The Antimonopoly Committee of Ukraine issued recommendations to pharmaceutical manufacturers and importers

On 24 April 2025, the Antimonopoly Committee of Ukraine (AMC) issued recommendations to 160 pharmaceutical manufacturers and importers.

According to the AMC’s market study, some companies apply overly restrictive criteria when selecting distributors, limiting access to only a few eligible candidates. These may include:

• a minimum number of distribution points or warehouses;
• strict delivery timelines;
• mandatory sales volumes or presence in specific rankings;
• other factors that disproportionately favour large or established players.

What’s the concern?

Such selection criteria may create artificial barriers to competition, granting certain distributors an unfair advantage not based on market performance but on tailored eligibility thresholds. This can limit the variety of medicines available to pharmacies and, ultimately, to patients.

The AMC also noted that such restrictions may violate Article 20-4 of the Law of Ukraine “On Medicines”, which outlines the obligations of manufacturers and importers in the distribution process.

AMC Recommendations:

Distributors should not be selected using discriminatory criteria that could lead to the exclusion or restriction of competition in the wholesale pharmaceutical distribution market. These recommendations apply to all market participants involved in the manufacturing and import of medicines.

The AMC urges all companies to review their commercial practices and avoid potential violations of competition law.