From July 12th 2012, the UK will be adopting and implementing EU guidance which will effectively remove the exemption which has for years allowed pharmacies to conduct up to 5% of their medicines turnover as wholesale trade, without the possession of a wholesale dealers license (WDL)
After that date, the MHRA have made it clear that they will NOT pursue pharmacies who are borrowing or lending stock, for the benefit of an NHS patient, but pharmacies who continue to trade commercially in pharmaceuticals after July 12th, without a WDL, WILL lay themselves open to prosecution by the MHRA. Further, the publication in the PSNC newsletter each month of UK branded medicines in short supply lays a further trap for those who continue to sell those listed branded products for export, unless they take a number of precautions to protect their situation.
There is usually a waiting list of WDL applications to be processed at the MHRA of approximately 3 months from receipt of a completed WDL application. The WDL application form has to be accompanied by a relevant set of wholesaling SOPs, and “technical agreements” with any 3rd party couriers or contract Responsible Persons (RPs) and the license application fee of some £3600 has to be pre-paid [This RP is NOT the same as a Pharmacy Responsible Pharmacist].
There are commercial exporting organisations offering to complete the whole WDL application process for pharmacists without charge, but there is usually a quid pro quo condition that such pharmacies must sell products for export to the company who conducted the application work and sell them at prices fixed by the purchaser.
Those pharmacists who wish to retain their independence in this matter will wish to retain the services of a reputable pharmacist run consultancy company to help obtain their WDL, after which they will be free to operate as they see fit.