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.

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