Drug Pricing
September 15, 2026
8 min

International drug price comparisons: why they mislead, and how to do them properly

Why cross-country drug price comparisons usually compare different things, and a seven step routine that produces a defensible result.

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Table of contents
    Summary
    • 29 of 31 examined countries applied external reference pricing, so national prices are not independent observations.
    • The five errors: mismatched price level, currency unit, VAT treatment, list against paid price, and unequal coverage.
    • Germany caps the wholesale margin at 37.80 euro, applying from a manufacturer price of 1,200 euro upwards.
    • In four of the six most accessible countries, the manufacturer price is derived or estimated, not published.
    • Match on the national pack code, never on pack size, and record the match rate.

    Most international drug price comparisons are wrong before the first number is compared. Not because the data is bad, but because the two prices being compared sit at different points of the distribution chain, in different currencies units, with different tax treatment and different coverage. A Swedish pharmacy purchase price against a Polish manufacturer price differs by the wholesale margin before any real price difference appears. This article sets out the five errors that break cross-country comparisons, the mechanism that makes national prices depend on each other, and a routine that produces a defensible result.

    Why do national prices depend on each other at all?

    Because most European countries set their prices by looking at other countries. External reference pricing, sometimes called international reference pricing, takes the price of the same medicine in a defined basket of countries and derives a national maximum or reimbursement price from it. In a 2015 survey, 29 of 31 examined countries applied external reference pricing.

    The mechanics differ sharply, and the differences decide how one country's price travels:

    • The Netherlands calculate maximum prices from Belgium, France, Norway and the United Kingdom. Norway replaced Germany in that basket in 2020.
    • Norway sets the maximum price as the average of the three lowest prices from a basket of nine countries, which includes Germany and Austria.
    • Iceland references only Denmark, Finland, Norway and Sweden.
    • Latvia has capped the manufacturer price of prescription medicines at the lowest price in Lithuania or Estonia since 1 January 2025.
    • Luxembourg uses no basket at all. The price follows the country of origin, and 80 to 90 percent of imports come from Belgium.

    For a comparison this matters twice. A German price change propagates into Norwegian maximum prices, and a Norwegian price then feeds the Dutch calculation. Prices in Europe are not 30 independent observations.

    Error one: comparing different price levels

    The single most common mistake. Published price levels differ by country: Central and Eastern Europe and the Benelux countries regulate the manufacturer price, Scandinavia the pharmacy purchase price, and France, Spain, Portugal and Estonia publish the consumer price.

    Converting between levels is possible, but it is regulation, not arithmetic. In Germany the wholesale margin is capped at 37.80 euro, and that cap applies from a manufacturer price of 1,200 euro upwards. In Portugal and Spain the margin bands sit on the manufacturer price level, and reading them the wrong way round produces a deviation of up to 3.23 euro per pack in Portugal. In Croatia the published figures are margin ceilings, so a back calculation yields an upper bound of the manufacturer price, not a price.

    Where no formula exists, the honest label is estimate. For Denmark, Finland, the Netherlands, Sweden and Cyprus, a manufacturer level figure is reconstructed with a margin assumption borrowed from the Austrian price commission.

    Error two: the currency unit is not what it looks like

    Three traps, all silent:

    • Denmark publishes every price in øre, a factor of 100 against kroner.
    • Romania publishes in RON, although at least one national methodology document names EUR.
    • Bulgaria switched to the euro on 1 January 2026, and older rates appear in euro without any marker.

    A currency conversion applied on top of a wrong unit produces a number that looks plausible and is off by two orders of magnitude.

    Error three: tax treatment

    VAT on medicines differs across Europe and changes. Finland raised VAT on medicines to 13.5 percent on 1 January 2026, while the consolidated version of the relevant law still showed the older schedule. If one side of your comparison carries VAT and the other does not, the difference you measure is partly a tax rate.

    Error four: list price against paid price

    National lists carry list prices. They do not carry the discounts that are negotiated afterwards, and in several markets those discounts are confidential by design. Even the authority database EURIPID, which harmonises four price levels across roughly 26 countries, had not implemented net prices in the sense of actually paid prices as of 2022, although the European Parliament had called for them in 2017.

    The practical consequence: a list price comparison is a comparison of published policy, not of what a payer or a wholesaler actually pays. Say so in the output, and the comparison stays defensible.

    Error five: unequal coverage

    Two countries with the same number of rows can cover very different shares of their market. France's public database carries a price for 13,648 of 20,900 packs, because the remainder is not reimbursed. Spain's Nomenclátor covers roughly 20,500 of about 67,000 presentations and carries no manufacturer price at all. Malta does not regulate medicine prices and publishes no price list.

    Coverage also decides which segment you are measuring. A comparison built only on reimbursed products silently excludes the self pay and OTC segments, which in several countries is where price competition actually happens.

    A worked example: six countries at ex-factory level

    The countries where a comparison is defensible today are those with a clear legal position and a stable technical route. Six qualify: Belgium, Finland, France, Italy, Norway and Sweden. Here is what each one requires before the numbers are comparable.

    CountryWhat you start fromWhat you have to doResidual uncertainty
    BelgiumEx-factory, published directly, dailyNothing, the level is already correctNone on the level itself
    ItalyClasse H carries ex-factory directly, Classe A retailApply the verified factor for Classe A, use the monthly transparency lists for currencyMain lists can lag by months
    FranceConsumer price, grossBack calculate through the statutory marginsThe formula changes on 20 January 2027
    NorwayAIP and AUPUse AIP, no manufacturer factor is publishedNo proven route to manufacturer level
    SwedenAIP, dailyUse AIP, or estimate manufacturer level with an external marginManufacturer level is an estimate
    FinlandWholesale via Hila, consumer via KelaApply the 3 percent margin, then VAT at 13.5 percentManufacturer level is an estimate

    Read the last column before the numbers. In four of the six countries the manufacturer price is either derived through a statutory formula or estimated with an assumed margin. Only Belgium and the Italian hospital list publish it directly. A table that presents all six as if they were measured the same way is the error this article is about.

    What about pack size and identity?

    Prices sit on packs, so a comparison needs pack level identity. The national pack code is the load bearing key: PZN in Germany, CNK in Belgium, CIP13 in France, AIC in Italy, Vnr in the Nordics. Pack size is a check value.

    Three identity traps decide whether an automated match works:

    • In France, CIP13 is a valid GTIN-13 across all 20,900 packs.
    • In Norway, deriving a GTIN from the article number works for only 16.5 percent of 9,508 packs.
    • In Czechia the GTIN field is empty in all 69,759 records, and in Hungary it is filled in 0.6 percent of cases.

    Where pack size has to be parsed from free text, the parser must stop on ambiguity rather than guess. A wrong pack size turns a price per pack into a wrong price per unit, and price per unit is what most comparisons ultimately report.

    A routine that produces a defensible comparison

    1. State the question in price level terms. "Ex-factory price of the same pack in six countries" is answerable. "Drug prices in Europe" is not.
    2. Normalise to one level, using the national margin rules, and mark every derived value as derived.
    3. Check unit and currency per country before arithmetic.
    4. Match on the national pack code, verify with pack size, and record the match rate.
    5. Report coverage and date per country, in absolute numbers.
    6. Label list against net explicitly, and name the countries where confidential rebates are known to apply.
    7. Repeat on a fixed schedule, because update rhythms differ from daily to two or three times per year.

    Conclusion

    International drug price comparisons mislead when they hide their assumptions. The five errors above are all avoidable with information that is available before the comparison starts: which level, which unit, which tax, list or net, and how much of the market the file actually covers. External reference pricing then explains why the remaining differences are smaller than the headlines suggest, because the countries are reading each other's prices.

    Related reading: European Drug Pricing Database: how cross-border prices work and Pharma pricing Germany: how the system works, plus drug prices by country.

    pharmazie.com is the consolidated pharmaceutical data platform by DACON Datenbank Consulting GmbH that bundles 25+ specialist databases into a single search, exclusively for healthcare professionals. Price coverage focuses on the DACH region and a number of further EU countries, with more countries following in the coming months.

    Author Image
    Ursula Tschorn
    Ursula Tschorn is CEO of DACON Datenbank Consulting GmbH and has been building pharmaceutical information infrastructure since 1989. She writes on drug data standards, pricing regulation and market access in the DACH region.

    FAQ

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