Medicine Shortages and Banned Exports

Medicine Shortages and Banned Exports by Graham Stewart, DHSC

 At the 2025 UK GDP Association CIC Annual Conference, attendees heard from a wide range of experts working across regulation, supply chain management and pharmaceutical quality.

Each session provided valuable insight into the challenges currently facing the medicines supply network and the regulatory frameworks designed to protect patient access. One particularly timely presentation came from Graham Stewart, who explored the growing issue of medicine shortages and the regulatory mechanisms used in the UK to manage them.

Representing the Department of Health and Social Care (DHSC), Graham delivered a session titled “Medicine Shortages and Banned Exports”, offering delegates a detailed look at how shortages arise, how they are monitored by government bodies, and what measures are available to mitigate the impact on patients and healthcare providers.

The Role of the Department of Health and Social Care

The Department of Health and Social Care is responsible for leading health and social care policy in England and plays a central role in ensuring that safe, effective medicines remain available to patients across the UK. Working closely with regulators such as the Medicines and Healthcare products Regulatory Agency (MHRA), the department monitors medicine availability and coordinates responses when supply disruptions occur.

Within this framework, pharmaceutical companies and marketing authorisation holders play an essential role in supporting transparency around supply challenges.

About Graham Stewart

Graham Stewart is the Head of Supply Chain and Responsible Person at the Department of Health and Social Care, is a retired pharmacist, with over 30 years’ experience across many different sectors of the pharmaceutical industry. He started his career as a retail pharmacist, running a high-street pharmacy in Aberdeen.

He joined the DHSC in September 2020 as part of the team leading the procurement of strategic stockpiles of medicines to support the UK’s response to COVID and Graham stayed on from March 2021 as the Department’s stockpile lead manager and the Responsible Person for the Department’s WDA(H).

Graham delivered a session at the conference relating to the management of medicine shortages and pharmaceutical products that have been banned from being exported.

His session covered:

Examples of medicines that have suffered from shortages within the supply chain:

• • • Reasons for medicine shortages
    • Requirement to report medicine shortages
    • Shortage mitigation measures
    • Export restrictions
    • Hoarding of medicine

Medicines Recently Affected by Shortages

Several categories of medicines have experienced notable supply disruptions in the months leading up to the conference, including treatments for:

• • • Hormone replacement therapy (HRT)
    • ADHD medications
    • Weight-loss injections

Graham explained how shortages affecting widely used medicines can quickly create challenges across the healthcare system, particularly when patient demand rises sharply or when media coverage increases awareness of certain treatments, an example of this is with weight-loss injections whereby media coverage has been extensive and has created an unprecedented demand for GLP-1 products.

Reporting Supply Shortages

A key message from Graham’s session was the regulatory expectation placed on Marketing Authorisation Holders (MAHs) to notify the Department of Health and Social Care of any issues that may affect the supply of their products.

These notifications enable government teams to assess potential patient impact and implement mitigation strategies before shortages become critical.

In recent years, reports of medicine shortages have increased. However, Graham highlighted an important nuance: this rise may not necessarily indicate that shortages themselves are becoming more frequent. Instead, it may reflect improved reporting practices following the COVID-19 pandemic, when supply chain visibility became a much greater priority for regulators and industry alike.

How Shortages Are Managed

When shortages occur, the Department of Health and Social Care works with regulators and the pharmaceutical industry to minimise disruption to patients.

Graham outlined several mitigation measures that may be used depending on the severity of the issue.

These can include:

• • • Introducing unlicensed medicines to temporarily supplement supply
    • Recommending clinically appropriate alternative licensed medicines
    • Restricting exports of medicines at risk of shortage
    • Working closely with wholesalers to ensure fair and balanced distribution across the UK

These interventions aim to stabilise supply while longer-term solutions—such as increased manufacturing output or regulatory approvals—are implemented.

Export Restrictions and the Banned List

One of the more widely discussed tools available to government during severe shortages is the introduction of export restrictions.

In situations where supply is critically low, wholesalers may be restricted from exporting certain medicines out of the UK. These medicines are placed on an official export ban list designed to protect domestic patient access.

Graham explained that these restrictions are closely monitored and enforced by the Medicines and Healthcare products Regulatory Agency, which reviews export requests and ensures compliance with the rules.

It is important to note that these restrictions apply only to wholesalers, not manufacturers.

There are also limited exceptions to export restrictions. For example, medicines on the banned list may still be exported for humanitarian purposes, provided the wholesaler notifies the Department of Health and Social Care in advance.

The Issue of Stockpiling

Another important topic discussed during the session was stockpiling or hoarding of medicines.

While it may appear logical for organisations to increase stock levels during periods of uncertainty, Graham highlighted that excessive stockpiling can create regional imbalances in supply, potentially leaving some areas short while others hold surplus inventory.

Hoarding can also create significant operational costs for organisations, including:

• • • Additional goods-in and handling requirements
    • Increased stock rotation management
    • Expanded storage needs and facilities
    • Higher administrative and procurement costs

Beyond these financial implications, stockpiling can undermine efforts to maintain fair distribution across the supply chain.

The Risks of Running Out

At the other end of the spectrum, running out of stock can also carry serious consequences for businesses and healthcare providers.

Out-of-stock situations can result in:

• • • Lost sales revenue
    • Reduced customer confidence
    • Loss of market share
    • Permanent switching to alternative brands

Once clinicians and patients move to a different product, they may not always return when supply resumes, making effective stock management crucial for both patient care and commercial stability.

The Importance of Supply Planning

To reduce both shortages and excess stock, wholesalers and suppliers are encouraged to maintain careful oversight of supply levels.

One practical recommendation highlighted during the session was analysing sales trends to maintain an appropriate buffer stock. For many NHS-supplied medicines, this typically means holding around eight weeks of supply, aligning with NHS expectations for supply continuity.

Effective forecasting, combined with open communication across the supply chain, remains one of the most reliable ways to maintain stable medicine availability.

 

Looking Ahead

Graham Stewart’s session provided conference attendees with a clear and practical overview of how medicine shortages are managed at a national level.

From regulatory reporting obligations to export controls and supply planning, the discussion highlighted the many moving parts involved in protecting patient access to essential medicines.

As the pharmaceutical supply chain continues to face global pressures, from manufacturing challenges to rising demand, collaboration between regulators, manufacturers and wholesalers will remain essential.

The insights shared at the 2025 UK GDP Association Annual Conference served as a timely reminder that maintaining a resilient medicines supply chain requires not only strong regulation but also proactive engagement from every part of the industry.

Registering for the 2026 conference

The UK GDP Association C.I.C (Community Interest Company) is delighted to announce that our third Annual Conference will be held on Tuesday 16th June 2026 and Wednesday 17th June 2026, in Northampton.

As with previous years, we have some amazing high-profile speakers, subject matter experts and multiple workshops scheduled each day to make this an industry leading interactive experience for delegates. The conference will cover a broad range of relevant GDP topics over the two days. 

There are discounted tickets available for UK GDP Association members, members can save £100 when attending both conference days. However, our commitment to low-cost, high-value educational content means that conference tickets will still be the best value whether you chose to join as members or not.

Membership is only £29 +VAT per individual, per year and offers reduced costs on consulting, training and conference tickets. If you buy tickets for both conference days, there is an even greater discount. Costs for non-members is just £224.50 per day, a fraction of the cost of other industry events!

In addition, on the evening of Tuesday 16th June, we will be hosting an evening event of dinner, networking, and even some of Dave’s infamous karaoke, for just £49 +VAT per person. This is a fundraising dinner in aid of the MVA Society.

Please see here for more information on the conference and to book your conference and evening dinner tickets.

We are very much looking forward to seeing you all at the conference!