Reference Pricing in Azerbaijan: Structure, Process and Key Implications for Pharmaceutical Market Access
Standard Pathway
Reference pricing is the central mechanism used by Azerbaijan’s Ministry of Health (MoH) and the Tariff Council to regulate medicine prices. The system ensures transparency, affordability and alignment with international price levels, while creating predictable conditions for pharmaceutical manufacturers entering the Azerbaijani market.
This article provides a detailed overview of how reference pricing works, how prices are calculated and approved, and what companies should expect when launching or registering medicines in Azerbaijan.
1. Regulatory Framework and Authorities
Reference pricing in Azerbaijan is governed by several key public bodies:
Ministry of Health (MoH) / Analytical Expertise Center (AEC)
Evaluates registration dossiers
Verifies pricing documentation
Provides recommendations for regulatory approval
Tariff Council of the Republic of Azerbaijan
Final authority for the approval of medicine prices
Publishes the official list of regulated wholesale and pharmacy prices
State Service for Antimonopoly and Consumer Market Control
Oversees compliance with pricing rules
Monitors behavior of wholesalers and pharmacies
Since 2015, Azerbaijan has operated a fully regulated pricing system, covering both prescription (Rx) and most over-the-counter (OTC) medicines.
2. Core Principle of Reference Pricing
Azerbaijan applies an External Reference Pricing (ERP) methodology:
the price of a medicine is determined by comparing its price with the prices in a defined basket of reference countries.
Reference Country Basket
Although periodically updated, the basket commonly includes a broad mix of EU countries and regional markets, such as:
France, Germany, Italy, Spain
United Kingdom
Greece, Portugal, Poland, Hungary, Bulgaria, Romania
Additional neighboring markets may be reviewed depending on dossier justification
Main Pricing Rule
Azerbaijan establishes the maximum wholesale and pharmacy selling prices based on the country of manufacture and ERP analysis. Prices are adjusted for:
Manufacturer’s ex-factory price
International logistics and customs considerations
National wholesale and retail margins, calculated according to Cabinet of Ministers Decree №209 (June 3, 2015)
This creates a clear, formula-driven pricing structure with minimal room for variation.
3. Price Calculation Method
Step 1 — Manufacturer Price Verification
The Marketing Authorization Holder (MAH) submits:
Ex-factory price certificates
Invoices or declarations from reference countries
CPP or proof of registration/marketing (where applicable)
Step 2 — ERP Benchmarking
The Tariff Council evaluates:
The lowest available price in the reference basket
Prices for identical strengths, pharmaceutical forms and pack sizes
Whether the product is marketed or only registered—a critical factor for the Recognition Procedure
Step 3 — Setting National Prices
Wholesale margin - Calculated as per Cabinet of Ministers Decree №209, based on ex-manufacturer price
Retail margin- Calculated as per Cabinet of Ministers Decree №209, based on ex-wholesaler price
VAT - 18% VAT applied
This results in a transparent, standardized pricing formula, ensuring that all market players operate under identical rules.
Step 4 — Tariff Council Approval
The Tariff Council:
Confirms the final maximum selling price
Publishes it on the official Tariff Council portal
Makes the price binding for all pharmacies, distributors and wholesalers
4. Price Revisions & Re-Evaluations
Azerbaijan may revise or re-evaluate prices in the following cases:
Exchange rate fluctuations exceeding official thresholds
Manufacturer request for upward or downward correction (rare and strictly justified)
Emergence of new reference country pricing data
Changes in packaging, pack size or pharmaceutical form
Recognition procedure dossiers requiring alignment with EU-marketed packs and prices
5. Implications for Pharmaceutical Companies
Advantages
Predictability: Clear, rule-based pricing environment
Transparency: ERP methodology minimizes subjectivity
Market trust: Regulated pricing prevents excessive retail markups
Equal competition: Uniform rules for all market entrants
Challenges
Lowest-price rule may significantly restrict margins
If the product is not marketed in the manufacturing country, the Recognition Procedure becomes impossible—a frequent issue for EMA-approved but non-launched products
Limited flexibility to adjust prices based on clinical value, innovation or unmet medical need
Packaging and labeling challenges when the home market does not commercialize the product
Reference pricing in Azerbaijan creates a transparent and predictable environment for pharmaceutical manufacturers, but it also requires careful planning and accurate documentation. Companies must understand the ERP methodology, the lowest-price rule, pack requirements and regulatory pathways to ensure successful market access.
Manufacturers who prepare early and collaborate with experienced local partners can navigate the system efficiently and ensure timely, sustainable access for patients.
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