MedTech Europe Archives - European Industrial Pharmacists Group (EIPG)

The drug shortage situation - EIPG's point of view


by Maurizio Battistini The shortage of medicines has been a major concern in the countries of the European Union, and elsewhere, for more than 10 years, so much so that the Economic Community has devoted a great deal of effort Read more

EP’s draft position on Unitary SPC and SPC Regulation revision


by Giuliana Miglierini The Committee for Legal Affairs (JURI) of the European Parliament released the draft amendments to the Commission’s proposals aimed to establish a Unitary Supplementary Protection Certificate (SPC) (links to the document and to the procedure) and to Read more

Reactions to the proposed ban of PFAS


by Giuliana Miglierini A proposal to ban around 10,000 per- and polyfluoroalkyl substances (PFAS) was submitted in January 2023 to the European Chemicals Agency (ECHA) by authorities of Germany, Denmark, the Netherlands, Norway, and Sweden. The proposal was published on Read more

Reactions to the proposed ban of PFAS

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by Giuliana Miglierini

A proposal to ban around 10,000 per- and polyfluoroalkyl substances (PFAS) was submitted in January 2023 to the European Chemicals Agency (ECHA) by authorities of Germany, Denmark, the Netherlands, Norway, and Sweden. The proposal was published on ECHA website on 7 February 2023.

The focus is the so-called “forever chemicals”, i.e. very high persistence PFAS typically characterised by bioaccumulation (also in plants), great mobility and a long range transport potential, and potential endocrine activity.

This landmark proposal by the five authorities supports the ambitions of the EU’s Chemicals Strategy and the Zero Pollution action plan. While the evaluation of such a broad proposal with thousands of substances, and many uses, will be challenging, we are ready.”, said Peter van der Zandt, ECHA’s Director for Risk Assessment.

The proposal was open to public consultation on 22 March 2023, giving rise to the collection of 5,600 comments. Opinions will be issued by ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC), to be then forwarded to the EU Commission for final decision.

 The current role of PFAS

PFAS are characterised by the presence of alkyl groups in which many or all the hydrogen atoms have been replaced with fluorine. The main carbon chain of these substances may have different lengths, from small molecules to long chain PFAS and polymers, and may carry a very wide variety of other functional groups. The strength of the carbon-fluorine bond is the root cause of PFAS persistence, leading to these substances remaining in the environment for decades to centuries.

Per- and polyfluoroalkyl substances are currently used in many different industrial sectors, thanks to their useful technical properties. Among others, PFAS can be used to repel water, oil and dirt from surfaces, and is characterised by a high durability under extreme conditions of temperature, pressure, radiation, and chemicals. PFAS also present electrical and thermal insulation properties.

The main features of the restriction proposal

According to the authorities that submitted the proposal, around 4.4 million tons of PFAS would end up in the environment over the next 30 years in the case of no action. Ban would refer to manufacture, placing on the market and use as such, as constituent in other substances or in mixture as well as in articles.

Two options for restriction have been considered, a full ban or specific derogations for certain industries, based on the analyses of alternatives, efforts put in place for switching to them, and socio-economic considerations. The ban would be effective above a set concentration limit; a transition period of 18 months should occur between final adoption and entry into force. Use-specific, time-limited derogation might refer, for example, to a 5-year period in the case of food contact materials for industrial food and feed production (as alternatives are already under development, but are not yet available to entry into force), or to a 12 years for implantable medical devices (for which identification, development and certification of alternatives is still needed).

During the public consultation phase, comments were received from more than 4,400 organisations, companies and individuals, to be reviewed by both the RAC and SEAC committees and the five proposing countries. Sweden, Germany and Japan are the countries that contributed the higher number of comments, well in advance of Belgium, China, Italy and the US. Companies provided more than the half of the comments (58,7%), followed by individuals (27,3%), and industrial or trade associations (9,8%). The full list of entities participating to the consultation is available at the consultation webpage.

EFPIA response to ECHA’s consultation

The European Federation of Pharmaceutical Industries and Associations (EFPIA) contributed to the consultation with a detailed document. Another joint ISPE-EFPIA document particularly addressed the use of fluoropolymers and fluoroelastomers in medicinal product manufacturing facilities.

While we support the need to restrict certain PFAS, we need to find the right approach to ensure the continued manufacturing and availability of medicines in Europe. A total ban would see medicines’ manufacturing in the EU grind to a halt in under three years. It would also jeopardise the production of all pharmaceutical substances in Europe and would conflict with the EU’s strategy of reducing dependency on nations outside of the EEA in the event of shortages or pandemics.”, said EFPIA’s director general, Nathalie Moll.

EFPIA’s consultation documents highlights the many different uses of PFAS in the pharmaceutical industry, ranging from active pharmaceutical ingredients (API) falling within the definition of PFAS used in the proposal, to building blocks and raw materials used within chemical synthesis of PFAS and non-PFAS medicines. Other reagents and equipment might also fall within the scope of the ban, as well as packaging materials or combination products such as pre-filled syringes. The ban would also affect the manufacturing process, where PFAS materials are used in a wide variety of applications.

It might thus result in the disappearance from the market of a large number of important medicines, warns EFPIA, due to the unavailability of replacement materials, and the time required to obtain regulatory re-approval of alternatives. The supply chain of pharmaceuticals would be also impacted at many stages, thus possibly exacerbating shortages.

In its analysis, EFPIA highlights how some PFAS are considered of low concern by the OECD, and in particular “those used in actual medicines have no or low identified risk through medicines risk benefit or environmental risk assessments”.

A patient access impact analysis was also jointly developed by the involved industrial associations (AESGP, EFCG, EFPIA, Medicines for Europe and Vaccines Europe), showing that the current proposal would lead to at least 47,677 global marketing authorisations being affected by the ban. More than 600 medicines from the WHO Essential Medicines List would be at risk; restrictions would greatly impact also the European Member State’s “Critical Medicines lists”.

EFPIA submitted also a socio-economic assessment of the proposal, according to which a broad restriction of PFAS used in the production of human medicines would have disproportionate negative impacts on the European economy and society. “Without additional derogations, the entire pharmaceutical industry would no longer be able to manufacture active pharmaceutical ingredients (APIs) (whether classified as PFAS or non-PFAS APIs) or associated medicinal products in the EEA”, writes EFPIA, resulting in APIs production to necessarily move out of the European Economic Area.

The position of the medical device sector

MedTech Europe also published a position paper on the PFAS restriction proposal and called fora realistic transition pathway to non-PFAS alternatives that are both reliable and feasible for medical technologies (including their manufacturing and supply chain) to avoid shortages of medical technologies for patients and practitioners”.

The position paper presents many PFAS use cases in the field of medical devices, together with the criticalities posed by the proposed transition. In particular, broad derogations should be considered to allow sufficient time to first “identify all PFAS uses in medical technologies and to subsequently move to alternatives where these are proven to be technically viable, available besides in conformity with the sector-specific MD and IVD Regulations so as fit for the intended purpose”. In this case too, the need to manage complex supply chains would require a realistic timeline in order to address dependencies, and long development timelines and steps to ensure compliance with the sectorial legislation.


The new vision for the European research landscape

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by Giuliana Miglierini

The new European framework for research and innovation, Horizon Europe (HE, 2021-2027), is now operative. A great deal of work has been accomplished in the recent months in order to define the possibility for third countries to participate to the new projects that will be activated. The List of Participating Countries in Horizon Europe was published by the European Commission at mid-June; it includes eighteen third countries associated to the framework programme, according to the provisions set forth by Regulation 2021/6951.

Eighteen third countries associated to Horizon Europe
The list also includes the United Kingdom, which became a third country after the Brexit, but with the exception of its participation to the EIC Fund (which is part of the EIC Accelerator that provides investment through equity or other repayable form).
The status of associated country makes its legal entities entitled to participate to HE’s projects under equivalent conditions as legal entities from the EU member states, unless specific limitations or conditions are specified in the work programme and/or call/topic text. All the sixteen non-EU countries associated to Horizon 2020 have expressed interest to continue the collaboration with the EU’s researchers. Transitional arrangements are in place to govern their participation to HE while waiting for the definitive closure of the negotiations.
Israel, Iceland and Norway are other components of this list, together with the majority of East European countries, Turkey, Morocco and Tunisia. Among not associated countries, Liechtenstein openly expressed its intention not to become an associated country. Further negotiations can lead to the expansion of the list.
Non-associated countries and international organisations can participate to most Horizon Europe’s calls, unless specific limitations or conditions apply; particularly interesting from this point of view are topics of research specifically directed to improve international cooperation.
Participants from not associated countries are not automatically eligible for funding, thus have to participate to the research activities at their own cost. Some exceptional circumstances allow them to access funding, i.e. in the case of outstanding competence/expertise, or if access to particular research infrastructures, data or geographical environment is needed. Automatic funding is available to a selected list of low- to middle-income countries from Africa, Asia, South America and Oceania.

The case of Switzerland
Switzerland is currently excluded from the pool of associated countries to Horizon Europe.
This is the result of the decision of the Swiss Federal Council occurred at the end of May to stop the seven years-long negotiations with the EU Commission (see more on Science Business).
Significantly, scientific research and the status of associated country within HE was not part of this negotiation, that was focused instead on bilateral agreements for the free movement of persons and mutual recognition of industry standards, agricultural products, air transport and land transport, as reported by Science Business.
The exclusion of Switzerland immediately caused a vivid debate among European scientists, worried for the possible consequences of the inability of their Swiss colleagues to take part to HE’s projects. An Open Letter signed by many different European Science,Technology & Innovation (STI) Councils and Advisory Bodies and other Science organisations (among which Science Europe and Cesaer) urges for the full association of Switzerland with Horizon Europe.
The signatories of this letter would like to underline the importance of continuing the long established and mutually beneficial cooperation between the EU and Switzerland in the domain of research and innovation”, states the letter. Many are the past contributions from the Helvetic country to the success of European research, starting with the hosting of the European Organisation for Nuclear Research (CERN) up to the foundation of the European Space Agency. “Downgrading Switzerland to a third country would severely limit its expertise being brought into Horizon Europe projects tackling today’s and tomorrow’s global challenges. We are convinced that this would lead to a lose-lose situation, putting successful cooperation in strategic areas at risk and ultimately weaken the ERA as a whole”, write the scientific organisations.

The situation with respect to China, the US and Canada
The “open strategic autonomy” is the new paradigm of action the von der Leyen Commission shall apply also in the field of research and innovation. According to Science Business, this approach will represent the basis for the negotiations with countries like China, that might require a higher level of attention with respect to the need of providing adequate protection for the intellectual property developed by European scientists.
Preliminary discussions to solve legal issues that prevented the participation of US universities to EU research projects in the past years are also undergoing. In the meantime, the high level EUUS Trade and Technology Council (TTC) was launched by US president Joe Biden and EU Commission president Ursula von der Leyen during the US-EU Summit in Brussels on June 15, 2021.
The TTC will meet periodically at the political level to coordinate approaches to key global trade, economic, and technology issues and to deepen transatlantic trade and economic relations commitment to strengthen our technological and industrial leadership and expand bilateral trade and investment. It also gives us tools to address threats such as unfair competition and the misuse of new technologies. This is a top priority for the EU, and we warmly welcome the fact that it is now also at the top of the transatlantic trade agenda”, said Valdis Dombrovskis, European Commission Executive Vice-President and EU Trade Commissioner.
The TTC will operate through several working groups, responsible to translate the political decisions into deliverables, coordinate the technical work and report to the political level. Among the first topics for its action is cooperation in the field of technology standards and secure supply chains.
Preliminary negotiations took place also with Canada in the course of the European Union-Canada summit, in June (See more here). Specific points in the field of health mentioned in the final joint statement include the launch of a new Canada-EU dialogue on health under the Strategic Partnership Agreement to improve health cooperation in multilateral contexts, and an enhanced bilateral cooperation under Horizon Europe. This last action should see some exploratory discussions towards a possible association of Canada to the framework programme, particularly with respect to the green and digital transitions and AI and quantum cooperation.

A new Strategy for Science Europe
Science Europe, the organisation representing major national research performing organisations (RPOs) and research funding organisations (RFOs) in Europe, has published its new Strategy 2021-2026 and the related Action Plan.
The central vision of the news Strategy is that “for a European Research Area with optimal conditions, to support robust education, research and innovation systems”. This goal will be pursued by defining the long-term perspectives for European research and selecting the best-practice approaches. Scientific knowledge as a common good, research as a public service, freedom of scientific inquiry, responsibility of all actors in ensuring the highest possible standards of quality, ethics, integrity, inclusivity, and openness in the conduct and management of research are just some of the values that have inspired the Strategy.
Three priorities will guide members organisations, starting from the role RPOs and RFOs can play in shaping future developments of the European research policy. Open science will continue to represent the paradigm of choice in order to ensure sustainability of the R&I system. A possible evolution of the current framework may result in the proposed European Framework Programmes for Research and Innovation. Science Europe will support its members in promoting investment in R&I and in closing the performance divide between different national R&I systems in Europe. Complementarities shall constitute the basis of bilateral and multilateral collaboration between member organisations, as well as of cross-border collaborations at a global level.
The diffusion of a solid, quality-driven research culture is a fundamental requirement for its success. Science Europe plans to play a central role with other European institutions in jointly define and implement the positive culture shift needed to create sustainable research ecosystems. This goal will take advantage of the different approaches and values that are used by researchers from different EU countries, taking also into consideration the global challenges and societal expectations and the degree of self-organisation of the European R&I system. Incentives and rewards are foreseen as a way to improve the sustainable development of research systems, together with a better coherence between policy areas.
According to Science Europe, the European research framework is called to an effort to develop new, long-term solutions for the current challenges that affects society. Interdependencies between curiosity-driven and challenge-oriented approaches should be addressed in order to boost this target, together with the support to Open Science models. A stronger engagement between researchers, policy makers and society, and improved support to trans-disciplinary research are key objectives set forth by Science Europe’s Strategy.

A Strategic Agenda from five industrial associations
From the industrial point of view, the activation of the new Horizon Europe research framework will correspond to the end of the Innovative Medicines Initiative (IMI), that characterised the public-private partnerships for research in the pharmaceutical and life sciences sectors in the past decade.
A new framework is expected to take its place, the proposed Innovative Health Initiative (IHI), which should be activated in the context of Horizon Europe. While the European Commission is still working to define the legislation governing the new partnerships, a Strategic Agenda for Research & Innovation in Healthcare has been released by five European industry associations representing the pharmaceutical, biotech and medical technologies industries (COCIR, EFPIA, MedTech Europe, EuropaBio and Vaccines Europe).The Agenda has been jointly drafted by the prospective IHI Joint Undertaking member industry associations and the European Commission services (based on the results of a public consultation ran in 2019) and it should represent the basis for the final, formal adoption of the new IHI framework after the partnership legislation has been adopted and the partnership is operational. A new tool is planned within Horizon Europe to run the IHI, the institutionalised Public-Private Partnerships, which are expected to help de-risking the pre-competitive public-private collaboration.
The vision illustrated by the document reflects the new models of cross-sectorial integration of technologies, know-how, products, services and workflows in order to build true new peoplecentred healthcare systems. The development of new solutions for the prevention, diagnosis and treatment of diseases should aim to sustain the good health of EU citizens, and decrease the disease burden for patients, care givers and healthcare professionals.
The new European ecosystem for R&I should aim, according to the document, to facilitate translation of scientific knowledge into innovation, so to respond to the strategic unmet public health needs in a cost-effective way.
Five specific objectives to be achieved by 2030 are envisaged by the Strategy, from a better understanding of the determinants of health and priority disease areas to the integration of fragmented health R&I efforts, up to the development of tools, data, platforms, technologies and processes for improved prediction, prevention, interception, diagnosis, treatment and management of diseases. Projects will be also targeted to demonstrate the feasibility of peoplecentred, integrated healthcare solutions. Digitalisation and data exchange will be central activities to achieve this goal, and will also support the development of new and improved methodologies and models for the comprehensive assessment of the added value of integrated healthcare innovations.
Examples of the activities that may be part of the new IHI projects are the discovery, development and testing of new molecules, and the study of their mechanisms of action; the development and testing of new processes and technologies, and new methodologies for the assessment of safety, health outcomes or for health-economic evaluation. Development may be run up to the pre-standardisation activities or pilots/proofs of feasibility scale, including in-silico trials. Contributions to the development of regulatory science are also an expected outcome. The pharmaceutical and medical technology sectors will be engaged in multi-sectorial activities, moving from product- and pathology-centric goals to patient-centric development. Priorities of research shall be set forth by early engagement with public sector stakeholders, through the establishment of a new Innovation Panel.