Position on the Critical Medicines Act: Balancing Supply Chain Resilience with Healthcare Systems Sustainability

On 11 March 2025, the European Commission published its proposal for a Critical Medicines Act (CMA), aiming to address shortages of critical medicines and strengthen Europe’s pharmaceutical supply chains. The initiative is also positioned as part of a broader push to enhance the EU’s strategic autonomy and competitiveness.

For the Critical Medicines Act to be truly effective, ESIP stresses that multi-layered, public support and incentives which aim to derisk production processes and strengthen supply chain resilience need to be balanced, transparent, evidence-based, economically-sound and accompanied by appropriate conditionalities.

The newly published position paper outlines several key recommendations:

• A thorough evaluation of market dynamics and supply chain vulnerabilities

• An assessment of the proposal’s economic impact, particularly in relation to public procurement criteria

• Flexible procurement guidelines allowing public authorities to prioritise supply security and resilience without compromising access or affordability

• Efficiency-driven industrial policy measures, with incentives and conditionalities tied to concrete supply security outcomes

• Predictable and sustainable EU and national public funding to support manufacturing

• Greater transparency around public incentives

• Consistent, EU-wide monitoring of medicine availability and shortages

• Inclusive governance structures involving national authorities in charge of procurement, pricing and reimbursement

ESIP emphasises the importance of a sound, balanced legislative framework that promotes supply security without undermining affordable access. The Critical Medicines Act must uphold the financial sustainability of public healthcare systems, a key element for a competitive European economy.

Find the full ESIP position paper on the European Commission's proposal for a Critical Medicines Act.