Cross-border prescriptions - EU, EEA and Ireland - Thyroid UK

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Cross-border prescriptions - EU, EEA and Ireland

helvella profile image
helvellaAdministrator

I have (at last) found some specific information about EU/EEA cross-border prescriptions post-brexit - there is a special case in respect of Ireland.

IRELAND

Cross-border prescriptions

• Introduction

• Rules

Introduction

If you have a medical prescription from a doctor in the European Economic Area (EEA), the prescription is valid in all other EEA countries if it contains certain information. The EEA includes the member states of the European Union as well as Iceland, Liechtenstein and Norway.

A medical prescription written by a doctor registered in the United Kingdom (UK) continues to be valid in Ireland, if it contains certain information. Likewise, a medical prescription written by a doctor registered in Ireland continues to be valid in the UK, if it contains certain information.

See 'Rules' below for the information that must be included.

A medical prescription is not valid in Ireland if it is issued by a UK-registered doctor, via an online service, to a person living in Ireland.

citizensinformation.ie/en/h...

REST OF THE WORLD (GERMANY)

Unless there are other special cases, I believe this information from the German health ministry applies:

Can dental and medical prescriptions for medicinal products, which were issued in the United Kingdom, still be dispensed in Germany from 1 January 2021?

According to section 2 (1a) of the Ordinance on the Prescription of Medicinal Products (Arzneimittelverschreibungsverordnung, AMVV), only medical or dental prescriptions from member states of the European Union, the European Economic Area and from Switzerland are deemed equivalent to prescriptions issued in Germany (implementation of Directive 2011/24/EU on the application of patients’ rights in cross-border healthcare). Therefore, since 1 January 2021, prescriptions from the United Kingdom may no longer be dispensed in Germany due to the withdrawal of the United Kingdom from the European Union and the expiry of the transition phase by the end of 2020.

bundesgesundheitsministeriu...

If anyone has further official statements for the rest of the world, please let me know!

[Updated as extra information has been found and added.]

20 Replies

Does that mean a UK issued prescription is only valid in Ireland if it's an actual paper prescription ? ie the doctor put's it in an envelope and sends it to Ireland, or am i being thick ?Or does it mean that the Irish resident has to go to UK to get it ?

I'm glad i'm not in the import /export business..... i'd be pulling my hair out.

helvella profile image
helvellaAdministrator in reply to tattybogle

Mutual recognition of healthcare computer systems is not considered in that statement. And I do not know if there is any separate agreement about them.

But the point is this, while in Ireland, you are expected to be prescribed only by prescribers within Ireland. But if you happened to visit the UK and receive a UK prescription from a UK prescriber, it would be valid within Ireland.

This online restriction is obviously to stop virtual prescription tourism!

I am. And I am! This has been the worst month of my business life. It's been so stressful and so unproductive. I'm off to work again shortly to try to get shipments ready for Monday. It didn't help that my EU courier of choice, with which I have an account, completely failed from about 4th Jan onward. They just return random shipments, regardless of flawless paperwork, with no explanation or apology. I have had irate customers who don't care less about Brexit, giving me a really hard time. I've had to ditch DPD now and use an international courier service. FedEx have been good, as have DHL and ironically, Parcel Force, a service I would never normally use. Desperately trying to set up a business account with UPS, but so is the rest of the UK, so that's not happening fast.

The only reliable way to get T3 in the UK now is via a UK pharmacy such as Roseway Labs. Yes it's a £1 a 20mcg tablet. But it's good T3 and it's available. I'd not try importing it from anywhere right now.

you have my sympathy , that sounds hideously stressful. If i was still in business, i'd be screwed now cos most of my work was for festivals/live music events.

I hope you can find a way through the chaos without loosing all your hair.

Fortunately one of my kids works installing Broadband which it seems is the right business to be in during a pandemic, so we haven't starved.

I wonder where that leaves Northern Ireland including practitioners and patients who have dual citizenship of Ireland and UK under the Good Friday agreement?

helvella profile image
helvellaAdministrator in reply to mourneadventurer

As I read it, anyone (regardless citizenship) can get a prescription from a UK prescriber and take it to a pharmacy in Ireland for dispensing. And vice versa.

The restriction being that the prescriber cannot issue that prescription on the basis of an online session to someone who is living in Ireland. (Definition of "living in" would need clarification.)

As I read it, this is intended to make life easier for those who cross the border - whether between Ireland and Northern Ireland or Great Britain (either way).

Nothing there clarifies whether a prescriber registered in Ireland can prescribe within the UK or vice versa. Mutual recognition of qualifications generally requires additional agreements and I simply do not know.

It is also unclear whether a pharmacy in Ireland could accept a UK prescription and post the dispensed medicine to the UK or vice versa. (I'd expect the actual prescription to have to be sent by post.) Though, only recently, there was some mention of Irish customs confiscating a prescription-only medicine being sent to a resident of Ireland.

Thanks Helvella much appreciated! I’ll dig a little deeper with some of the contacts you’ve listed. My consultant endo and his peers are completely in the dark as well.

helvella profile image
helvellaAdministrator in reply to mourneadventurer

I'd very much appreciate extra information - or corrections - as available! :-)

Sadly I’ve discovered that Novothyral is not available in the Republic of Ireland. However Liothyronine is and might be an alternative way forward (ie. using Liothyronine and Levothyroxine separately) for those living in NI? At least this can be followed up if required when pandemic restrictions relax.

Obtaining Novothyral 100 from an online European pharmacy with a UK prescription would cost approx £55. (Sadly that is no longer an option given Brexit as UK Endo qualifications are no longer recognised).

Obtaining Novothyral 100 from a UK based distributor from the ThyroidUK list cost £99 with special delivery for 180 tablets.

Thankfully we still have this option albeit really expensive open to us despite the pandemic lockdown.

helvella profile image
helvellaAdministrator in reply to mourneadventurer

Thank you for letting us know.

I am in NI and am using T3 which I sourced from outside the EU without problems - does the NI protocol mean that they will no longer be able to ship this to me?

Hi Redlester,I don't know, some musings however:

Prescription is written by a GP or Endo whose qualifications and licence are recognised

T3 medication source is outside the EU - if you were able to access it before Brexit then it might be worth trying again? Perhaps worth a phone call to customs?

I decided to use the ThyroidUK list of UK pharmacies and accessed my usual T3/T4 combo

Please PM me if you are successful.

Hi mourneadventurer

I am more concerned about customs than the prescription at the moment as my supplier does not require prescription and I don't currently have T3 prescription. I am going to PM you about your other points in case what I say would contravene forum rules.

helvella profile image
helvellaAdministrator in reply to Redlester

So far as I am aware, the legality of importing prescription-only medicines - for personal use - has not changed.

Everything is to do with recognition of prescriptions and duty/tariff barriers, customs clearance charges, etc.

Tom Hanks said you can get meds through US customs if it’s for a goat......maybe we should be trying this😂

This is really useful info, Helvella! Thanks for taking the time to put this info together!

the good news is that the pharmacy I have used in Germany for 2 or 3 years now, has dispensed without me sending a script the last 2 times I have ordered. Presumably illegal but I am happy with it!

Caggie61 profile image
Caggie61 in reply to bellk

Hi, would you be so kind as to private message me details of your pharmacy in Germany who has honoured your order please? Mine has just declined for the first time x

bellk profile image
bellk in reply to Caggie61

If you tell me how to send a PM on here I will. Sorry, I can be a bit of a technodummy. I last ordered in November 2020 so under old rules. As for not requiring a script, I have been thinking about this and wonder if there is a glitch in the company's computer system(which I desperately don't want to be brought to their attention) which enable repeat orders to be dispensed from the same prescription . Which unfortunately probably means this won't work for new customers.

helvella profile image
helvellaAdministrator in reply to bellk

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