DISTINGUISHED REPRESENTATIVES OF THE NATIONAL CONGRESS OF BRAZIL,

and to whom it may concern,

The European Foundation of Traditional Chinese Medicine (FEMTC) is an international institution created in 1989 that, as a private foundation, its main goals are the promotion, dissemination, teaching, research and defence of the practice of Chinese medicine at a national and international level, under the criteria of quality and scientific rigour. Its mission is to help normalize this millenary discipline in the legal, teaching and assistance framework, ensuring that Chinese medicine is recognized in different countries and at the university level.

The Foundation is supported by important and prestigious institutions of Chinese medicine. Initially, it was created by Chinese and Spanish institutions, although today, it has reached collaboration agreements and has joined different prestigious international institutions around the world, working for the same objective as the FEMTC: recognition, development, internationalization and standardization of Chinese medicine.

The field of Integrative Medicine is a sector of emerging health sciences. In the majority of developed and developing countries, there is a large percentage of the population which uses Complementary Medicines.

In countries such as the United Kingdom, Germany, Belgium, the Netherlands and the Nordic countries, natural and complementary medicine is being incorporated into traditional health structures. For example, 90% of pain treatment services in the United Kingdom and 70% in Germany include acupuncture among the treatments they provide. The European Agency for the Evaluation of Medicines works on the quality, safety and efficacy of plant-based medical products and established a Working Group on these products, back in 1997.

Brazil is a world reference in the area of integrative and complementary practices, in basic health care. It is a modality that invests in prevention and health promotion, with the aim of preventing people from getting sick.

In addition to this, when deemed necessary, in Brazil the Integrative and Complementary Practices (PIC) can also be used to relieve symptoms and treat people who already have some type of disease. Under a close and consensual look and supported by WHO guidelines, the Ministry of Health approved, through Ordinance GM / MS 971 of May 3, 2006, the National Policy for Integrative and Complementary Practices in Health (PNPIC).

“Around the world, traditional medicine is the main pillar of the provision of health services, or its complement (World Health Organization)”

The process of integration of both Western and Traditional Medicines, allopathic and holistic, has led different organizations to invest human and economic capital to investigate the impact it could have on the health and Social Security of many countries. In 1998, the European Union completed a COST project (European Cooperation in Science and Technology) on non-conventional medicine. Several governments participated, including Spain, with the objective of demonstrating the possibilities, limitations and significance of complementary medicines, establishing a common scientific framework, harmonizing legislation and helping to control healthcare costs.

In January 2010, the CAMbrela project was launched, a pan-European research network on natural therapies, which has financed more than 1.5 million euros through the EU's Seventh Framework Program. The working groups that form CAMbrela focus on terminology, the legal framework, the needs of patients, the role of natural therapy treatments in health systems and research methodology.

In January 2014, the CHETCH project was initiated, in the specific field of acupuncture and Chinese medicine, funded by the EU, with a budget of € 788,000, in which Spain has participated.

It is also important the creation of the ISO/TC 249 Technical Committee on TCM of the International Organization for Standardization (ISO), which has published 40 international standards on acupuncture and Chinese medicine, and is working on another 46, currently under development, is also significant.

It is worth highlighting the indications of the World Health Organization in this regard and the explicit desire to incorporate the Complementary Traditional Medicines at the world level (WHO traditional medicine strategy: 2014-2023): “Around the world, traditional medicine is the main pillar of the provision of health services, or its complement (WHO) ”.

Traditional Complementary Medicines are an important and often underestimated part of health care. It is practised in almost every country in the world, and demand is increasing. Traditional medicine of proven quality, safety and efficacy help to ensure that all people have access to health care.

We must also bear in mind that the current ICD-11 project (International Classification of Diseases, 11th Revision), agreed at the meeting of the EB (the Executive Board of WHO) recently held at the WHO headquarters in Geneva (February 2019) and approved at the WHO General Assembly (May 2019), includes a section 40 on Traditional and Complementary Medicine.

70% of health expenditure is reimbursed based on the information in the mentioned ICD. This WHO decision will help the spread of Complementary Traditional Medicines and its inclusion in ICD-11 is “a powerful tool for health care providers, placing these therapies as a legitimate product” for insurers. This WHO action regarding Complementary Traditional Medicines will have a significant impact worldwide.

Health Sciences professionals who work under the prism of Integrative Medicine, within their framework of competencies, are doctors with orthodox university training who add to this complimentary training in other models of medicine and merge techniques and procedures in their clinical work.

Chinese medicine, and Acupuncture as part of it, "is a total sum of knowledge, techniques and procedures" that aim to provide a solution, from a holistic approach to imbalances in human health.

It is an ancient science whose practice has been effective since time immemorial throughout the world. Over the years and scientific and medical advances, not only it has gained relevance in the environments that called it into question, but it has also proven its effectiveness through scientific evidence confirming that it is an effective, quality, safe and effective medicine.

In the past, at certain times and scenarios, the normal development of scientific evidence was conditioned, but nevertheless it has not been an obstacle to the existence of numerous studies and conclusive scientific evidence, such as:

The study prepared by the acupuncture doctors Antonio Alfaro and Alicia López, "Scientific basis of acupuncture", where scientific evidence is expressed that supports the technique of acupuncture and Chinese medicine.

Referring to data from this study, the International Health Commission defined by consensus in 1997 that acupuncture is effective for osteoarthritis and myofascial pain, (5/6 studies reported a significant effect on the relief of chronic myofascial pain).

The articles of various authors that the Society of Medical Acupuncture of Spain shows us in relation to different clinical trials practised on the technique of acupuncture are also notable.

For example, the Acupuncture clinical trial for cervical pain is of special relevance, which in its systematic review indicates that: Cervical pain is one of the three most frequent pains of the skeletal muscle system. Acupuncture is sometimes used as an alternative to the more traditional treatments for musculoskeletal pain ... Acupuncture treatments appear to be safe and the only possible adverse effects were minor, transient and benign, and they were pointed out in the trials ... Individuals with chronic cervical pain who received acupuncture showed, above average, greater pain relief, immediately after treatment and in the short term than those who received false treatments. Individuals with chronic cervical pain with irradiation symptoms in the arms that received acupuncture showed, on average, greater pain relief, in the short term than those on the waiting list.

However, if we refer to the last few years, for purely enunciative purposes, it should be highlighted:

1. When “Acupuncture” is entered as a keyword in the PubMed search engine, 29,039 scientific articles appear in English, of which 15,057 are from the last 10 years, 8,474 are from the last 5 years, 4,113 are RCT (randomized controlled trial reports) and 1,474 published in leading clinical journals.

2. Acupuncture (and Chinese Medicine) is regulated, both in terms of the official nature of their studies, and their activity as a health profession, not only in China and its area of influence, but also in countries such as Chile, most states from USA, Australia, Germany, Switzerland, Portugal, etc.

3. There is an ISO Technical Committee (ISO/TC 249), which is developing standards to ensure the quality, safety and efficacy and efficiency of Acupuncture (and Chinese Medicine).

4. The World Health Organization, in its 2014-2023 strategy, states: “provide support to member states to take advantage of the possible contribution of traditional and complementary medicine (including acupuncture and Chinese medicine) to health, wellness and people-centred health care…”.

5. A research project has just been completed, which has lasted 4 years, funded by the European Union, in which Spain has participated, on Acupuncture and Chinese Medicine, called CHETCH.

6. In November of 2018, the eighth anniversary of the inclusion of the MTC Acupuncture and Moxibustion in the Representative List of the Intangible Cultural Heritage of Humanity of UNESCO was celebrated at the UNESCO headquarters in Paris. During this event the “Paris Declaration on Acupuncture” was approved: Also on November 2018, a week later, the “Rome Declaration on Acupuncture" was approved during the celebration of the World Congress of Chinese Medicine”: Previously, one month earlier, on October 24, 2018, President Trump signed the HR6 project, which had obtained sufficient votes for approval by the two Houses of Congress, for which it was included for the first time officially to Acupuncture in the US Federal Health Insurance System.

7. In addition to scientific journals on Acupuncture (and Chinese Medicine), beyond any doubt (some in collaboration with internationally renowned Groups such as Elsevier Group), Acupuncture and Chinese Medicine are practiced in reference hospitals, such as the Sloan Kettering Memorial (one of the most prestigious in oncology in the USA), Children's Hospital Los Angeles, or the permanent Kaiser Group, to name a few. These disciplines are also taught in a multitude of prestigious universities in Western countries, in addition to Asians and there are many investigations underway around the world.

WHO strongly recommends the regulation of Traditional and complementary medicine (T&CM) and their integration into the National Health Systems in the WHO Traditional Medicine Strategy: 2014-2023, in response to the needs and challenges identified by the Member States.

The use by the population of the T&CM reaches, according to the WHO, levels between 20% and 75% (which have ever used it) and between 7% and 30% (which have used in the last year), depending on the countries and continues to increase year after year.

There is also a high level of user satisfaction. It follows that both for its frequency of use by the public, and for the need to determine the quality and safety of patients, its regulation is absolutely necessary.

In recent years T&CM have been regulated in most of the United States, Canada, Chile, Nicaragua, Australia, Portugal, Germany, Hungary, South Africa, China (new regulation), the two Koreas, Vietnam and other countries in Southeast Asia; there is also self-regulation in England, Holland, Nordic countries; and it is in the process of regulation (more or less active) in Italy, France, Brazil, Argentina, Panama, Spain, etc.

The vast majority of health professionals and non-health professionals agree on the need for the alleged regulation.

The global WHO report on traditional and complementary medicine 2019 will be focused on address the gap in reliable, credible and official data of Member States in the area of T&CM. This report reviews the overall progress in T&CM over the past two decades and is based on contributions from 179 WHO Member States. It provides valuable information for policymakers, health professionals and the public to capitalize on the potential contribution of T&CM to health and well-being.

Regarding how the regulation should be, we find that the current trend is a model similar to Portugal or Australia, which have been the last ones to regulate, but with the addition that it should also regulate the training and professional qualification in Acupuncture of doctors and all other health groups.

For natural therapies and medicines we understood, as happened in Australia and Portugal (taking into account in addition to other regulations such as China, as a country of origin, USA, etc.) higher and/or undergraduate studies will be established (Bachelor's degree), with its postgraduate degrees, masters and doctorates, which can be accessed with the same requirements as any university career in the area of Health Sciences. Moreover, for Western doctors and other health professionals, we propose postgraduate and/or masters of qualification and specialization.

We understand that, with the Acupuncture Regulation, Brazil will take a great step to improve the quality of training and professional studies, as well as facilitate access to research and quality care for Brazilian citizens.

Brazil has already done excellent public work with integrative and complementary practices since its implementation throughout its Public Health System so that acupuncture will be a historic achievement for Brazil and its people.

We also express our support for the work of the representatives of the Federation of Acupuncturists of Brazil (FENAB) who are working tirelessly to promote this Regulation in their country.

For this reason, we send this public letter to the representatives of the National Congress of Brazil, as support to adopt this initiative and approve the Regulation of Acupuncture in your country, as soon as possible.

We remain at your entire disposal to cooperate selflessly to the best of our ability, in this important responsibility that, as representatives of the citizens of your country, corresponds to you.

Ramon Mª Calduch

Madrid, August 29, 2019