Table. Characteristics of the Transparency Provisions in Different EU Member States .
| DE | ES | FR | IT | LV a | NL | SE | UK | PT | EFPIA b | ||
| Type of policy | |||||||||||
| Industry self-regulation | Y | Y | Y | Y | Yc | Y | Y | Y | |||
| Government | Y | Y | Y | ||||||||
| Target industries | |||||||||||
| Pharmaceutical industry | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y |
| Medical device industries | Y | Yd | Y | ||||||||
| Health professionals covered | |||||||||||
| Physicians | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y |
| Non-physicians | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y | Y |
| Organisations covered (eg, hospitals, medical centres, Universities, medical societies) | |||||||||||
| Y | Y | Y | Y | Ye | Y | Yf | Y | Y | Y | Y | |
| Individual data | |||||||||||
| Mandatory data release | Yg | Y | Y | Y | Y | ||||||
| Consent required | Y | Y | Y | Y | Y | Y | |||||
| Threshold for disclosure | |||||||||||
| N | N |
Y €10 |
N | N | N |
Y €500/year per company |
N | N |
Y €60 |
N | |
| Types of payments excluded from disclosure | |||||||||||
| Meals and drinks | Y | Y | Y | Y | Y | Y | Y | Y | |||
| Drug samples | Y | Y | Y | Yh | Y | Y | Y | Y | Y | Y | |
| Transfers of value related to OTC drugs | Y | Y | Y | Y | Y | Y | |||||
| Small gifts, education or promotional materials | Y | Y | Y | Y | Y | Y | Y | Y | |||
| Other | # | ¨ | * | ||||||||
| Location of the data and searchability | |||||||||||
| Centralised searchable registry | Y | N/Ai | |||||||||
| Centralised searchable registry with no possibility for data extraction | Yj | Yj | Y | ||||||||
| Separate PDFs or weblinks on a single website | Y | Y | Y | N/A | |||||||
| Separate PDFs on each company website | Y | Y | Y | Y | N/A | ||||||
| Data access judged to be user-friendly | |||||||||||
| N | N | N | N | N | N | Partial | N | Y | Partial |
N/A |
|
Abbreviations: DE, Germany; ES, Spain; FR, France; IT, Italy; LV, Latvia; NL, The Netherlands; SE, Sweden; UK, United Kingdom; PT, Portugal; EFPIA, European Federation of Pharmaceutical Industries and Associations; EU, European Union; OTC, over-the-counter.
a In Latvia governmental and industry regulation coexists, with complementary roles.
b The EFPIA Code is included for comparison with national codes.
c Mixed: Code developed by a multi-stakeholder organisation, CGR, with support for the central database by the Dutch Ministry of Health and management by an independent foundation (Stichting Transparantieregister Zorg).
d Payments from medical devices companies reported as of 2016; governed by another Code (not assessed for the purpose of this paper).
e Does not cover universities but covers foundations or associations affiliated to universities.
f Only covers organisations that subscribe to the Code; others can join on a voluntarily basis.
g Payments made from January 1, 2017 do not require prior individual consent by Healthcare Professionals and will be published on an individual basis except for transfers of value related to R&D which will remain being published on an aggregate basis.
h Samples reported under different regulatory requirements.
i Mandates publication on a publicly available platform, either on a company website or centralised.
j Partly searchable. In the Netherlands, searching is possible by beneficiary, not by company.
# Only the following payments are covered: organising and sponsorship of promotional and scientific events attended by specialists (includes travel and accommodation); support to specialist professional associations and medical institutions for scientific or professionally oriented event.
♦ Research costs excluded, except for some non-interventional research.
* Cost of travel, accommodation or fees for conference participation are irrelevant (although not formally excluded) as this is not allowed in the Swedish industry code.