UK Controls on Parallel Export and Hoarding of Restricted Medicines

Overview of the Policy

The UK government has introduced restrictions on the export and hoarding of certain medicines that have been placed on the UK market and where there is evidence the medicine is in critical shortage or at risk of critical shortage. This measure aims to prevent worsening medicine shortages and ensure that medicines are available to meet the needs of UK patients.
Source: Parallel export and hoarding of restricted medicines (gov.uk)

“Hoarding” refers to a situation in which wholesale dealers withhold a medicine from supply when it is in short supply, which could jeopardise access for patients.
Source: Parallel export and hoarding … (gov.uk)

Export and Hoarding Restrictions

Under the guidance, wholesalers and licence holders may be prohibited from exporting or hoarding medicines on the restricted medicines list. This list is reviewed and updated regularly, and it is the responsibility of the trader to check it prior to export.
Source: Parallel export and hoarding … (gov.uk)

Restrictions apply to exports both within and outside the European Economic Area (EEA) for products that have been placed on the UK market for UK patients.
Source: Parallel export and hoarding … (gov.uk)

Decision Criteria for Restrictions

The Department of Health and Social Care (DHSC) regularly reviews which medicines should be subject to export restrictions. A medicine may be restricted if it meets all of the following conditions:

• The medicine is required to meet the needs of UK patients.
• The medicine is currently in critical shortage or at risk of critical shortage.
• Exporting that medicine would worsen or contribute to the shortage in the UK.
  Source: Parallel export and hoarding … (gov.uk)

The UK has committed to removing medicines from the restricted list when they no longer meet the criteria, in line with its obligations under the World Trade Organisation (WTO).
Source: Parallel export and hoarding … (gov.uk)

Examples and Updates

As of late 2025, the restricted medicines list contains a variety of products such as Atomoxetine, Baloxavir, Cefalexin, and others that cannot be exported or hoarded due to ongoing supply concerns. The list is updated periodically to reflect the current market situation and supply risks.
Source: List of medicines that cannot be exported … (gov.uk)

Export Limitations for Branded Medicines

Since 1 January 2021, branded medicines placed on the UK market may no longer be exported to countries in the EEA where such exports could negatively impact UK supply. Traders should also be mindful of guidance on the exhaustion of intellectual property rights and parallel trade.
Source: Medicines that you cannot export or hoard (gov.uk)

Regulatory Consequences

Attempting to export or hoard a restricted medicine may be considered a breach of the Human Medicines Regulations 2012 (regulation 43(2)) and a contravention of a wholesale dealer licence. Regulatory action by the Medicines and Healthcare products Regulatory Agency (MHRA) could include suspension of the wholesale dealer licence.
Source: Medicines that you cannot export … (gov.uk)

Importance for UK Supply Chains

These restrictions form part of the UK’s broader strategy to maintain medicine availability and supply chain resilience. Limiting exports and hoarding in times of strain helps protect public health by ensuring that critical medicines remain available domestically rather than being diverted elsewhere.
Source: Parallel export and hoarding … (gov.uk)

Conclusion

The UK’s controls on parallel export and hoarding of restricted medicines are designed to safeguard the supply of essential medicines for UK patients, especially during periods of shortage. By enforcing export limits, maintaining an up-to-date restricted list, and ensuring compliance with regulatory obligations, the UK targets balanced and transparent management of medicine supplies.
Source: Parallel export and hoarding of restricted medicines (gov.uk)