When the UK adopts an EU wide directive on July 12th 2012, community pharmacies will no longer be able to rely upon the former understanding that they can trade up to 5% of their medicines turnover without holding a Wholesale Dealers Licence (WDL).
The MHRA have made it clear that from July 12th onwards any pharmacy that continues to trade in medicines, other than for the benefit of an INDIVIDUAL patient (for example borrowing a product from another pharmacy) without holding a WDL will be liable to prosecution by themselves as the enforcement agency.
For those pharmacies who neither hold a WDL nor have so far applied for a WDL but have been habitually selling medicines by way of trade, usually for export, there is only 1 month left before this activity becomes illegal.
Further, as there is typically a delay of around 3 months between submitting a completed WDL application to the MHRA and being inspected by the MHRA, it is now inevitable that any trading in medicines by unlicensed pharmacies who have not yet applied for a WDL would from 12th July, and in August and even September almost certainly be illegal.
I would advise pharmacies who neither hold nor intend to apply for a WDL to keep a careful record of any trade (non-dispensing) transactions that they carry out from July 12th onwards in order to be able to prove, if challenged by the MHRA inspectorate, that all such trade transactions are to benefit specific individual patients