Retail Sale of Over-the-Counter Medicinal Products at Fuel Stations
On 3 March 2026, Resolution of the Cabinet of Ministers of Ukraine No. 1803 dated 26 December 2025 “On Amendments to the Licensing Conditions for Conducting Business Activities in the Manufacture of Medicinal Products, Wholesale and Retail Trade in Medicinal Products, and Import of Medicinal Products (except active pharmaceutical ingredients)” entered into force.
The Resolution introduces significant amendments to the Licensing Conditions approved by CMU Resolution No. 929 dated 30 November 2016 and effectively legalises the retail sale of over-the-counter (OTC) medicinal products at fuel stations, including through vending machines.
1. New Retail Model at Fuel Stations
The Licensing Conditions have been supplemented with new Clause 158-1, which provides that retail trade in exclusively over-the-counter medicinal products is permitted at fuel station premises on the basis of a licence. Such sales may be carried out by fuel station employees without establishing a pharmacy or a structural subdivision thereof.
A mandatory requirement is compliance with the storage conditions specified by the manufacturer, as well as ensuring proper receipt of medicinal products and incoming quality control by an authorised person.
In essence, the legislator has created a separate format for the distribution of OTC medicinal products outside the traditional pharmacy network.
2. Storage and Premises Requirements
The Resolution requires that fuel stations designate a dedicated area for storing medicinal products, separate from other goods. Storage conditions must fully comply with the manufacturer’s requirements, including temperature and other specified parameters.
Accordingly, the business entity must ensure an adequate material and technical base and maintain continuous control over storage conditions.
3. Sales via Vending Machines
The amendments also expressly allow the sale of OTC medicinal products through vending machines located at fuel stations. Such sales are permitted only if the manufacturer’s storage requirements are observed.
Loading medicinal products into vending machines, conducting incoming quality control, and organising the receipt process must be carried out by an authorised person. Therefore, even an automated sales model remains subject to elements of pharmaceutical oversight.
4. Qualification Requirements and Quality System
Amendments to Clause 3 of the Licensing Conditions establish that business entities engaged in the retail sale of medicinal products at fuel stations must designate a person holding higher education of at least the initial (short-cycle) level in “Pharmacy, Industrial Pharmacy.” No professional experience requirements are imposed.
This designated person is responsible for ensuring the functioning of the medicinal products quality system within one region (oblast). Thus, responsibility for the quality system is concentrated in a qualified pharmaceutical specialist, even though the actual sales may be performed by fuel station employees.
5. New Licensing Documentation
Amendments to Clause 7 of the Licensing Conditions expand the list of documents required for obtaining a licence. For retail trade in medicinal products at fuel stations, applicants must submit information on the availability of the material and technical base and qualified personnel in accordance with a newly approved form. implement this law.