PHOENIX Pharma SE
PHOENIX group
The PHOENIX group is active in the pharmaceutical wholesale and pre-wholesale business areas with 214 sites across 29 EU countries supplying pharmacies, doctors, and medical institutions with medicines and health products.
ID: 108461232380-63
Lobbying Activity
Response to Update of EU rules on audiovisual media services
9 Dec 2025
To whom this may concern, PHOENIX group welcomes the Commissions initiative aimed at improving the cross-border circulation of media content and protecting viewers. To educate and inform patients about the patient-centered care they can receive in their local pharmacies, PHOENIX group uses influencer marketing on Instagram and TikTok in several markets where we are active with our pharmacy operations notably in Baltics, Italy, Switzerland and Norway. Against this background, we were pleased to see in the Call for Evidence that the Commission will particularly look at professional content creators on video sharing platforms, and how commercial communications by these should be treated. To delineate between, on one hand, trusted, professional content and on the other, fearmongering / click bait for profit content, PHOENIX group calls for the updated EU rules on audiovisual media services. For more detail on our concrete proposals, please consult the attached file. We remain at your disposal for any additional questions you may have. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Digital package – digital omnibus
13 Oct 2025
To whom this may concern, PHOENIX group welcomes the Commissions initiative aimed at setting digital simplification agenda for the years to come and bringing immediate relief to businesses across the EU. PHOENIX group is the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries. With the ever-increasing digitalization, we rely heavily on the EU digital policy to set the right context for ensuring patient safety and access to medicines in the EU. That said, we strongly believe that some EU digital rules should be revised to simplify administrative procedures whilst maintaining highest levels of patient safety and access in the world. Therefore, we propose 1. Simplifying rules on cookies and tracking technologies 2. Simplifying European Digital Identity Framework 3. Simplifying European Data Governance Act For more details, please find attached our submission. We remain at Commission's disposal for any further clarifications and engagement. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Union prevention, preparedness, and response plan for health crises
6 Oct 2025
To whom this may concern, PHOENIX group welcomes the initiative of the European Commission aimed at developing a Union-wide plan under Regulation (EU) 2022/2371 to strengthen preparedness and response to serious cross-border health threats. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers it essential to support further development of EU policy on this matter. Against this background, we would like to share several recommendations (please see attached) to ensure successful creation and implementation of the Union-wide response plan for health crises. The last but not least, PHOENIX group offers its extensive supply chain expertise and stands ready to support Commission and Member States in providing further Medical Counter Measures to patients and Member States in need. We remain available for any further questions from the Commission and look forward to continuously sharing our expertise on this subject. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Targeted revision of the EU rules for medical devices and in vitro diagnostics
2 Oct 2025
To whom this may concern, PHOENIX group welcomes the commitment of the European Commission to revise EU rules on medical devices and in vitro diagnostics. We especially welcome the focus of the targeted revision on protecting patient health whilst making the medical device sector more agile in a challenging global environment. Against this background, PHOENIX group considers that the Commission should, among other producer relevant issues, focus on challenges experienced by distributors of critical medical devices to bring meaningful outcomes for European patients. For more details please consult the attached contribution. We remain at your disposal for any questions you may have. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Review of the Digital Markets Act
10 Sept 2025
To whom this may concern, PHOENIX group fully supports keeping DMA implementation (with some smaller amendments as per the attached document) uninterrupted as a matter of priority in the EU digital policy landscape. We remain available for any further questions the Commission might have and look forward to continuous engagement on the subject matter. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to EU cardiovascular health plan
3 Sept 2025
To whom this may concern, PHOENIX group welcomes the Commissions initiative aimed at addressing the major health burden of European citizens - cardiovascular diseases. We especially welcome the fact that the initiative will look at improving prevention, early detection and diagnosis. However, we regret to see that the Call for Evidence does not mention any specific role of community pharmacies as the first point of care for millions of European patients. It remains unfortunately widely unknown that pharmacists perform a number of other services incl. those of relevance for cardiovascular health along the entire patient journey. These include, but are not limited to blood pressure checks, cholesterol & glucose screening, cardio-check services, medication use review, smoking cessation programs etc. For more detail about our position and examples of how pharmacists can support the EU cardiovascular health plan, please consult the attached document. PHOENIX group remains available for any further questions from the Commission and looks forward to continuous engagement on this subject matter. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Clean corporate vehicles
29 Aug 2025
To whom this may concern, Please find attached PHOENIX's group position on the Clean Corporate Vehicles. PHOENIX group remains available for any further questions from the Commission and looks forward to continuous engagement on this subject matter. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full response5 Feb 2024
To whom it may concern, PHOENIX group welcomes the proposed Delegated Act amending training requirements for pharmacists under the Directive 2005/36/EC of the European Parliament and of the Council as regards minimum training requirements for the professions of nurse responsible for general care, dental practitioner and pharmacist (i.e. Professional Qualifications Directive). We particularly applaud a gradual shift to more clinical focus of the pharmacist training. In our capacity as the largest European employer of pharmacists with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers it of utmost importance to support continues updates of the training requirements for pharmacists to fit patient and community pharmacy needs. Against this background, we are pleased to share our position with the European Commission and interested stakeholders (please see attached). We look forward to engaging further with the interested EU stakeholders as a part of this legislative process. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Evaluation of the Regulation on serious cross-border threats to health
22 Jan 2024
To whom this may concern, PHOENIX group welcomes the initiative of the European Commission to evaluate the early implementation period of the Serious Cross-Border Threats to Heath Regulation. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers it essential to support further development and enforcement of the EU legislation around serious cross-border health threats by, among others, sharing our position with the Commission and interested stakeholders. Please find our contribution attached. In general, PHOENIX group supports delineating the evaluation of the Serious Cross-Border Threats to Heath Regulation from the ongoing HERA review. Our contribution to the evaluation of Serious Cross-Border Threats to Heath Regulation focuses specifically on joint procurements of medical countermeasures for cross-border health threats performed by HERA (Article 12 of the Regulation). We look forward to the continious engagement with the European Commission and interested stakeholders on the issue as a part of the ongoing evaluation. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods
15 Jan 2024
To whom it may concern, PHOENIX group welcomes the initiative of the European Commission to evaluate Regulation 2019/515 on the mutual recognition of goods lawfully marketed in another Member State of 19 March 2019. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers mutual recognition of goods as essential to the successful enforcement of the free movement of goods as enshrined in the EU treaties. Against this background, we are pleased to share our position (please see attached) with the Commission and interested stakeholders on this subject. PHOENIX group remains available for any further questions from the Commission and looks forward to continuous engagement as a part of the review process. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Review of the Health Emergency Preparedness and Response Authority (HERA)
10 Jan 2024
To whom it may concern, PHOENIX group welcomes the initiative of the European Commission to review the implementation of HERAs operations before 2025 deadline set in the Article 8 of the Commission Decision C(2021)6712 of 16 September 2021 establishing the HERA. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers it essential to support further development of the HERA and its health security related activities across the EU by sharing our position with the Commission and interested stakeholders. Please find our contribution attached. We look forward to engaging further with HERA and the European Commission as a part of this ongoing review. Kind regards, Gavrilo Nikolic Head of Public Affairs
Read full responseResponse to Evaluation and revision of the general pharmaceutical legislation
3 Nov 2023
To whom this may concern, Please find attached PHOENIX group contribution to the European Commissions public consultation on the Revision of the EU general pharmaceuticals legislation. PHOENIX group applauds the European Commission for reviewing and updating the outdated European pharmaceutical legislation for the benefit of European patients. In our capacity as the largest European integrated healthcare provider with 224 sites in the business areas of pharmaceutical wholesale and pre-wholesale across 29 European countries and with more than 3,200 pharmacies in 17 European countries, PHOENIX group considers it essential to support further development of the legislative process by sharing our position with the Commission and interested stakeholders. Kind regards, Gavrilo Nikolic Head of Public Affairs (on behalf of the PHOENIX group)
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