Open letter to the Federal Antimonopoly Service of Russia

Open letter to the Federal Antimonopoly Service of Russia 20 August 2020

Dear Colleagues!

(And we, at least, are united by our long-term professional work as part of the expert council under the Federal Antimonopoly Service (FAS) for the Development of Competition in the Social Sphere and Healthcare.)

With age, I stopped being surprised at the sometimes ridiculous and absurd decisions made by individual officials in the power structures, realizing that not only an atmospheric column weighing 214 kg, but also a serious bureaucratic press, presses on the shoulders of each of them.

 However, on August 6 of this year, while on vacation, I was sadly puzzled by a report in the media about the FAS warning issued to me in connection with the comment to “Izvestia” on July 13, 2020 about the price increase for analgin. At first I took it as a bad joke, reminiscent of George Orwell's dystopian novel “1984”. However, numerous phone calls from colleagues and media representatives have convinced me that this is not a joke. That is why I am addressing you with an open letter.

An analysis of the economic situation, carried out by numerous research institutes and the expert community, shows that the period of record low inflation in Russia is over. According to Rosstat (Federal State Statistics Service), in July prices rose by 0.4% against 0.2% a month earlier. Apples have risen in price by 20 rubles per kilogram, compared to last year, buckwheat - by 35 rubles. Experts say that the main reasons for the rise in prices for food products are the fall in the ruble exchange rate, the rise in the price of gasoline, and the increase in utility tariffs. By the end of 2020, the Bank of Russia predicts inflation at around 3.7-4.2 percent. At present, it is about 3.4 percent. Similar processes are taking place in the pharmaceutical industry, which, among other things, was indicated by the FAS in the reports and speeches of its employees. According to DSM Group, over the year, the weighted average cost of a package of medicines in the Russian Federation increased by 23.8%. Analysts believe that these are the consequences of the depreciation of the ruble and the impact of the pandemic. Therefore, it is strange that an objective and competent commentary based on many years of experience in the industry, the opinion of research and marketing companies, and just basic knowledge of the laws of economics, caused such a reaction from the anti-monopoly authority.

At the same time, at least, the causal relationship was turned upside down: not the speaking on a public platform "can lead to a violation of antimonopoly legislation, in particular, to the establishment or maintenance of prices for drugs," but the rise in prices specifically for analgin led to this comment.

I would like to understand the logic of reasoning of the official who prepared the document for signature. What thoughts visited his/her bright mind? I do not exclude that he saw himself as at least an employee of the Ministry of Truth from the aforementioned Orwellian novel. But away from imagination!

Over 18 years of work, ARPM has accumulated rich experience of interaction with various structures of the executive and legislative branches. Members of the Association, experts working both in companies and in the executive management, have a broad professional outlook and a significant amount of knowledge of the intricacies of the industry. Their assessments and judgments contribute to making decisions not only aimed at the development of Russian pharmaceutical industry, but also, most importantly, at protecting the interests of patients.

There are still many problematic issues in the pharmaceutical industry, and their solution depends on the well-coordinated, high-quality, professional and responsible work of all participants in the process.

I urge you to further dialogue on the effectiveness of the drug supply system for the population, including complex issues of pricing, the monopoly position of the operator of the Drug Movement Monitoring (DMM) system and the only supplier for a number of drugs.

Let us not only listen, but also hear opponents, and engage not in warnings, but in argumentation. This is the only way we can work out effective mutually acceptable solutions.


Yours faithfully and hope for understanding,

 General Director of the Association of Russian Pharmaceutical Manufacturers

Victor Dmitriev.

Return to the list