Skip to main content
. 2020 Sep 21;124(12):1287–1296. doi: 10.1016/j.healthpol.2020.09.001

Table 3.

Financial sanctions related to medicine shortages as of March / April 2020.

Country Financial sanctions in general Financial sanctionsa
for non-supply for non-compliance to reporting requirements for non-compliance with stocking requirements
Austria No No No Not appl. (no reserve)
Albania Yes No Not appl. (no register) Yes (in contract)
Bulgaria No No Not appl. (no register) Not appl. (no reserve)
Canada Yes No Yes No
Cyprus No No No (sanctions were being discussed) Not appl. (no reserve)
Czech Republic Yes Yes Yes Not appl. (no reserve)
Denmark Yes Yes Yes (but not imposed) Yes, under the contractual tender obligation (inpatient medicines) to stock listed medicines for 3−6 months
Finland Yes No No (sanctions were being discussed) Yes
Germany Yes No Yesb Not appl. (no reserve in principle)
Israel No No Yes No
Italy Yes No Yes (since 2019) Not appl. (no reserve)
Latvia Yesc No Yes No
Lithuania No No No Not appl. (no reserve requirements for MAH)
Malta No No No No
Moldova No No Not appl. (no register) Not appl. (no reserve)
Netherlands Yes Yes (for winners of the tenders) Yes Yes, under implementationd
Norway No No No Noe
Portugal Yesc Yes (but not imposed) Yes (but not imposed) Yes (but not imposed)
Romania Yes No Yes Not appl. (no reserve)
Russia No No Not appl. (no register) No
Slovenia Yes Yes, for wholesalers in case of non-supply with 24 h (weekdays) or 72 h (weekend) Yes Not appl. (no reserve requirements for MAH)
Sweden Yes Yes (for winners of the tenders) No Not appl. (no reserve)
Switzerland No No No No
United Kingdom Yesc No Yes No

MAH = marketing authorisation holders, not appl. = not applicable.

a

Unless indicated (e.g. for Denmark), it is not known whether, or not, sanctions were actually enforced.

b

Since a legal change on 1 April 2020, which introduced the obligation to notify the register.

c

In addition, financial sanctions for the export of medicines which are prohibited to be exported.

d

Policy of supply reserves will be established in 2020, to be introduced with financial sanctions.

e

On the contrary, increased costs for wholesalers for additional stockpilings during the COVID-19 crisis are refunded by the state.