The Hellenic Competition Commission (HCC) publishes the key findings of the mapping study on the conditions of competition in the market for Veterinary Medicinal Products (VMPs) for sheep and goats, focusing in particular on vaccines, antibiotics/anti-flammatory (hereinafter referred to as “antibiotics”) and antiparasitic drugs. The VMPs for sheep and goats were selected because these productive animal species constitute the largest part of the livestock population in Greece (excluding chicken) and because sheep and goat milk is exclusively used for the production of feta cheese. 

This mapping study is complementary to the HCC’s mapping of the animal feed production and marketing sector. The reference period for this study is January 2019-June 2024, while both mapping studies are part of the Authority's strategic goal to assess the conditions of competition in the agri-food sector in Greece and, in particular, in the supply chain of basic food products. The implementation of this strategy started in 2023 with the Authority's sector inquiry into six basic consumer goods at the retail level, including fresh milk. (see Sector Inquiry findings, HCC’s Newsletter-Issue 8, December 2023).

Mapping Results

The main conclusions regarding VMP importers, VMP wholesale stores and, in particular, pharmaceutical wholesalers, and issues concerning the operation of the sector in general, are set out below.

Regarding importers of veterinary medicinal products, the following observations can be made: 

The largest part of vaccines, antiparasitics, and antibiotics for sheep and goats in terms of value is imported and marketed in Greece by subsidiaries of foreign multinationals. The VMPs for sheep and goats falling within the above categories are mainly sourced from north-western European countries, notably the Netherlands (19.9%), Spain (19%), Belgium (18.8%), and France (12.6%).

The structure of importers' sales value for vaccines, antibiotics and antiparasitics for sheep and goats did not change significantly during the period considered (2019-first half of 2024). In 2023, sales in the above categories increased by 13.7%. Over time and without any significant changes, it appears that the largest percentage of imports of vaccines, antibiotics and antiparasitics traded by importers relates to off-patent products (2023: 81%).

Source: Company Data, Calculations Mapping & Research Unit- HCC

In the case of antiparasitics, generic drugs account for a larger share of sales than vaccines and antibiotics, but even in this category, most drugs sold by importers are branded off-patent products.

Regarding importers' sales in value per customer category, it is observed that importers of veterinary medicinal products for sheep and goats sell mainly to pharmacies (23%), veterinary practices for productive animals (20%), private veterinary clinics (18%), and pharmacies (15%). It is noted that direct sales to cooperatives and farms are limited. Α vast majority of sales of on-patent originator and generic VMPs for sheep and goats are directed towards private veterinary practices.

Source: Company Data, Calculations Mapping & Research Unit- HCC

Larger price spreads (i.e selling prices minus purchase prices) are observed for vaccines compared to antiparasitics and antibiotics, per unit of main active substance. Especially after 2022, the difference between purchase and sale prices shows a significant increase for antiparasitics and antibiotics. In general, there is a higher rate of increase in sale prices compared to the rate of increase in purchase prices.

Source: Company Data, Calculations Mapping & Research Unit- HCC

In terms of market concentration degree, in the broader categories of VMPs for sheep and goats, i.e., antibiotics, vaccines and antiparasitics, there is a moderate degree of concentration for antibiotics and antiparasitics (with the HHI index at 1,743 and 1,767, respectively) and a high degree of concentration for vaccines (HHI= 3,106). The picture changes if focused on a specific category of drugs according to the ATCvet code. Thus, it appears that there is a monopoly in specific codes (QG51, QJ51, and QI03) in the categories of antibiotics and vaccines, as well as a high degree of concentration per ATCvet code in the antiparasitic category. It should be noted that, in all ATCvet codes, importers’ market shares are identical to those of their suppliers. The only exception is one company, for the ATCvet code QP52, which has four suppliers.

Specifically for generics, in 2023, there is a moderate degree of concentration for the antibiotics category (HHI 1,684) and a high degree of concentration for vaccines (HHI= 10,000) and antiparasitics (HHI 2,489).

Regarding VMP wholesalers, the following observations can be made: 

The structure of the sales value of the VMP wholesalers, participating in the survey, for vaccines, antibiotics and antiparasitics for sheep and goats does not change significantly during the period of reference (2019-first half of 2024).

In 2023, 46% of sales are directed to private veterinary clinics, with the second largest percentage, 24%, going to pharmacies. These two categories account for 70% of sales, and this picture does not vary over time or according to product type.

Source: Company Data, Calculations Mapping & Research Unit- HCC

Overall, there are small spreads for each product category per unit of active substance. There are no significant horizontal sales between pharmaceutical wholesalers.

General issues identified:  

A. Complexity of the regulatory framework: The legislative framework is fragmented across multiple laws and decrees, making it difficult to understand and comply with, especially for small and very small entities.

B. Conflict of Interest Issues: Veterinarians may dispense prescriptions issued by themselves only for animals they treat (see Article 5(2)(c) of Law 2538/1997). The dual role of veterinarians ‒as prescribers and sellers of veterinary medicines at the same time‒ favors information asymmetry regarding the medicine prescribed and the existence of any cheaper alternatives. Livestock farms usually work with specific veterinary practices, so that each farm has its own veterinarian who is authorized to prescribe and dispense medication for its animals. It should be noted that even if the farmer goes to an independent retail store selling veterinary medicines, the restriction of Article 7(8) of Law 2538/1997 applies, according to which the person in charge of the store "is required to dispense veterinarians' prescriptions precisely and is not allowed to replace a veterinary medicinal product listed on the prescription with another of his choice."  

C. Restrictions on online sales (e-commerce): Online sales of veterinary medicines apply to non-prescription veterinary medicines.  Therefore, all prescription medicines for productive animals are excluded from the possibility of being sold via e-commerce.

D. Parallel imports: Parallel imports or exports of VMPs in Greece from pharmaceutical wholesalers are almost non-existent. The lack of parallel trade is thought to be linked to the need to comply with the labeling and language requirements of the destination country, combined with the low volumes absorbed by the Greek market. Although multilingual labeling is possible, in practice, medicines marketed in Greece are only available with packaging and instructions for use in Greek. The low quantities traded probably do not justify the relative financial investment on the part of wholesalers/distributors in repackaging units, nor the commercial interest in parallel imports in general. 

The adoption of multilingual packaging at European level, including Greek, could facilitate parallel trade by allowing the free movement of veterinary medicines between Member States.

For more details, see the attachment in PDF (in Greek).