Road map and BAA market: forecasts and risks
The Action Plan (Roadmap) developed by the FAS of Russia «Promotion of Competition in Healthcare» (hereinafter the «Roadmap») was approved by Order of the Government of the Russian Federation No. 9-p of January 12, 2018. The Roadmap contains the regulatory proposals, some of which relate to the biologically active additives market (hereafter the «BAA»). In particular, paragraph 14 of the Roadmap indicates the need to improve the regulatory framework in the field of BAA circulation by «imposing a ban on the market authorization of BAAs and drugs with similar or confusingly similar names». According to the Roadmap, the relevant proposals are aimed at BAA-trafficking and consumers misleading interdiction. However, the introduction of complete bans may have unintended consequences in practice.