Germany: CJEU rules on SPCs for combination products

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Germany: CJEU rules on SPCs for combination products

We recently reported on the opinion of the advocate general (AG) in the case CJEU (C-121/17) concerning supplementary protection certificates (SPC) and the question of when a product, which is not explicitly mentioned in the basic patent, is protected by the basic patent, according to Article 3 (a) of Regulation (EC) No 496/2009. While it has been clarified that infringement rules cannot be applied, it is still not clear which test should be used for assessing the requirement of Article 3(a). Recently, the CJEU issued a judgment on this case which interestingly differs on this point from the opinion of the AG.

In the underlying case, the validity of an SPC for the combination of tenofovir and emtricitabine, marketed as Truvada by Gilead, is questioned. The focus of the basic patent is on tenofovir while emtricitabine is reflected in the patent claims only by the term "optionally other therapeutic ingredients". The patent specification does not mention emtricitabine or any other active for combination therapy.

For the assessment of whether the product of the SPC is protected by the basic patent, the AG suggested a rather strict disclosure test, requesting that each of the active ingredients is "precisely and specifically identifiable" in the patent. The AG also explicitly rejected an assessment of whether the SPC product makes use of the "core inventive advance" of the protected invention as was proposed by the referring UK court.

In its decision, the CJEU both avoids the terminology of "precisely identifiable" and also does not agree with the AG in explicitly rejecting the core inventive advance test. Notably, while the AG did not distinguish between combination products and mono products, the CJEU explicitly limits the order of the judgment to combination products.

For the purposes of determining what is protected under Article 3(a), the CJEU seems to advocate a two-pronged test. Firstly, whether the combination of the active ingredients, in light of the description of that patent, makes use of the invention needs to be assessed. Secondly, each of those active ingredients must be specifically identifiable in light of all the information provided by the patent. For the combination of tenofovir and emtricitabine the CJEU considers the above requirements not fulfilled, but emphasises that this has to be decided by the national courts based on the national rules defining the extent of protection.

This can hardly be seen as a rejection of the considerations underlying the core inventive advance test and an endorsement of a strict disclosure requirement. It remains to be elucidated what is meant by "specifically identifiable" and whether different requirements apply for mono products and combination products. The two pending referrals directed to mono products will further sharpen the requirements of Article 3(a).

wunsche

Dr

Annelie Wünsche


Maiwald Patentanwalts- und Rechtsanwaltsgesellschaft mbH

Elisenhof, Elisenstr 3D-80335, Munich, GermanyTel: +49 89 74 72 660 Fax: +49 89 77 64 24info@maiwald.euwww.maiwald.eu

more from across site and SHARED ros bottom lb

More from across our site

Managing IP will host a ceremony in London on May 1 to reveal the winners
Abigail Wise shares her unusual pathway into the profession, from failing A-levels to becoming Lewis Silkin’s first female IP partner
There are some impressive AI tools available for trademark lawyers, but law firm leaders say humans can still outthink the bots
Lawyers at Simmons & Simmons look ahead to a UK Supreme Court hearing in which the court will consider whether English courts can determine FRAND terms when the licence is offered by an intermediary rather than an SEP owner
Firm says appointment of Jeremy Drew from RPC will help create ‘unrivalled IP powerhouse’, as it looks to shore up IP offering ahead of merger
Law firms are expanding their ITC practices to account for the venue’s growing popularity, and some are seeing an opportunity to collaborate with M&A teams
Erise IP has added a seven-practitioner trademark team from Hovey Williams, signalling its intention to help clients at all stages of development
News of prison sentences for ex-Samsung executives for trade secrets violation and an opposition filed by Taylor Swift were also among the top talking points
A multijurisdictional claim filed by InterDigital and a new spin-off firm in Germany were also among the top talking points
Duarte Lima, MD of Spruson & Ferguson’s Asia practice, says practitioners must adapt to process changes within IP systems, as well as be mindful of the implications of tech on their practices
Gift this article