# Germany access note — NeuralCIM / NeuroEPO

This is a regulatory/source-check note, not legal or medical advice. Families should confirm with a German physician, pharmacist, German customs/Zoll, and the relevant medicines authority before paying for or carrying any medicine.

## Is NeuralCIM authorised in Germany/EU?

- I did not find a German/BfArM or EU/EMA marketing-authorisation trail for **NeuralCIM / NeuroEPO plus** for Alzheimer’s.
- NeuralCIM is a recombinant erythropoietin-derived biologic product, but the EU-authorised epoetin products I found are anaemia-related products such as NeoRecormon/Binocrit-type epoetins, not NeuralCIM for Alzheimer’s. Do not treat those as interchangeable.

## If a German resident orders it by mail/subscription

- Germany’s Federal Ministry of Health says medicines not authorised/registered in Germany are generally subject to an import/bringing-in prohibition under §73(1) AMG.
- Mail-order to German consumers is only allowed for authorised/registered medicines and only from permitted EU/EEA online pharmacies meeting German comparable safety standards.
- I did **not** find a verified legal route for a German resident to simply subscribe online and have NeuralCIM shipped from Cuba.

## If a traveller brings it into Germany personally

- German customs/Zoll and BMG describe a travel-necessities exception: travellers entering Germany may carry medicines for their usual personal need, generally up to **three months’ supply** according to the recommended dose.
- This travel exception does not allow counterfeit medicines, doping/prohibited substances or narcotics without their stricter paperwork. NeuralCIM does not appear to be a narcotic, but composition/status should be checked before travel.
- Carrying a medicine personally after a Cuba clinic prescription/evaluation may be a different situation from mail-order import. It still requires prudent documentation: prescription, diagnosis/medical certificate, original packaging/label, invoice, dose instructions, and ideally German/English translation.

## German pharmacy individual import route

- BMG/Zoll describe another exception: a German pharmacy may order a non-Germany-authorised foreign medicine for an individual patient under §73(3) AMG, if conditions are met. Those include small quantity for an individual order, lawful marketability in the source country, and no identical/comparable German-authorised product for the indication.
- For products from third countries outside the EU/EEA, BMG says a medical/dental prescription is always required. A German physician/pharmacy would need to handle this; it is not a direct consumer subscription model.

## Practical bottom line for Germany

- **Clinic treatment in Cuba:** Germany does not appear to prohibit a person from travelling to Cuba for treatment, but medical risk, documentation and re-entry/import rules matter.
- **Bringing some back personally:** possibly allowed only within the German travel-necessities rule, usually max three months’ personal supply, with documentation and no prohibited/counterfeit product issue.
- **Ongoing German access/subscription:** not verified as allowable. The safer formal route would be a German doctor + German pharmacy individual import review, not a direct online order from Cuba.
- **Use inside Germany:** should be supervised by a physician; NeuralCIM is not a casual supplement and the Cuban label/trial route describes prescription/medical supervision.