As a first step towards the adoption of a Pharmaceutical Strategy for Europe the Commission published on 2nd of July a roadmap, inviting interested citizens and stakeholders to share their views on the Strategy. Scheduled to be adopted before the end of the year, the overall objective of the Pharmaceutical Strategy for Europe is to help ensure Europe's supply of safe and affordable medicines and support the European pharmaceutical industry to remain an innovator and world leader.

Stella Kyriakides, Commissioner in charge of Health & Food Safety, said:

“By the end of the year, I will present an ambitious Pharmaceutical Strategy for Europe to ensure affordability, sustainability and security of supply. The coronavirus pandemic has showed us more than ever that we need to have a crisis-resistant system and the means to produce medicine within the EU to ensure timely access to essential medicines for our citizens and hospitals in all circumstances.”

Citizens, experts and stakeholders are invited to give, until 7 July 2020, their feedback to the roadmap through the Better Regulation Portal and consult the dedicated website for additional information and to follow updates. This roadmap will be followed by a public consultation.

06 July 2020, submitted by Nora LAUBSTEIN

1. In the name of European patients and professional providers in the field of a sustainable, holistic, individual person-centered and forward-looking strategy for access to affordable medicines, we have identified the following key-demanding: In the last twenty-five years Natural Medicine/CAM has suffered the loss of thousands of traditional and medicinal products. We want them back! E.g. there is no longer a BSE-epidemic which cuts organic medicinal products.

2. The doses of a Natural Medicines/CAM medical product depend of the individual need of patients. We need a harmonisation of national and European regulation.

3. A new EU-pharmaceutical strategy should include a separate chapter for CAM and its medicinal and other products. It would be crucial to develop a design for research and studies for Natural Medicine/CAM`s own, respecting the specific circumstances and needs. On top the inclusion of additional effects by the composition of medicinal products.

4. We welcome the COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE EVALUATION of the Regulation (EC) No 1924/2006 on nutrition and health claims made on foods with regard to nutrient profiles and health claims made on plants and their preparations and of the general regulatory framework for their use in foods, hoping for support and a fruitful together with CAM-stakeholders.

With kind regards Nora Laubstein

25 June 2020, submitted by Nora LAUBSTEIN

Dear Commissioner Stella Kyriakidis,
yes there is a need to build a holistic, individual patient-centered, forward-looking EU Pharmaceutical Strategy which covers the whole life-cycle of pharmaceutical products from scientific discovery to authorization and patient access including sustainable medicines and remedies too. First I have to mention some challenges related to the current legislation: Directive 2004/24/EC (THMPD-herbal preparations) as a body of rules enabling a simplified registration of natural products with long term tradition. Inside the attached file you will find my concrete suggestions for a better EU-pharmaceutical strategy.

Second: The new strategy should ensure the sound functioning of the internal market and the sustainability of public finances AND the environment. It will create synergies with relevant EU policies, such as in the areas of agriculture, air pollution, clear water and the reducing of plastic-waste. The coherence will be kept with EU clinical trials respecting the biological and physical regulation of human and animal beings.

The idea of a “New Green Deal” and the implementation via SDG`s into the “Health in all policies”-project should be based crucial on the interdisciplinary aspects of natural medicine, products and prevention.

Sincerely, Nora Laubstein, Association for Natural Medicine in Europe-ANME e.V.

ECHAMP fully supports this initiative. We recommend that the new strategy also acknowledges the contribution that the industry for homeopathic and anthroposophic medicinal products can make towards achieving a forward-looking EU Pharmaceutical Strategy that balances curative treatments with preventive care, including appropriate self-medication.

EUROCAM, representing 60,000 organised patients/citizens, 250 national associations and a substantial part of the 400,000 doctors, veterinarians and practitioners in the sector of Traditional and Complementary Medicine (T&CM) across Europe, welcomes the Commission’s Roadmap towards a Pharmaceutical Strategy for Europe.