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European Coalition on Homeopathic & Anthroposophic Medicinal Products

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Homeopathic medicinal products

Directive 2001/83/EC on medicinal products for human use outlines two procedures for market access of homeopathic and homeopathically produced anthroposophic medicinal products:

  • Special Simplified Registration Procedure (Article 14)
  • Marketing Authorisation (Article 16).

The Special Simplified Registration Procedure (simplified registration) applies to homeopathic medicinal products that comply with the following criteria:

  • They are administered orally or externally
  • No specific therapeutic indication appears on their labelling
  • There is a sufficient degree of dilution to guarantee their safety; in particular they may not contain more than 1 part per 10,000 of the mother tincture or more than 1:100th of the smallest dose used in allopathy with regard to active substances whose presence in an allopathic medicinal product results in the obligation to submit a doctor’s prescription.

Those products which do not comply with these criteria need to be authorised in accordance with Article 16. As a consequence, the general marketing authorisation procedures for allopathic medicinal products are in principle applicable to homeopathic medicinal products which are not eligible for a simplified registration.

However, Member States have the competence under Article 16(2) to retain or introduce specific rules for pre-clinical tests (pharmacological and toxicological tests) and clinical trials in accordance with the principles and characteristics of homeopathy as practised in that particular Member State. Thus they are able to adopt special rules to make a risk/benefit assessment as follows:

  • Recital 25 of 2001/83/EC (formally Recital 11 of the preamble to Directive 92/73/EEC) states: “(…) In particular, those Member States which have a homeopathic tradition should be able to apply particular rules for the evaluation of the results of tests and trials intended to establish the safety and efficacy of these medicinal products provided that they notify them to the Commission”