Oireachtas Joint and Select Committees

Wednesday, 28 September 2022

Joint Oireachtas Committee on Agriculture, Food and the Marine

General Scheme of the Veterinary Medicinal Products, Medicated Feed and Fertilisers Regulation Bill 2022: Discussion

Mr. Ray Doyle:

Yes. The terminology they are using is "comparable products" the farmer could be offered. This was one of our early asks with the Department in the development of the NVPS. Even at our most recent meeting a number of weeks back, it still had not been addressed. I am told that they are now focused on it. We are greatly alarmed that this could be greatly abused. For example, if a veterinary practitioner was to prescribe a product that was only available through veterinary channels, we would be effectively out of the market because there would be no generic alternative. What I mean by this is, the prescription must have the active ingredient, the percentage of it, the administration mode, and maybe the withdrawal period. We are concerned that the potential for abuse would be great in that the percentage could be unique to veterinary channels and we would not have any available comparable product to offer, even though the active ingredient might be the same for. For example, there are a large number of generic type products available for certain ivermectin-based products. If, however, one created a product with a 3.16% weight-for-volume percentage, and it was only sold through veterinary channels given by the manufacturing company, nobody would have it. Licensed merchants would not have access to it. They would only have potentially a 5% product or 10% product, but that would not be comparable according to the NVPS. We have asked the Department clearly that this requirement for the percentage needs to be removed, and that it would just be the active ingredient as well as the other parameters that should be on it, to ensure that the lack of competition does not arise. I believe the Deputy had another question.