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Executive Report on Strategies in Austria
ICON Group International, June 2007, Pages: 392


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How to Strategically Evaluate Austria

Perhaps the most efficient way of evaluating Austria is to consider key dimensions which themselves are composites of multiple factors. Composite portfolio approaches have long been used by strategic planners. The biggest challenge in this approach is to choose the appropriate factors that are the most relevant to international planning. The two measures of greatest relevance are “latent demand” and “market accessibility”. The figure below summarizes the key dimensions and recommendations of such an approach. Using these two composites, one can prioritize all countries of the world. Countries of high latent demand and high relative accessibility (e.g. easier entry for one firm compared to other firms) are given highest priority. The figure below shows two different scenarios. Accessibility is defined as a firm’s ease of entering or supplying from or to a market (the “supply side”), and latent demand is an indicator of the potential in serving from or to the market (the “demand side”).
Framework for Prioritizing Countries

Demand/Market Potential Driven Firm







Relative Accessibility

Accessibility/Supply Averse Firm








Relative Accessibility
In the top figure, the firm is driven by market potential, whereas the bottom figure represents a firm that is driven by costs or by an aversion to difficult markets. This report treats the reader as coming from a “generic firm” approaching the global market - neither a market-driven nor a cost-driven company. Planners must therefore augment this report with their own company-specific factors that might change the priorities.

Latent Demand and Accessibility in Austria

This report provides an extremely detailed overview of factors driving latent demand and accessibility in Austria. Latent demand is largely driven by economic fundamentals. But, latent demand only represents half of the picture. A country may at first sight appear to be attractive due to a high latent demand, but it is often less attractive when one considers at the macro level how easy it might be to serve that entire potential and/or general business risks.

Chapter 2 deals with macro-accessibility. While accessibility will always vary from one company to another for a given country, the following domains are typically considered when evaluating macro-accessibility in Austria:
Openness to Trade in Austria
Openness to Direct Investment in Austria
Local Marketing and Entry Strategy Alternatives
Local Human Resources
Local Risks

Across these domains, a number of not-so-obvious factors can affect accessibility and risk. These are also covered in Chapter 2, which is presented from the perspective of an American firm, though it is equally applicable to most firms entering Austria. This chapter has been authored by local offices of the U.S. Government. I have included a number of edits to clarify the provided information as it relates to the general strategic framework.

In Chapter 3, I summarize the economic potential for Austria over the next five years for hundreds of industries, categories, and products. The goal of this chapter is to report my findings on the real economic potential, or latent demand, represented by Austria when defined as an area of dominant influence. The data presented are the result of various spatial econometric and time-series forecasting models which, for each category presented, are applied to forecast and allocate latent demand across all countries of the world and major distribution centers or centers of dominant influence within each country. This is accomplished knowing that economic fundamentals (e.g. income) generally vary from one country to another within a given country over time. In this chapter, I report the allocation for each category for Austria as an area of dominant influence in Europe and, potentially, the world.

The report concludes with trade indicators for Austria. Often, the amount of trade flowing into and out of a country is a strong indicator of trading partners, trade openness, and related latent demand. Trade indicators are purely statistical in nature. Although international trade is not a direct measure of latent demand, it does provide an indicator of general market conditions with respect to trade flows and trade openness in Austria.

As a whole, this report presents a strategic assessment of Austria by considering an extremely broad set of factors affecting both latent demand and accessibility, as outlined in the following chapters.

MACRO-ACCESSIBILITY IN AUSTRIA
Economic Fundamentals and Dynamics

Austria is a small, open economy, dependent on foreign trade and closely linked to the economies of other European Union (EU) member states, particularly Germany.  Foreign trade and investment ties with Central and Eastern European countries also play an increasingly important role.

Austria’s 1995 accession to the EU had a positive impact on foreign investment, inflation, and economic growth by providing access to the single market and by fostering liberal policies to promote competition and dismantle protectionism.  As one of the eleven founding members of Economic and Monetary Union (EMU), Austria adopted the common “Euro” currency, which fully replaced the Austrian Schilling on March 1, 2002 and is the only legal tender in Austria.  With the Euro, Austria no longer faces exchange rate risk with many of its most important foreign trading partners. 

Foreign investors as well as local businesses still must cope with rigidities, barriers to market entry, and an elaborate regulatory environment in certain sectors.  Progress was made in streamlining the permit process, in deregulation and liberalization, particularly in the telecommunications, electricity and gas sectors.  However, there is room for improvement.  The government intends to move its economic reform program forward with the goal of making the Austrian economy more flexible and creating a more competitive business climate, but faces stiff opposition in Parliament and from various interest groups, depending on the issue.

The economic opening of the Central and Eastern European (CEE) countries has had a stimulative effect on Austria’s economy.  Austrian firms have invested sizable sums in and continue to move labor intensive low-tech production to these countries.  Austrian banks have established extensive networks in the CEE countries.  Austria serves as an economic gateway to the CEE, attracting EU firms seeking convenient access to newly emerging markets.  However, as a location for foreign investment and regional headquarters, Austria is increasingly under pressure from CEE competition for such investment.  The Austrian government, as well as business interests, support the EU’s eastern enlargement, but was able to negotiate transition periods for free movement of labor and of services with the enlargement candidates to minimize competitive impacts on the Austrian labor market.

Infrastructure Development

Austria has a modern communications and transportation infrastructure.  An extensive highway system provides good access to major Western European industrial centers and ports.  The Austrian railroad offers efficient passenger and freight service.  Modernization plans will include higher-speed rail service in the near future.  However, both highway and railroad connections to Austria’s neighbors in Central and Eastern Europe, the Czech Republic, Slovakia and Hungary, need considerable improvement and upgrading.  Although Austria has convenient air service to major destinations world-wide, the only carrier offering direct flights from the Vienna International Airport to major U.S. destinations is the Austrian national carrier “Austrian Airlines.”

The Austrian telecommunications network is sophisticated and reliable, and even though prices declined in past years, in some areas is still expensive by U.S. standards.  The use of mobile phones is particularly widespread in Austria, with 81% of the population using a mobile phone in 2002 (second in Europe after Norway).

In the first quarter of 2003, about 57% of the Austrian population (above the age of 14) had permanent Internet access (only a slight increase on last year’s level, but above European average), 48 % from home, 29% (in 2002) are using broadband technologies.  Internet shopping is far less popular but also increasing.  25% are saying that they “have already shopped over the Internet Only 5% purchase goods on-line regularly.  Internet access is becoming increasingly important among businesses, with 85% of all firms and companies currently on-line and 65% with their own homepage.

Political Risks
Economic Relationship with the United States

Austria has enjoyed good bilateral relations with the United States over the past several decades. Most of Austria’s political leaders and many Austrians recognize and appreciate the essential role played by U.S. economic assistance under the Marshall Plan after World War II, and the role played by the United States in promoting the conclusion of the Austrian State Treaty of 1955. This treaty ended the four-power occupation following World War II and established Austria as an independent state. The generations that recall these events, however, are aging.

Austria maintains an embassy at 3524 International Court, NW, Washington, D.C. 2008 (Tel. 202-895-6700). Consulates are located in New York, Chicago and Los Angeles, with honorary consulates in Atlanta, Boston, Buffalo, Charlotte, Columbus, Denver, Detroit, Honolulu, Houston, Kansas City, Miami, New Orleans, Philadelphia, Pittsburgh, San Francisco, San Juan, Seattle, St. Louis and St. Paul.

Major Political Issues Affecting Business Climate

The government consists of a center-right coalition between the conservative People’s Party (OVP) and the populist Freedom Party (FPO).

Austria has based its foreign policy on the concept of neutrality since the 1955 State Treaty.  In 1995, Austria joined NATO’s Partnership for Peace and the EU. Austria’s participation in evolving EU security and defense cooperation has necessitated some redefinition of neutrality.

Austrian leaders emphasize the unique role the country still plays as a link between West and East and as a frontier state in EU enlargement. Austria is active in the United Nations and in UN peacekeeping efforts including SFOR and KFOR.

Vienna is the headquarters of important international organizations like the Organization for Security and Cooperation in Europe (OSCE), the International Atomic Energy Agency (IAEA), the UN Industrial Development Organization (UNIDO), the Comprehensive Nuclear-Test-Ban Treaty Organization (CTBTO), the International Institute for Applied Systems Analysis (IIASA), the Organization of Petroleum Exporting Countries (OPEC), the Wassenaar Arrangement (WA), and a branch office of the European Patent Office (EPO).

Civil Society

In the postwar decades, the so-called “Social Partners” dominated the Austrian political-economic system.  They include the mandatory membership Labor Chamber (for all employees), Economic Chamber (for all businesses) and Agriculture Chamber. These bodies have had both a formal and informal consultative role on major economic policy decisions, in order to defuse potential social and economic conflicts.   While this led to virtually no strikes in Austria in the postwar era, the Social Partnership was criticized for slowing or blocking needed reforms.  OVP-FPO governments have gradually shifted social and economic decision making away from the social partners to Parliament.  However the social partners continue to insist on their consultative role on reforms, and the unions have stepped up protest actions and strikes in response to government reform initiatives.
Politics sometimes intrudes on business decisions. Government procurement decisions often indicate a pro-EU bias, according to U.S. firms, especially in defense procurements.

Non-governmental organizations (NGO’s) are becoming more influential in many political fields in Austria, ranging from the environment and consumer protection to human rights issues.

Austria maintains a constant exchange of business representatives, students, cultural groups and tourists with the countries of Central and Eastern Europe. The Austrian government and various Austrian organizations, including business and labor, provide assistance and training to support constructive changes in this region.

The Political System

Austria is a parliamentary democracy. The Chancellor is the Head of Government and the President is the Head of State. The President - who is elected every 6 years directly by the people - formally gives a mandate to the prospective Chancellor to form the government.   The Federal Assembly (Parliament) is composed of two houses - the National Council (Nationalrat) or the lower house, and the Federal Council (Bundesrat) or upper house. Virtually all legislative authority, however, is concentrated in the National Council, whose 183 members are elected according to a system of proportional representation and party affiliation, including a threshold of 4 percent for any party to enter parliament. Elections must be held every four years. The National Council may dissolve itself before the end of four years by a simple majority vote, or the Federal President may dissolve it on the recommendation of the Chancellor. The Federal Council consists of 62 members elected by the legislatures of the nine provinces. It is effectively restricted to reviewing legislation passed by the National Council.

The highest courts of Austria’s independent judiciary are the Constitutional Court, which has jurisdiction over constitutional matters; the Administrative Court, which handles bureaucratic disputes; and the Supreme Court, for civil and criminal cases. Justices of all three courts are appointed by the president for life terms.

Austria is a federal system in which the nine Laender (provinces) have a considerable share of political and administrative power, including welfare and environmental matters, and ownership of land. Although most authority still rests with the federal government, the provinces are responsible for the implementation of the majority of federal laws and the supervision of local administrations. The provinces are headed by governors elected by the provincial legislatures on the basis of the popular vote.  They meet regularly in an informal governors’ conference, which makes recommendations for federal legislation concerning the provinces.

Marketing Strategies
Distribution Channel Options

Austria enjoys a multitude of distribution and sales channels, including traditional wholesale distribution and retailing, catalog and e-commerce channels, direct marketing methods, franchising, joint ventures and other licensing agreements.

It may be useful to think of Austria in terms of the following five marketing or distribution areas:
Vienna and vicinity: the business and government center and most populous part of Austria;
Pre-alpine provinces: Styria, Lower Austria, and Upper Austria, where most industrial and agricultural production takes place;
Alpine provinces: Carinthia, Tyrol, and Salzburg, which rely heavily on tourism;
Vorarlberg in the far-western Alps on the Swiss border, which has a small but wealthy population; and
The eastern flatlands of Burgenland:  the least developed part of Austria.

Many Austrian firms distribute to the neighboring markets of Central and Eastern Europe at the wholesale level, and some Austrian retail chains are beginning to build up networks in those countries as well. By the same token, German and international retail giants have been building up their presence in Austria over the past several years.

Pricing Issues

Even when concentrating on importers of U.S. products, there is no uniform product pricing structure in Austria.  Importers may receive their products from central distribution centers in the European Union (EU), directly from the United States, or from third markets.  The number of resellers depends on the size of the market and the nature of the product.  The one thing that is to be noted is the Value Added Tax (VAT) of 20% for most items, which is tacked onto the price and ultimately paid by the consumer.

Retail Trends

Austrian retailing is well into a long overdue modernization.  Austria’s accession to the EU in 1995 was a major impetus for change, bringing reforms in the regulatory environment, giving consumers the freedom to shop in neighboring EU countries, and opening the borders completely to the retail giants of neighboring Germany.  What was once a highly regulated and protected environment that supported thousands of small shops and boutiques (with restricted opening hours, a limited selection, and high prices) is now slowly becoming a modern, consumer-oriented and market-driven retail environment that favors major chains and mega-stores.  Price competition is accelerating, and concentration in most retail sectors is high and increasing as the giants either merge or buy each other out in their battle for market share.  The losers are the small shops and boutiques that make up over 80% of all retail Austrian enterprises, but account for a rapidly shrinking market share.

Operating Hours
One of the most important limitations on consumer behavior has been the slow liberalization of Austria’s strictly regulated shopping hours. Despite incremental improvement, Austria still has the most restrictive shopping hours in all of Western Europe. Most stores may only stay open a maximum of 66 hours per week, and these hours must be between 6:00 AM and 7:30 PM Monday through Friday, and 6:00 AM to 5:00 PM on Saturdays. A new federal law recently passed the Austrian parliament whereby stores have the possibility to stay open between 5:00 a.m. and 9:00 p.m., at the discretion of each provincial government.  With a few exceptions, primarily for tourism areas, stores must stay closed on Sundays and holidays.  A few brave storeowners in the Vienna area have challenged the Sunday closing requirement, but stiff fines have prevented this movement from gaining momentum. As a result, consumers have less time to spend on comparison or recreational shopping.

Convenience Stores
An exception to the restricted opening hours exists for so-called convenience stores, which are allowed to sell food items for immediate consumption outside the standard opening hours.  Gas stations with attached shops in particular have discovered this to be a wonderful source of additional income with attached shops.  However, these establishments are not to exceed 80m2 in size and the only products they are allowed to sell outside the standard opening hours are food and drink for immediate consumption, as well as items that could conceivably be needed for travel.

Direct Marketing
Within limits set by Austrian law, telephone and direct mail solicitation are very much in evidence in Austria. Some U.S. companies, including Tupperware and Amway, have established themselves in the Austrian market with multi-level marketing systems.

Catalog Shopping
Catalog shopping sales have been stagnating for the past several years, in fact, ever since the first and most consequential relaxation of store opening hours.  Sales are still a respectable $1 billion annually. Market leaders are Quelle/Neckermann and Otto/Universal, both German origin, with a share of over 70%.  Newcomer La Redoute is still building market presence.  The most growth is seen in smaller specialty catalogs that offer hard to find luxury and specialty goods.

Electronic Commerce
E-commerce is the fastest growing shopping form in Austria.  The average Internet user is younger, wealthier and better educated than the population at large, with the lowest usage rates among the elderly over 60.  The most common items bought are books, magazines, and hotel rooms or vacations. 

Agents and Distributors

Qualified Austrian agents and distributors can be found for nearly every kind of product.

Franchising Activities

Franchising is still a relatively small factor in the Austrian economy, though it continues to demonstrate reputable growth.  It is estimated that franchising accounts for less than 5 percent of total retail sales (compared to around 50 percent in the United States).  The past ten years have seen the total number of franchise systems in Austria increase dramatically, from under 50 at the end of the 1980’s to over 300 today, though growth rates have been stagnating the past few years as the economy has slowed.

Around half of the franchise systems operating in this country are of local origin.  The top foreign participant in the Austrian franchising economy is Germany, with around 25 percent of the franchise systems, followed by the United States, with about 10 percent of all the systems operating in Austria.  While most German operations either set up a company headquarters in Austria or franchise direct over the (EU internal) border, most American companies choose to expand their operations in Austria through a master franchise partner, a solution that has had mixed results.

Some of the best prospects for franchising include business and personal services, schooling and training, and specialty retailing.

The Austrian Franchise Association collects data, maintains an informative web site, and co-organizes seminars as well as a yearly trade show:

Österreichischer Franchiseverband
Mag. Waltraud Frauenhuber
Bayerhamerstraße 12/1
A-5020 Salzburg
Tel: +43-662-874236-0
Fax: +43-662-874236-5
E-mail: oefv@franchise.at
Web site: www.franchise.at

Joint Ventures and Licensing

Joint ventures and licensed production arrangements in Austria offer U.S. firms several advantages, including free access to the European Union market, improved access to Central and Eastern European markets, reduction of transportation costs to European destinations, and high quality production.  Joint ventures may be formed as companies, partnerships, or other legal entities.

Austrian companies are receptive to licensing arrangements, especially as a source of technology.  Royalty and license fee payments may be freely transferred out of Austria.

In addition to the assistance offered by the U.S. Commercial Service in Vienna, U.S. firms seeking joint venture or license partners in Austria will receive valuable information from the Austrian Government’s investment organization:

Austrian Business Agency
Opernring 3, A-1010 Vienna, Austria
Tel. (43 1) 588 58-12
Fax: (43 1) 586 8659
Contact Point for North America: Richard Schuhmertl
Web site: www.aba.gv.at

Creating a Sales Office

Establishing a business in Austria is a bureaucratic maze, despite recent efforts to reduce the paperwork involved.  Some regions have moved to set up one-stop shops for entrepreneurs, but the jury is still out on how much of the red tape these new offices can really eliminate. 

Most business activities in Austria are regulated, and require that a separate application be made for a business license (Gewerbeschein) and registration in the commercial register (Firmenbuch).  Evidence of proficiency is required for most businesses; usually a passing score on an examination or evidence of prior experience in the field is sufficient.  For business activities that do not require proof of proficiency, the business license is granted automatically upon registration of the business.

There are several options available to the investor when deciding on the legal form of an Austrian office, including public corporations, limited liability companies, limited or unlimited commercial partnerships, silent partnerships, branches of foreign enterprises, cooperative societies, and sole proprietorships.  Most foreign-owned businesses choose to operate as a limited liability private company (Gesellschaft mit beschraenkter Haftung or Ges.m.b.H.).

Selling Strategies

Possibly due to the many years of shortage during World War II and the post-war period, and certainly due to their monarchical authoritarian history, the typical buyer-seller relationship in Austria can best be characterized as “demand-pull”, i.e., the customer wants or needs something and is thus at a disadvantage. The seller has the item that the customer wants, and is therefore in a position of power. That several sellers may be competing for the same customer’s business, or that the seller needs customers in order to turn his goods into revenue, is known in theory but this knowledge has not quite trickled down into the interpersonal relationships between sales staff and their customers.

Though there is certainly no need to imitate this typical Austrian style of sales, it should indicate some limits to what could be characterized as typical American practices.  Highly choreographed and high-pressure sales techniques, for example, or hearty friendliness to someone just met, are absolutely alien to Austria, and are an almost guaranteed way to bring an early end to negotiations.

A second consideration is the price/quality question.  Ever more sectors are becoming heavily price-driven, a development that has accelerated with the economic slowdown of the past several years.  Where once quality and personal relationships played a larger role in purchasing decisions, focus has shifted to the bottom line.

Advertising and Trade Promotion

The economic slowdown has left its mark on the local advertising industry after nearly two decades of high growth.  The distribution of advertising Euros has not changed much.

Print Media
Daily papers, regional publications, magazines, industry publications and other print media account for more than half of all advertising spending.

Television
TV accounts for around 22% of the advertising pie.  It is only in 2003 that the first private Austrian television network started operations - most viewers watch one of the two state television channels.  Currently, 42% of Austrian households also receive satellite programming and 37% are hooked up to cable. Thus advertising in Germany is being consumed in Austria, and, to some extent, special Austria advertising windows are being built into cable programming.

Radio
Radio advertising accounts for just over 7% of advertising spending, a significant fall from the boom years of 1997 and 1998 when Austria liberalized access to radio frequencies and the first private radio stations went on the air.  All currently operating private radio stations are owned by large media concerns.  Austrian National Broadcasting operates several national and regional radio stations, including the national market leader.

Other Advertising Venues
Direct mail accounts for around 8 percent of advertising spending, and billboard advertising remains a constant feature of Austrian marketing with around 7 percent of advertising spending.

Truth in Advertising
A Consumer Forum has been established in the Austrian Economics Ministry.  The forum comprises representatives of political parties, business organizations, labor unions, and business associations.  A subcommittee for commercial advertising examines posters, TV, radio and newspaper ads, and entire sales campaigns, with regard to their truthfulness, information value and ethnic sensitivity.  The forum can initiate proceedings against advertisers who make false claims.  Anyone transgressing established commercial usage laws may be sued.  The government recently lifted the regulation that prohibited comparative advertising, thus enabling advertisers to make direct comparisons between their products and services and those of their competitors.
Trade Promotion
Annually, between 100-150 national and international trade fairs representing many industry sectors are organized in Austria.  Most of the Austrian fairs are open to the general public and thus take on an advertising function.  Austrian importers also attend the major European trade fairs.

Pricing Issues

Austrian prices remain among the highest in the European Union, reflecting high social costs of labor (including mandatory health insurance and pension fund contributions for employees), extensive agricultural subsidies, the small size of the market, and high taxes.  The value-added tax (VAT) on most products and services is 20 percent.  Special taxes are levied on luxury goods, fuel, drinks, tobacco and other items.  These taxes quickly add up and should be taken into consideration when pricing products for sale in Austria.

Supplying Customer Service

Customer service and support in the consumer industries is improving with EU integration.  Starting on January 1, 2002, the basic warranty for consumer purchases was increased from 6 months to 2 years, and the burden of proof reversed (the customer is no longer required to prove that he did not break the item, rather, the store must show that he did).  Despite this improvement, the unlucky customer who purchases a defective product may still not be able to bring it back to the store for replacement, but must wait weeks while the product is shipped for repair.  Publicizing American-style guarantees and customer service is slowly gaining popularity as a marketing tool.

Business customers demand a different level of support, and most wholesalers or distributors offer excellent support.  If a part on a machine breaks, the customer will demand that it be replaced or repaired within 24 hours, which may present logistical problems for smaller U.S. suppliers who cannot warehouse replacement parts in Europe.

Public Sector Marketing

The Austrian Government adheres to the WTO (GATT) Agreement on Government Procurement.  Austria’s Federal Procurement Law was amended in January 1997 to bring its procurement legislation in line with EU guidelines, particularly on services.  Austria does not have Buy National laws, but as with any political decision, the economic impact of the contract is taken into consideration.  In addition, some major contracts are negotiated by invitation, and limited tenders and offset requirements are common in defense contracts.

Intellectual Property Risks

Austria is a member of all international intellectual property rights agreements.  To begin the process of registering a patent in Austria or in the EU, contact the Austrian Patent Office:

Oesterreichisches Patentamt
(Austrian Patent Office)
Kohlmarkt 8-10, A-1014 Vienna, Austria
Tel. (43 1) 534-24-0                 
Fax. (43 1) 534-24-110
Web site: www.patent.bmwa.gv.at
A list of patent attorneys is available through the Austrian Patent Attorney Chamber:

Oesterreichische Patentanwaltskammer
Museumstrasse 3
A-1070 Vienna, Austria
Tel. (43 1) 523 4382                
Fax: (43 1) 523 4382-15
E-mail: pak@patentanwalt.at
Web site: www.patentanwalt.at

Hiring Local Counsel

Some Austrian law firms can conduct business in English and are familiar with U.S. law.  Some are members of the bar in the United States. 

Import and Export Regulation Risks
Customs Regulations and Tariff Rates

Austria is a member of the European Union EU and as such the Austrian customs regime is based on the “TARIC” (integrated tariff of the EU), determined in Brussels.

The TARIC can be searched by country of origin, Harmonized System Code, and product description on the interactive Web site of the Directorate-General for Taxation and the Customs Union. The TARIC is updated annually in April.

EU Import tariffs vary depending on the product, however, for most U.S. exports the tariffs are relatively low.  In fact, over half of all products from non-EU countries enter without any tariff.  The average EU tariff level for manufactured goods is relatively low at 3.5%, but some goods are taxed at a higher rate.  For example, passenger cars and office machines have duties of about 10%.  For certain kinds of shoes and special motor vehicles, the rate may be up to 18%.  U.S. exporters can obtain EU import tariff rates at the following Web sites: http://europa.eu.int/comm/taxation_customs/databases/database.htm or www.taric.com

Non-Tariff Trade Barriers

In general, there are no non-tariff barriers for U.S. companies entering the Austrian market. Nevertheless, some U.S. pharmaceutical companies have complained about restricted access to the Austrian market. A U.S firm seeking to market a drug in Austria must first obtain approval from the Austrian Social Insurance Holding Organization (Hauptverband der Oesterreichischen Sozialversicherungstraeger). According to critics, the non-transparent procedures by which the Hauptverband approves drugs for r


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