http://www.doctorswithoutborders.org/publications/article.cfm?id=6871&cat=open-letters



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MSF Open Letter to TPP Countries: Don't Trade Away Health**
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*Geneva, 15 July 2013*

We are writing to express serious concern over provisions under negotiation
in the Trans-Pacific Partnership Agreement (TPP) that threaten to restrict
access to affordable medicines for millions of people, especially in low-
and middle-income countries. Unless certain damaging provisions are
removed, the TPP has the potential to become the most harmful trade pact
ever for access to medicines.

Médecins Sans Frontières/Doctors Without Borders (MSF) is an independent
international medical humanitarian organization that delivers medical care
to people affected by armed conflicts, epidemics, natural disasters and
exclusion from healthcare in nearly 70 countries. In order to fulfill its
mission, MSF requires access to affordable medicines.

Generic competition has proven to be the best way to reduce drug prices and
improve access to treatment. MSF began providing antiretroviral (ARV)
treatment for HIV/AIDS in 2000 when the cost of treatment was more than
10,000 USD per patient per year. MSF now treats 285,000 people in HIV/AIDS
projects in 21 countries, mostly with generic drugs produced in Asia. These
generics have reduced the cost of treatment by nearly 99% to less than 140
USD per patient per year. Ministries of health, humanitarian medical
treatment providers like MSF, and donors routinely rely on affordable
quality generic medicines to treat a variety of health needs.

The TPP is being negotiated without opportunity for meaningful public
input. Leaked texts, however, indicate that stringent intellectual property
(IP) provisions proposed by the United States go well beyond rules
established by the World Trade Organization (WTO) Agreement on
Trade-Related Aspects of Intellectual Property Rights (TRIPS). These
demands, summarized in an annex to this letter, will roll back public
health safeguards and flexibilities enshrined in international law, and put
in place far-reaching monopoly protections that will restrict generic
competition and keep medicine prices unaffordable.

We believe this presents a direct threat to the future availability of
affordable medicines for MSF’s patients and for millions of others around
the Asia-Pacific region. We are also concerned that the TPP, billed as a
‘21st century model trade agreement’, could become a global standard, with
worldwide damaging repercussions for access to treatment.

Negotiating countries should reject provisions that will harm access to
medicines and ensure that the final text is aligned with relevant global
public health commitments. Such commitments include the 2001 WTO Doha
Declaration on TRIPS and Public Health and the 2008 WHO Global Strategy and
Plan of Action on Public Health, Innovation, and Intellectual Property.

The medical research and development (R&D) system as it stands today does
not deliver innovation for neglected populations and it results in
unaffordable medicine prices for patients worldwide. Stricter IP rules
reinforce, instead of reform, this broken system. There is a pressing need
for a paradigm shift in the way pharmaceuticals are researched and
developed, and how intellectual property is applied to medicines as global
public goods. Governments should introduce global norms which delink drug
development and price. MSF believes this is essential to closing the gap in
access to medicines for millions of people around the world by promoting
both innovation and access.

We thank you for your attention and are available for further discussions
and information.

Sincerely,

Dr. Unni Karunakara
International President
Médecins Sans Frontières

Dr. Manica Balasegaram
Executive Director, Access Campaign
Médecins Sans Frontières

Sophie Delaunay
Executive Director, USA
Médecins Sans Frontières/Doctors Without Borders*


**ANNEX*


Certain provisions are critical to maintaining legal and regulatory
flexibility for the protection of public health and access to medicines.
MSF urges TPP negotiating countries to:

   1. *Retain flexibility in determining patentability criteria and subject
   matter.* The TPP proposal requires new patents be granted for existing
   drug modifications, even in the absence of improved therapeutic efficacy,
   facilitating abusive patent evergreening practices that extend monopolies.
   The TPP also requires the patenting of diagnostic, therapeutic, and
   surgical methods, potentially exposing doctors to liability for performing
   patented procedures.
   2. *Allow pre-grant opposition.* Pre-grant opposition is an important
   tool to combat weak patents that allows both public oversight and technical
   support to national patenting authorities. The TPP proposes to prohibit
   this legal safeguard, making challenging undeserved patents more expensive
   and cumbersome.
   3. *Not mandate data exclusivity. *Data exclusivity is not required by
   international law and represents a way for pharmaceutical companies to
   delay generic competition, even in the absence of a patent barrier. If data
   exclusivity is imposed, generic companies face the choice of unethically
   repeating costly clinical trials on drugs, or waiting out the term of data
   exclusivity before registering a product. The TPP proposal mandates data
   exclusivity, and proposes to extend its coverage for biological products.
   4. *Not mandate patent linkage.* The processes of patenting a drug and
   obtaining regulatory approval are usually independent. The TPP proposal,
   however, requires countries to link these two processes and prohibits
   national drug regulatory authorities, charged with evaluating drug safety
   and efficacy, from approving generic medicines until patents have expired.
   This link delays generic competition and brings the responsibility of
   evaluating drugs’ patents under the purview of drug regulators.
   5. *Not mandate patent term extensions.* International law requires
   patents for pharmaceutical products to be granted for 20 years, but the TPP
   proposal requires countries to grant patent term extensions, prolonging
   high-priced monopolies and further delaying generic competition.
   6. *Not expand IP enforcement requirements. *Expanding enforcement to
   include higher damages thresholds, mandatory injunctions and increased
   authority for seizures by customs officials on the mere suspicion of an
   infringement. This interferes with a country’s ability to balance public
   health interests in enforcement disputes and leads to delays in the trade
   for pharmaceuticals.
   7. *Remove intellectual property from the Investment Chapter.* The TPP
   proposal gives pharmaceutical companies the right to sue governments that
   have regulations which reduce the companies’ expected profits. This action
   will take place in a private, supra-national tribunal. This restricts a
   country’s ability to structure legal and regulatory systems to best suit
   the public health needs of their population.


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Policy Director
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