Importing medicines into the UK for a private telehealth service is permitted only under specific regulatory frameworks — primarily the Specials regime for unlicensed medicines, and the Wholesale Dealer's Authorisation (WDA) regime for licensed medicines. Casual or unstructured importation is not lawful. This piece walks through the routes and when they apply.
Why this question matters in UK telehealth
UK telehealth brands sometimes want to source medicines from EU or US suppliers either for cost, for availability of formulations not licensed in the UK, or for category-specific reasons. The regulatory framework around importation is strict and the MHRA oversight has tightened since Brexit.
Getting this wrong — importing without proper authorisation or operating outside the Specials criteria — is one of the more visible enforcement areas. Brands that build international supply chains without aligning the regulatory framework attract attention quickly.
The Specials regime for unlicensed medicines
The Specials regime permits the supply of unlicensed medicinal products to meet the special clinical needs of an individual patient where no licensed alternative is suitable. Importation under Specials requires MHRA notification, prescriber justification for the specific patient, and proper distribution governance.
Specials is not a route to broad supply of unlicensed medicines. It is patient-specific and clinically-justified. Telehealth services using Specials regime properly: document individual patient need, justify why no licensed alternative is suitable, notify MHRA, and supply only the prescribed quantity. Telehealth services using Specials carelessly: bulk-supply unlicensed products and treat the patient-specific requirement as a formality.
Wholesale Dealer's Authorisation (WDA) for licensed medicines
Importation of licensed medicines for commercial supply requires a Wholesale Dealer's Authorisation issued by MHRA. WDA holders must comply with Good Distribution Practice (GDP), maintain a Responsible Person, and operate appropriate storage and quality systems.
Obtaining a WDA is a substantial regulatory project — typically 6-12 months from application to grant, with significant infrastructure and governance requirements. It is not a quick add-on to a telehealth service. Most UK telehealth brands access imported licensed medicines via existing WDA-licensed wholesalers rather than holding their own WDA.
What this means for international telehealth brand expansion
A US or EU telehealth brand expanding into the UK cannot simply import its existing supply chain. The UK regulatory framework requires UK-licensed medicines through UK-licensed wholesalers to UK GPhC-registered pharmacies. The brand experience can be consistent across markets; the regulated supply chain cannot.
Brands sometimes assume the EU CE mark or US FDA approval provides UK market access. It does not. Each jurisdiction has its own medicines licensing regime, and the UK regime is independent post-Brexit.
How PExpo handles imported and unlicensed medicines
PExpo's dispensing operation handles licensed UK medicines through proper UK supply channels. Where category demand or patient need requires unlicensed Specials-route products, PExpo's pharmacy operates within the Specials regime under MHRA notification and proper clinical justification.
For brands launching in the UK and considering imported products, the dispensing partner relationship is the right place to handle the regulatory framework rather than the brand attempting to operate its own importation. See our brand model page for the operational scope and our pricing page for the commercial structure.
Specials regime importation is patient-specific and clinically-justified. It is not a route to broad supply of unlicensed medicines. Bulk-supply under Specials with the patient-specific requirement treated as a formality is non-compliant and visible to MHRA.
A US or EU telehealth brand expanding into the UK cannot simply import its existing supply chain. The brand experience can be consistent across markets; the regulated supply chain cannot.
Importing medicines into the UK for a private telehealth service is permitted under the Specials regime (unlicensed, patient-specific) or the WDA regime (licensed, commercial). Both require MHRA authorisation and proper governance. Brands that operate within these frameworks build sustainably; brands that bypass them attract enforcement attention. See our brand model page for the dispensing partnership route and our pricing page for the commercial structure.
Frequently asked questions
Can I import GLP-1 medications from the US for cheaper supply to UK patients?
Not lawfully — GLP-1 receptor agonists imported into the UK for commercial supply require either Specials regime authorisation (patient-specific, clinically-justified) or supply through UK-licensed channels via a WDA-licensed wholesaler. Bulk importation outside these frameworks is not permitted.
How long does a Wholesale Dealer's Authorisation (WDA) take?
Typically 6-12 months from application to grant, plus substantial infrastructure, governance, and Responsible Person recruitment. It is a substantial regulatory project.
Does PExpo handle Specials regime medicines for telehealth brands?
Yes — where category demand or patient need requires unlicensed Specials-route products, PExpo's pharmacy operates within the Specials regime under MHRA notification and proper clinical justification. See our brand model page.
