutical reform may be accelerated, where possible.

The second part of the Communication addresses the structural measures identified by the Commission to support the long-term security of supply. A Critical Medicines Alliance should become operative in 2024, with the objective of diversifying supply and modernising production of critical medicines. The Critical Medicine Alliance will represent the industrial policy pillar of the European Health Union, and it will allow for the coordination of actions at EU level against the shortages of medicines and supply chain vulnerabilities. The Alliance will focus on a targeted number of critical medicines with the highest risk of shortages and impact on healthcare systems. Among its objectives are the coordination of public procurement practices at EU level, and how to diversify global supply chains through strategic partnerships. The possibility to expand Europe’s capacity to produce and innovate in the manufacturing of critical medicines and ingredients in coordinated way will be also explored, as well as helping leverage and align EU and national funding. The development by the Commission of a common strategic approach to medicines stockpiling in the EU was announced for the first half of 2024. A dedicated, preparatory study for a possible Critical Medicines Act should be launched by the end of 2023, followed by a impact assessment. At the international level, the Commission aims to establishing a network supporting resilience of supply chains, and strategic partnerships with third countries for the production of critical medicines.

ANAFAM associated to IGBA representing Mexico

The Mexican National Association of Drug Manufacturers ANAFAM was accepted in September 2023 as a member of the International Generic and Biosimilar medicines Association (IGBA), representing global manufacturers of generic and biosimilar medicines.

ANAFAM Board Member and former President Dagoberto Cortés, commented “It is an honour for ANAFAM to participate as a member of IGBA, whose goals we fully share. We are delighted to work together to ensure patient global access to affordable, quality-assured, and effective medicines and obtain a stronger voice in Mexico”.

The Mexican regulator COFEPRIS is one of the 15 Regulatory Members of ICH, added David Gaugh, IGBA Chair, welcoming ANAFAM’s membership. “One of our goals is to be a representative body for the global generic and biosimilar medicines industries by attracting the widest assembly of members who are committed to subscribing to our standards and common principles, and to matching the continuous expansion of the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH)”, he said.

Source: IGBA

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