Rxchange response to proposals to reduce risk from counterfeit medicines (MHRA MLX357)

Rxchange have responded to the MHRA consultation on measures to strengthen the medicines supply chain and reduce the risk from counterfeit medicines.

Rxchange accepts that every reasonable step should be taken to eradicate the possibility of counterfeit medicines entering the supply chain and while generally supporting a number of the proposals that affect supply at or near its source, Rxchange vehemently disagree with proposals that would restrict pharmacies ability to sell stock between pharmacies. They consider that availability of stock would be affected and that public healthcare would therefore suffer, creating a 'postcode lottery' affecting who would be able to obtain the required medication.

'Pharmacies are already suitable places to store pharmaceuticals and supply them to patients. They are regulated by the Medicines Act and are inspected by the RPSGB to ensure compliance to the regulations. The public should have as much trust in obtaining non-counterfeit medicines from a pharmacy as a proprietor of another pharmacy would in obtaining the same product from that pharmacy. The level of trade between pharmacies is insignificant compared to the amount occurring between WDL holders and pharmacies. Effects of reducing counterfeit medicines by regulation at the pharmacy-end would be proportionately ineffectual.'

Rxchange identified the proposals were both anti-competitive - as pharmacies without a WDL would be unable to clear their stock while corporates could continue to move stock between branches - and that the proposals would be highly problematic to enforce and measure. Rxchange also highlighted the commercial and environmental implications associated with restricting a pharmacies ability to 'sell on' its excess stock.

They were also critical of the consultation process which, while engaging a number of agencies and organisations on the periphery of the supply chain, did not directly engage the pharmacies that the proposals would affect.

The full response document can be found at www.rxchange.co.uk/news/rxchange-response-to-mhra-mlx357.pdf.

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Rxchange response to proposals to reduce risk from counterfeit medicines (MHRA MLX357)