Q. I have been asked by a dentist to supply POMs for use in their practice, do I need a Wholesale Dealers Licence to do this?

A. No - a legal supply would be permitted provided the dentist issues the pharmacist with a requisition (signed order) authorising the supply.

A Wholesale Dealer’s Licence (WDL) is not required when supplying another healthcare professional unless that supply is to another registered pharmacy.

In July 2012 the MHRA repealed section 10(7) of the Medicines Act which had previously allowed pharmacists to trade in medicines in certain circumstances without a wholesaler dealer’s licence.

The MHRA has stated that this change to legislation should not adversely affect the supply of medicines from community or hospital pharmacies to other healthcare professionals who need to hold stocks of medicines either for direct supply to their patients or for use within their practice.

They also acknowledge that there are occasions when pharmacists need to obtain small quantities of medicines from other pharmacies to satisfy the needs of an individual patient, for example to complete a prescription for a medicine that is unavailable.

The MHRA has confirmed that supplies of medicines by community or hospital pharmacies to other healthcare professionals in the UK who require medicines either to treat or to supply directly to their patients is “an important and appropriate part of the professional practice of both community and hospital pharmacy and falls within the definition of provision of healthcare services”.

This form of medicines supply is not considered to be wholesale dealing and does not require a wholesale dealer’s licence (WDL).

Pharmacists are also permitted to obtain small quantities of medicines from other pharmacies without the need for a WDL provided certain criteria are met:

  • That this only occurs occasionally
  • The quantity of medicines involved is small
  • It is required for an individual patient
  • No profit is generated from the supply.

Note that if supply is to a pharmacy within the same legal entity – i.e. the same limited company - then it is considered a stock transfer and a WDL is not required.

In all other cases a WDL is required. Pharmacists requiring guidance on applying for a WDL can find this information on the MHRA website.

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