As of 25 June 2017, tough restrictions on the issuance of a licence to operate a pharmacy open to the public (community pharmacy) were introduced. The procedure for obtaining a licence is very difficult and its outcome depends on the subjective assessment of provincial Pharmaceutical Inspection authorities. The statutory possibility of derogation from the application of these restrictions is structured in an impractical way. The procedure hinders the efficient assessment of conditions of the important interest of patients and of the need to ensure their access to medicinal products. As a result of the different practice of provincial pharmaceutical inspectors, the interpretation of regulations is not uniform across the country. The way the regulations are interpreted in practice is not subject to substantive review in the course of appeal proceedings. This makes it difficult for an applicant to obtain a pharmacy licence under legitimate circumstances. Simple changes to the prescribed procedure are advisable, as they could make its application more uniform, while patients could benefit from better access to pharmacotherapy.
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