Statement at the fifth meeting of the open-ended Intergovernmental Working Group (IGWG 5) on the WHO Pandemic Agreement

On behalf of the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA), we appreciate the opportunity to share comments for consideration during the Fifth Meeting of the Intergovernmental Working Group on the Pandemic Agreement.

We remain concerned that the "stacked" and overlapping obligations within the current PABS architecture risk disincentivizing research at the very moment when the world needs strong and agile R&D ecosystems. The system's complexity, combined with remaining uncertainty on scope, creates barriers that could slow innovation rather than accelerate preparedness.

Regarding the definition of Pathogens with Pandemic Potential (PwPP), the latest Bureau text ties the definition directly to the draft Pandemic Agreement's definition of a pandemic emergency. As drafted, a pandemic emergency is determined through broad criteria on geographic spread, excessive pressure on health systems, socioeconomic disruption, and the need for rapid international action. These concepts are important but lack scientific precision and allow significant interpretive flexibility, both technical and political. Without measurable epidemiological thresholds, the definition could be applied inconsistently or overly expansively.

This ambiguity produces real and immediate challenges. It is not clear that technology platforms, commonly used bacterial families, or non-acute pathogens are explicitly carved out. There is a genuine risk that materials essential for everyday scientific work could inadvertently fall within scope. Materials employed strictly as R&D tools should be excluded, and only pathogens used as the basis for countermeasures targeting genuine pandemic-capable threats should be in scope.

Predictability is essential for both companies and laboratories. Developers must know well in advance whether their R&D activities will fall under PABS, rather than discovering this only once an emergency is declared or when approached to sign agreements at a late stage.

For these reasons, the PABS expert group in charge of developing the Pathogen list must include manufacturers and relevant scientific expertise, apply rigorous and transparent scientific criteria and operate independently from political considerations. List updates must occur at intervals that support long-term planning rather than through frequent or unpredictable cycles.