药品流通"两票制"政策实施后,低开高返的招商代理模式不复存在,靠佣金为企业提供营销服务的合同销售组织成为业界最认可的模式.欧盟药品流通监管的经验启示我们,代理活动本身并没有问题,代理和经销行为相互重叠才是造成我国药品流通行业混乱的原因.应尽快完善合同销售组织(或代理商)注册、审批、监管等配套制度,将合同销售组织等新兴流通主体纳入监管范围.%After the implementation of the two-invoice system, the investment agent model of low open and high return no longer exists, and the contract sales organization which relies on commission to provide marketing services to enterprises becomes the most recognized model in the industry. The experience of EU drug circulation regulation reveals that there is no problem in agency activity itself, but the overlapping of agent and distribution behavior is the cause of the confusion of drug circulation industry in China. The registration, examination and approval, supervi-sion and other supporting systems of contract sales organization (or agent) should be improved as soon as possible, and the contract sales organi-zation and other emerging circulation subjects should be brought into the scope of supervision.
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