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The authors argue that the European Commission's Strategic Approach to Pharmaceuticals in the Environment is insufficient to address the risks of pharmaceutical pollution and antimicrobial resistance (AMR). They highlight that AMR causes over 25,000 deaths annually in the EU and costs the economy more than €1.5 billion. To address these threats, the letter proposes five specific measures: increasing supply chain transparency to prevent double standards in developing countries, expanding Good Manufacturing Practice (GMP) to include compulsory environmental criteria for overseas factories, requiring compulsory environmental risk assessments (ERA) for all human and veterinary medical products, adding pharmaceuticals to the Environmental Quality Standards (EQS) Directive, and establishing a mandatory EU monitoring system for antimicrobials and AMR microorganisms in the environment.

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  • Antimicrobial resistance (AMR) is estimated to cause more than 25,000 deaths per year in the EU and results in annual economic losses exceeding €1.5 billion due to productivity losses and healthcare costs.
  • The authors propose that the European Commission should mandate transparency across the pharmaceutical supply chain and expand the Good Manufacturing Practice (GMP) framework to include environmental criteria, enabling the control of discharges at overseas factories that supply the EU market.
  • The letter calls for compulsory environmental risk assessments (ERA) for all human and veterinary medical products, including those authorised before October 2005, and suggests that the absence of harmful environmental effects should be a requirement for authorisation.
  • The authors urge the European Commission to set concentration limits for pharmaceuticals under the Environmental Quality Standards (EQS) Directive and to implement a mandatory EU-wide monitoring system for antimicrobials and AMR microorganisms in the environment.

Cite the original document

APA
Changing Markets Foundation (2019). 2019-04-10_Joint_letter_EC_FINAL copy. https://changingmarkets.org/wp-content/uploads/2023/10/Joint_letter_in_reaction_to_the_Strategic_Approach.pdf
Chicago
Changing Markets Foundation. 2019-04-10_Joint_letter_EC_FINAL copy. 2019. https://changingmarkets.org/wp-content/uploads/2023/10/Joint_letter_in_reaction_to_the_Strategic_Approach.pdf.
Wikipedia
{{cite press release |author=Changing Markets Foundation |title=2019-04-10_Joint_letter_EC_FINAL copy |date=10 April 2019 |url=https://changingmarkets.org/wp-content/uploads/2023/10/Joint_letter_in_reaction_to_the_Strategic_Approach.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{changingmarketsfoundation201920190410jointletterecfinal, author = {{Changing Markets Foundation}}, title = {{2019-04-10\_Joint\_letter\_EC\_FINAL copy}}, publisher = {Changing Markets Foundation}, year = {2019}, month = apr, url = {https://changingmarkets.org/wp-content/uploads/2023/10/Joint_letter_in_reaction_to_the_Strategic_Approach.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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