Is CoWIN's Lack of Interoperability With EU Green Pass Behind UK-Covishield Row?

The issue of international acceptance of COVID vaccine certificates has become a controversy. Image used for representational purposes. 

(Photo: Shruti Mathur/ The Quint)

We are yet to see a month since the pandemic began without some new controversy taking over the news cycle. And one of the contenders for the month of September 2021 is the kerfuffle over the international acceptance of vaccine certificates.

This is not the first time that vaccine certificates have been an issue. Many international travellers will remember filling out immigration forms confirming that they have not visited countries that have yellow fever, and if they have, they have been properly vaccinated before travel and they have a vaccine certificate to prove it.

Travel Restrictions Across the World

Almost all countries have imposed travel restrictions of varying degrees virtually through the entirety of 2020, and most of 2021. Now, with vaccination rates looking better by the day – at least for the more affluent nations – these restrictions are being progressively relaxed.

The degree of relaxation varies with each country, and that, for a variety of reasons. The EU Green Pass is a system in the European Union for all European Medicines Agency (EMA) authorised vaccines, ie., the ones administered by EU member nations.

What about citizens from non-EU nations who wish to travel to EU member states? The Green Pass currently allows for such travel if two conditions are met. The first condition is that the traveller must be vaccinated by an EMA authorised vaccine. The second condition is that there must be a certificate of vaccination in a form acceptable to the EU, which can be verified.

Both conditions come with an exception: the vaccine must either be an EMA authorised vaccine, or EU member states can also choose to allow those travellers who are fully vaccinated with vaccines that are on the WHO Emergency Use Listing process.

The certificate of vaccination is only acceptable from certain countries whose vaccine certification system is interoperable with the EU Green Pass system. Guidelines that laid out the interoperability requirements were put in place in January 2021, building out on discussions held between the European Commission and Member States. These discussions started in November 2020.

CoWIN Not Recognised by EU Green Pass System

What is the current status where the second condition is concerned?

Sixteen nations today have reciprocity with the EU Green Pass system. Within the EU, COVID vaccination certificates from these sixteen states and territories are accepted by, and have the same status as, the EU Digital COVID certificate. And that cuts both ways: these sixteen states and territories accord the same status to the EU Digital COVID certificate.

Sadly, CoWIN is currently not recognised by the EU Green Pass as being interoperable and that has meant that the vaccination certificates issued by CoWIN aren’t generally recognised in the EU.

What is important to note is that EU member states only have to accept vaccination certificates for those vaccines that have received EU marketing authorisation. Member states may decide to waive restrictions for travellers who have received another vaccine, but they are not obliged to.

It is in the exercise of this flexibility that some EU member states like France recognise Covishield and the CoWIN-generated vaccination certificate. As a result of not integrating with the EU Green Pass, India will have to negotiate individually with each country to accept the vaccination certificate generated by CoWIN.

The Question of India's Vaccines

The Vaxzevria vaccine, which is manufactured by the Serum Institute of India (SII) has been approved by the MHRA in the UK, but not by the EMA. Therefore, those in the UK who have received the Vaxzevria jab are currently treated as “not fully vaccinated” in the EU Green Pass system until the EU allows all vaccines approved by the WHO.

Astra Zeneca can apply to have SII listed as a manufacturing facility for Vaxzevria, making Vaxzevria made by SII a vaccine approved by the EMA, exactly in the same manner in which it was done in the UK, albeit temporarily and for just a few batches.

All of which brings us to the question of India’s vaccines, and their acceptability.

Covaxin has not been approved by either the EMA or the WHO, and whether it will be approved or not currently remains unclear. Covishield, on the other hand, has been approved by the WHO, but not by the EMA, USFDA, MHRA or regulators in other developed countries.

Is Covishield the Same as Vaxzevria?

There seems to be very little in the news about this issue — is Serum Institute’s Covishield the same as Astra Zeneca’s Vaxzevria?

Both were developed by Oxford University and licensed to Astra Zeneca, and both have been manufactured by SII in India. If they are both indeed the same vaccine, why are they mentioned individually in all official communication. For example, the UK and France mention each of them separately.

Should they be considered to be different just because they have different brand names? Well, Vaxzevria, as described on the AstraZeneca website is: One dose (0.5 ml) contains Chimpanzee Adenovirus encoding the SARS-CoV-2 Spike glycoprotein (ChAdOx1-S), not less than 2.5 × 108 infectious units (Inf.U).

The description for Covishield, on the other hand is this: ChAdOx1 nCoV- 19 Corona Virus Vaccine (Recombinant) 5 × 10 viral particles (vp).

It would seem that Astra Zeneca and SII themselves believe that these are different vaccines.

Perhaps they can tell us if the vaccines are really the same. Until they do, we just have to infer from their own descriptions that the two vaccines are different. If they are indeed the same, why would they be described so differently?

A Question of Racism?

The one test would be how Europeans and the British governments treat their own citizens who have received the Covishield vaccines in India. If indeed there was racism at play how do they explain that the travel restrictions apply in an identical manner to both Indians and their own citizens who have received Covishield vaccines in India.

Surely, the European and British governments would treat their own citizens better than Indians. Sadly, racism is just something to get the Indian mainstream media screeching for months now and many politicians have jumped on the bandwagon recently, a diversion from focussing on what the Indian government needs to be doing.

How Can Travel Restrictions for Indians Be Eased?

There is no point in seeking accountability from the Indian government for the delay in CoWIN being interoperable with the EU Green Pass or in getting Covishield approved by the EMA, MHRA, etc.

It is going to be quite a task for India to negotiate reciprocal travel protocols with each country in the world. It should be easier to have CoWIN integrate with one global platform, (the EU Green Pass being the only operational one) so that vaccination status can be easily verified by both governments and private entities.

That requires CoWIN to be trusted by other countries in the same way as the EU Green Pass is.

This is one task for the Indian government to accomplish as a priority. The Indian government should have done this before July 2021 and it should be embarrassed that countries like Albania, Turkey, Ukraine and Morocco have accomplished this.

The second and perhaps a task more easy to accomplish is to get consensus among all countries that the WHO approved list of vaccines is acceptable and specific authorisation of each vaccine by every country would be too cumbersome. This should immediately ease travel restrictions for all Indians who have had Covishield and hopefully, even Covaxin when the WHO grants approval.

It is not Covishield, not CoWIN, not even racism — it is just inertia of the Indian government that's causing Indian travellers such hardship.

(Murali Neelakantan is the principal lawyer at amicus. He was formerly global general counsel at Cipla and global general counsel and executive director at Glenmark.)

(Ashish Kulkarni teaches courses in economics and statistics at the Gokhale Institute of Politics and Economics, Pune, and blogs daily at econforeverybody.com.)

(This is an opinion piece and the views expressed above are the author’s own. The Quint neither endorses nor is responsible for them.)