From 12th July 2102, the UK is adopting an EU directive which will effectively close the loophole that has previously allowed pharmacies to conduct up to 5% of their trade commercially without holding a wholesale dealers license.
Those wholesale exporters in particular who are currently buying small quantities of stock from pharmacies who do not hold a wholesale dealers license, will from 12th July be open to enforcement action by the MHRA, as from that date wholesale commercial transactions with pharmacies can only be with WDL licensed pharmacies.
Unless pharmacies have already applied for a WDL, they are almost certain NOT to get one before 12th July, as the MHRA typically have a 3 month waiting list of license applications to be processed and approved. So, wholesale dealers need to be particularly careful to demand copies of pharmacies WDLs after 12th July, otherwise they could be putting their own WDL at risk.
Finally, all wholesale dealers should have regard to the monthly list of branded medicines in UK short supply published in the PSNC month contractor newsletter (which is freely available to all from www.psnc.org) . These listed branded medicines should not be exported without the exporter taking various steps both to verify the current stock situation and other steps to protect themselves legally from prosecution.
Pharmacy Consulting Ltd offer independent advice and support in all the above situations.