Germany: AG provides an advisory opinion on Article 3(a) of the SPC Regulation

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

Cookies Settings

Germany: AG provides an advisory opinion on Article 3(a) of the SPC Regulation

At the end of April 2018, Advocate General (AG) Wathelet handed down an advisory opinion regarding the first of three recent referrals to the CJEU (C-121/17). This concerns the interpretation of Article 3(a) of Regulation (EC) No 469/2009.

In the main proceedings, Teva and others challenged the validity of Gilead's SPC/GB05/041 covering a composition containing tenofovir disoproxil (TD) and emtricitabine. The composition is used in the prevention and treatment of HIV and is marketed by Gilead under the trade mark Truvada.

The supplementary protection certificate (SPC) was granted based on the marketing authorisation and claim 27 of EP 0 915 894 B1, which relates to a pharmaceutical composition comprising TD and optionally other therapeutic ingredients.

Against this background, the referring UK court asked the CJEU which criteria needed to be applied in order to decide whether a product is protected by a basic patent in force and proposed applying the core inventive advance test to Article 3(a) of the regulation.

The AG emphasised the importance of the claims in determining whether a product is protected while rejecting the further assessment of whether the product constitutes the core inventive advance of the basic patent. According to the AG, this assessment could be confused with the criteria determining whether the invention is patentable, which is different from the question of product protection under Article 3(a).

The fact that a product falls within the scope of protection of a basic patent under Article 69 EPC does not necessarily mean it is protected by the patent under the regulation. The AG summarised that a product is protected within the meaning of Article 3(a) if it would have been obvious to a skilled person at the priority date of the basic patent, that the product (in a combination, each active ingredient in that combination) was specifically and precisely identifiable in the wording of the claims.

Since the term "optionally other therapeutic ingredients" would constitute the only identification of emtricitabine in the claims of the basic patent, the AG considered that the "specific and precise identification" criterion is not fulfilled. Although the opinion is non-binding, if followed, it might mean that EU authorities take a stricter approach to Article 3(a) than they have taken to date.

Since the opinion provides little guidance on what is meant by "specifically and precisely identifiable" regarding products defined by generic terms, it remains to be seen whether the CJEU will follow the AG's opinion and/or provide more concrete guidance on the interpretation of Article 3(a) of the regulation.

Sybille Pfender


Maiwald Patentanwalts GmbHElisenhof, 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

IP boutique Petillion represented IKEA in the dispute, which concerned the use of the multinational’s trademarks in an immigration-focused campaign. The firm tells Managing IP how it secured the outcome
The Pizzeys-Griffith Hack integration was designed to create a stronger Australian IP platform but with several ex-Pizzeys principals now gone, the deal's success may depend on where clients place their trust
Thomas Lonsdale and Hsu Min Chung of HGF explore the practical impact of the EPO’s Enlarged Board of Appeal’s decision in G1/25 and its interplay with G1/24
The firm’s recent IP hire and launch of a new robotics industry group signal an effort to capture work emerging from AI entering the physical world
Another firm sets up shop in Dallas, bringing its patent disputes capabilities to one of the US’s busiest litigation venues
Entrepreneurial IP lawyers are still launching specialist firms, but increasingly with larger teams, broader coverage and greater infrastructure than the boutique model once implied
Jevon Louis explains how Covid led to a focus on local clients, discusses why mediation is successful in Singapore and reflects on the growing demand for AI advice
An increase in instructions from domestic companies and litigation for international clients are driving success for the Chinese IP firm, according to two lead partners
Ankur Sangal said he wants his team, nearly 30-strong already, to respond to a growing demand for specialist, commercially focused IP advice in a ‘rapidly evolving’ Indian market
As AI adoption accelerates across corporate IP departments, Simon Webster, president of IP at Clarivate, argues that success will depend less on technology alone and more on data quality, workflow design, and organisational readiness
Gift this article