Joint Nordic Procurement – 2028

FGL, the Swedish Association for Generic Medicines and Biosimilars, welcomes the opportunity to comment on the proposed joint Nordic procurement.

FGL’s starting point is that regional procurement is preferable to national procurement. We oppose a general move towards centralised Nordic procurement. Centralisation risks excluding smaller and newly established suppliers and reducing the number of companies remaining in the market. If a single supplier serves several countries, a supply failure also becomes harder to manage. Local tenders by the Swedish regional authorities allow more suppliers to remain active and provide alternative sources of supply.

FGL recognizes the objective of making the combined Nordic market more attractive to suppliers and thereby improving long-term availability. However, a larger aggregated procurement does not in itself guarantee stronger security of supply. If centralization results in fewer awarded suppliers, lower commercial viability for alternative suppliers or increased dependence on one supply chain across several countries, the effect may instead be greater market concentration and increased vulnerability.

For each product, the procurement authorities should therefore assess not only the number of bids received, but also the likely impact on supplier diversity and continued market participation throughout the contract period and after the contract has ended.

There may, however, be exceptions. Joint Nordic procurement can be appropriate for products with small volumes, particularly critical medicines where demand in individual countries is insufficient to attract suppliers or maintain availability. The purpose should be to make continued supply commercially viable. Joint procurement should not replace functioning competition or be used to extend the lowest price in one country across the Nordic region.