Therapy

Center for Phage Research and Phage Therapy, Regensburg, Germany
Almost immediately after the discovery of bacteriophages by Frederik Twort and Félix d'Hérelle in 1915 and 1917, their potential for antibacterial therapy and prophylaxis in humans was recognized and applied. Bacteriophages provide the optimal conditions for this: High specificity, low toxicity, and self-maintaining and amplifying character. Renewed attention to the therapeutic potential of phages reflects growing concern about the emergence of antibiotic resistance and the prospect of a post-antibiotic era. However, modern phage therapy products must compete with today’s antimicrobial drugs, which includes the regulatory requirements for clinical use.

Recently, compassionate use of phages in cases, lacking therapeutic options (bacteria multiresistant against antibiotics) for serious or life-threatening infections has been used and occasionally published. Although there are currently few reference laboratories for the selection and testing of phages for clinical isolates, on-site testing is particularly advantageous in urgent cases. At the PCR new molecular tests to facilitate personalized phage therapy are developed.

Background Information

Phage Therapy for Multidrug-Resistant Infections: Medical Need and Regulatory Challenges

1. Prevalence of MDR Infections in Bavaria and Germany (2023)

Multidrug-resistant organisms (MDROs) cause tens of thousands of infections annually in Germany, especially in hospitals. An estimated 6% of all nosocomial infections are due to MDROs, equating to approximately 24,000–36,000 hospital-acquired infections per year. Including community-acquired cases, the total number of MDRO infections in Germany is estimated at around 54,500 annually. The following overview shows the main pathogens and their incidence:

Pathogen (MDRO)

Nosocomial infections/year (Germany)

Mortality rate (per 100,000 inhabitants)

MRSA (Methicillin-resistant S. aureus)

~11,000

~4.0

VRE (Vancomycin-resistant enterococci)

~4,000

~3.4

Multidrug-resistant E. coli

~8,000

~7.9

Multidrug-resistant K. pneumoniae

~2,000

~2.2

Multidrug-resistant P. aeruginosa

~4,000

~1.6

These five pathogens (the "ESKAPE group") account for the majority of severe MDRO infections. Bavaria, as the largest federal state, reflects national trends (e.g., a significant decline in MRSA rates but increasing problems with gram-negative pathogens). Each year, an estimated 9,700 deaths in Germany are directly attributed to MDRO infections. Including all cases where MDROs were at least involved, the number rises to up to 45,000 deaths annually.

2. Economic Impact: Additional Costs from MDRO Infections

MDRO infections impose substantial additional costs on the healthcare system. They often prolong hospital stays (by about five days on average), require more expensive treatments, and necessitate isolation measures. Studies estimate additional treatment costs of €5,000 to €20,000 per hospital-acquired MDRO infection. MRSA infections, for instance, incur costs nearly three times higher than comparable MSSA infections. An analysis by the Techniker Krankenkasse (TK) reported average excess costs of ~€17,500 per MDRO case. Recent calculations estimate even higher costs — up to €27,000 per patient — due to increasingly complex resistance patterns. This represents a 41% increase compared to 2018 and corresponds to an overall burden of ~€1.1 billion annually for German hospitals alone. Including all direct and indirect costs (rehabilitation, isolation, personnel, etc.), the total economic impact is estimated at €4 billion per year.

Main cost drivers of MDRO infections include:

  • Prolonged hospital stays and intensive therapy (e.g., use of reserve antibiotics),
  • Isolation measures (e.g., staff training, protective clothing, single rooms),
  • Diagnostics (e.g., pathogen identification),
  • Indirect costs (e.g., blocked beds, canceled elective procedures),
  • Intangible costs (e.g., psychological burden of isolation).

These additional costs are often not reimbursed. Under Germany’s DRG system, MDRO-related expenses are only partially covered. Health economic analyses emphasize that investments in MDRO prevention (e.g., hygiene staff, screening programs) are cost-effective.

3. Regulatory Barriers to Phage Therapy in Germany

Despite promising results in individual cases, phage therapy remains outside standard care in Germany. Multiple bureaucratic and regulatory hurdles currently limit its broader application against MDROs:

  • No approved medicinal product: Currently, no phage preparations are approved in Germany. Since phages are classified as medicinal products, they would require extensive clinical trial data on pharmaceutical quality, efficacy, and safety. Due to their host specificity, these requirements are difficult to meet.
  • Compassionate use only: In the absence of approval, phage therapy is currently only available via individual treatment attempts (compassionate use). This allows physicians to use phages when standard options fail, but such use is not intended for systematic data collection. There are no formal treatment guidelines; each application is experimental and requires utmost caution.
  • Manufacturing and quality standards: Phages must be produced under GMP conditions. There are very few approved production facilities for phages in Germany. An alternative is the production of patient-specific phage formulations by pharmacies ("magistral formula"), as is regulated in Belgium. While theoretically allowed in Germany, this pathway lacks infrastructure and clear regulatory support. The BfArM has signaled openness but demands high quality standards.
  • Lack of reimbursement: Without official approval and early benefit assessment, there is no legal entitlement to reimbursement by statutory health insurance. Currently, funding occurs only in exceptional cases — often via research projects or case-by-case decisions. Billing codes are also lacking in the outpatient setting. This uncertain reimbursement situation significantly limits access.
  • Stance of authorities and policymakers: Both regulatory agencies and professional societies acknowledge these hurdles. The BfArM has emphasized the need for new approval pathways or exemptions. The German Bundestag recommends further development of phage therapy as a response to antibiotic resistance — including support for clinical research, regulatory adaptation, and transitional solutions like magistral formulations.
  • Guidelines on phage therapy ("AWMF S2k Leitlinie Phagentherapie") in Germany are not expected to be published until November 2025 

These obstacles highlight that phages do not fit neatly into the existing pharmaceutical framework. Experts recommend a package of coordinated measures, including public funding programs, dynamic reimbursement models, add-on payments for hospital phage use, and international collaboration to establish phage banks and quality standards.

References

 Federal Ministry of Justice. (2010). Ordinance on the compassionate use of medicinal products (Arzneimittel-Härtefall-Verordnung) of 14 July 2010, last amended by ordinance of 6 July 2022. Federal Law Gazette, I, 935.

 Federal Ministry of Justice. (2006). Ordinance on the manufacture of medicinal products and active substances (Arzneimittel- und Wirkstoffherstellungsverordnung) of 3 November 2006, last amended by law of 23 October 2024. Federal Law Gazette, I, 2523.

German Bundestag. (2023). Bacteriophages in medicine, agriculture and food industry – Application prospects, innovation and regulatory issues (Report of the 18th Committee, BT-Drucksache 20/7600, 19 July 2023). Berlin: German Bundestag. Retrieved from https://dserver.bundestag.de/btd/20/076/2007600.pdf

Federal Joint Committee (G-BA). (2024). Off-label use – Prescribability of medicinal products in non-approved indications (Information page, as of December 2024). Retrieved from https://www.g-ba.de/themen/arzneimittel/arzneimittel-richtlinie-anlagen/off-label-use/

Kern, B.-R., & Rehborn, M. (2019). § 96 Medical standards. In B.-R. Kern & M. Rehborn (Eds.), Handbook of Medical Law (5th ed.). Munich: C.H. Beck.

Lipp, V. (2022). Compassionate use and medical research. In A. Laufs & C. Katzenmeier (Eds.), Medical Law (8th ed.). Munich: C.H. Beck.

Teklemariam, A. D., Al Hindi, R., Qadri, I., Alharbi, M. G., Hashem, A. M., Alrefaei, A. A., … Harakeh, S. (2024). Phage cocktails – an emerging approach for the control of bacterial infection with major emphasis on foodborne pathogens. Biotechnology and Genetic Engineering Reviews, 40(1), 36–64. https://doi.org/10.1080/02648725.2023.2178870

Willy, C., & Bröcker, F. (2023). Phage therapy in Germany – on the way to reintroduction into military medicine. Military Medical Monthly Journal, 67(6), 237–244. https://doi.org/10.48701/opus4-158

Scientific Services of the German Bundestag. (2023). Compassionate use – Current legal situation and practice (Status WD 9–3000–083/23, 19 December 2023). Berlin: German Bundestag. Retrieved from https://www.bundestag.de/resource/blob/986600/622476f3e4b0252f03ad816c34969c33/WD-9-083-23-pdf.pdf

World Medical Association. (2013). Declaration of Helsinki – Ethical principles for medical research involving human subjects (59th WMA General Assembly, Fortaleza 2013). Ferney-Voltaire: WMA. Retrieved from https://www.bundesaerztekammer.de/fileadmin/user_upload/_old-files/downloads/pdf-Ordner/International/Deklaration_von_Helsinki_2013_20190905.pdf