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Pharmacotherapy of unlicensed medicines prepared and distributed by Dutch pharmacies
  1. HPA Scheepers1,2,
  2. V Neerup Handlos3,
  3. MH Schutjens4,
  4. C Neef2,5
  1. 1 Ministry of Health, Welfare and Sport, Dutch Health Care Inspectorate, Utrecht, The Netherlands
  2. 2 CAPHRI School for Public Health and Primary Care, Maastricht University, Medical Centre, Maastricht, The Netherlands
  3. 3 Capital Region Pharmacy, Herlev, Denmark
  4. 4 Schutjens-De Bruin in Tilburg, Pharmaceutical Law University of Utrecht, The Netherlands
  5. 5 Maastricht University Medical Centre, Clinical Pharmacy, Maastricht, The Netherlands
  1. Correspondence to HPA Scheepers, Ministry of Health, Welfare and Sport, Coordinating Specialist Senior Inspector at the Dutch Health Care Inspectorate, Stadsplateau 1, Utrecht 3521 AZ, The Netherlands; hp.scheepers{at}


Introduction and objective In the Netherlands, preparing and distributing pharmacies (PDPs) are taking over a large proportion of pharmacy preparations. PDPs prepare and distribute medicinal products to dispensing pharmacies. Many pharmacies have stopped pharmacy preparation. However, this contravenes the Dutch Medicines Act and the European Union (EU) Directive 2001/83/EC on which Dutch law is based. This is because the medicinal products of PDPs are unlicensed and PDPs do not have a manufacturing licence.

Methods To solve the conflict with the Dutch Medicines Act, PDPs have since 2007 been authorised by the Dutch Health Care Inspectorate by means of a circular letter. This circular letter describes the qualitative conditions that must be fulfilled by PDPs. The circular letter's conditions state that PDPs must perform verifiable investigations to assess the availability, or not, of licensed pharmacotherapeutic alternatives (PA investigations) and to assess the pharmacotherapeutic rationale and the needs of the patient (PT investigations).

Results Regular visits were performed by the Dutch Health Care Inspectorate to check the compliance of PDPs with the circular letter. This article describes the results of these inspections for PA and PT investigations.

Conclusions The results of the inspections show that so far almost all PDPs inspected have complied with the PA and PT conditions of the circular level at system level. However, in a substantial proportion of cases, the rationale of the pharmacy-made products is insufficient or insufficiently documented.

  • pharmacy preparation
  • preparing and distrbuting pharmacy
  • dispensing pharmacy
  • Circular Letter
  • large-scale preparation through pharmacists
  • GMP (Good Manufacturing Practice)
  • product dossiers

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