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Entering the UK pharmaceutical market

What international companies need to understand prior to selecting a partner.

The NHS serves 67 million people through a single national system. That sounds like simplicity. It is not. Formulary committees, Integrated Care Board structures, MHRA regulatory requirements, national tender frameworks, and dispensing system configurations all complicate matters. The path from a licensed product in Australia, the United States, or Europe to an NHS dispensing shelf is not obvious from the outside. Most international pharmaceutical companies that try to manage it on their own lose 6 to 12 months before finding the right entry point. The ones who succeed quickly share one characteristic: they found a partner who already knew the landscape.

 

This article covers how to enter the UK market, what the NHS procurement process looks like for newcomers, and what to seek in a commercialisation partner.

Clinic

Why the UK is worth the effort

The NHS is a single-payer healthcare system.*1 For pharmaceutical companies used to fragmented private insurance, varying state rules, or multi-payer models, this is a material difference. Gaining MHRA authorisation and NHS formulary approval means a product can reach patients nationwide through one commercial route and one distribution network.


The MHRA now operates independently of the European Medicines Agency, but its standards are internationally recognised and its processes well established.*2  An MHRA-approved dossier includes content needed for later European authorisation. Companies entering the UK are not duplicating effort if they plan to enter Europe next.


There is also a specific commercial opportunity that deserves more attention. Many NHS patients cannot take medicines in standard tablet or capsule form. These include children needing weight-adjusted dosing, older adults with swallowing difficulties, and patients on enteral feeding in intensive care. It also includes individuals with complex conditions where a standard formulation is not appropriate. These patients are often served by unlicensed compounded products prepared locally or sourced through a specials supplier.*3  Such products are more expensive, carry greater clinical risk, and expose hospitals to audit.

A company with a licensed, stable alternative to an unlicensed special has a commercially and clinically convincing proposition for the NHS. The market exists, and it is not fully served.

What the NHS procurement landscape actually looks like.

Most international pharmaceutical companies lack a clear understanding of how the NHS buys medicines. This is not a criticism; it is simply a consequence of the NHS being a system unlike any other in the world. Understanding the structure is the first step to navigating it.

Within each Trust, a Drug and Therapeutics Committee (D&TC) reviews new medicines.*4  For novel products, this means submitting an application, undergoing clinical review, and receiving a decision on inclusion on the formulary. This takes time and requires specific evidence. For established generics, this can be shortened for direct procurement, a faster path to the first order.​

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Integrated Care Boards

Currently across England, 42 Integrated Care Boards (ICBs) manage health and care for defined geographic populations.*5  Each ICB's Medicines Optimisation function issues guidance which shapes prescribing across all Trusts in its area. Securing positive ICB-level guidance is far more efficient than approaching each Trust individually. Identifying the ICBs relevant to your product's patient population and the key Medicines Optimisation Leads is fundamental to any NHS commercial strategy.

National tender frameworks

Some medicine categories are procured via national frameworks or tenders, giving preferred supplier status across participating NHS Trusts for a defined period.*6  This eliminates the need for individual Trust approvals and speeds up the transition from authorisation to commercial volume. Not all products qualify, and tender timing is fixed. Missing a cycle means waiting for the next one. Identifying where a product fits in the national procurement calendar is a key early commercial task.

The system listing gap

Most international companies, and many UK-based ones, do not anticipate this step. A product can be MHRA-licensed, formulary-approved, and listed on a national tender, yet still not appear on a drop-down menu when a hospital pharmacist tries to dispense it. NHS dispensing systems, JAC, Ascribe, and EPMA being the most common, all require a separate configuration to add any new product.*7 Until then, the product does not exist in the dispensing workflow. 

Worth knowing

Most NHS Trusts already hold an active account with the major pharmaceutical wholesalers and 3PL operators. A product distributed through an established 3PL means NHS Trusts can order without setting up a new supplier account, removing the single most common administrative friction point in NHS market activation.

What kinds of products work

The qualifying criterion for a UK in-licensing opportunity is not the product format. It is the patient at the end of it. A tablet, a liquid formulation, a vial, any of these can represent a compelling in-licensing proposition if there is a patient population with an unmet clinical need that the mainstream market has not adequately served.

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The commercial logic is simple: a licensed product typically replaces an unlicensed one already used and funded by the NHS.*3  When a hospital sources an unlicensed compounded product for patients unable to take standard tablets, it confirms the clinical need. With a licensed option, the goal is not to create demand, but to redirect spending toward a product with stronger clinical credentials, longer shelf life, and lower risk. This is a faster commercial process than launching a product where the NHS does not already buy alternatives.

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Patient populations where this dynamic is most active include neonates and paediatric patients requiring weight-adjusted doses,*8  older adults with dysphagia associated with Parkinson's disease, dementia, or stroke, *9   patients receiving enteral nutrition in intensive care or rehabilitation settings, and adults managing conditions where the available licensed tablet formulation is not clinically appropriate.

 

These are not niche populations. Dysphagia is common in older adults and in people with conditions such as stroke, Parkinson's disease, and dementia, and is associated with increased healthcare use and costs.*9  Historically, many medicines used in children have lacked age-appropriate licensed formulations, which is one reason paediatric regulation now requires dedicated investigation plans.*8  NHSBSA data show that unlicensed specials account for substantial annual NHS spend, and local prescribing guidance encourages switching to licensed alternatives where clinically appropriate.*10

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Current Phase

Launch and grow

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Ongoing support and European expansion

Post-launch support covers supply management, pharmacovigilance obligations, and NHS account management. For companies with wider ambitions, the MHRA dossier provides a foundation for European expansion without starting from scratch.

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The process does not end at launch if the partnership is built well.

What to look for in a UK commercialisation partner

Choosing a UK partner is the most important step in market entry. The partner handles regulatory submission, NHS strategy, supply chain, and ongoing distribution and compliance. The wrong choice is costly in time, money, and position.

 

Five criteria determine a strong partnership.

1.
Regulatory navigation experience

​Ask for specific examples: which products has this partner taken through the MHRA process, over what timelines, and with what outcomes? A partner who has navigated MHRA submissions directly is materially different from one who manages the process through third-party contractors with limited oversight. The MHRA process is manageable for a team that has done it. It is full of avoidable delays for one that has not.

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Qualifying question:

Can you give me two examples of MHRA submissions you have managed, the timelines, and the outcomes?

2.
NHS market access capability

Regulatory approval is necessary but not sufficient. The partner needs active relationships within NHS procurement: medicines management pharmacists, procurement business partners, Medicines Optimisation Leads at ICB level. They need to understand the D&TC process for novel products and the procurement route for generics. These require different approaches and different contacts.

Qualifying question:

How do you approach formulary approval for a new product, and at what level of the NHS do you typically operate?

3.
Supply frame infactructre

Understand who holds the Wholesale Dealer's Authorisation (WDA), who manages the 3PL warehousing relationship, and how the import and distribution chain is structured. A partner with an established 3PL arrangement connected to NHS and private hospital channels means your product enters a working supply chain rather than one that needs to be built from scratch around it

Qualifying question:

Who holds the WDA, who is your 3PL, and how is stock replenishment managed?

4.
Commercial execution track record

There is a difference between a partner who has launched products in the NHS and one who advises on how to do it. The former has dealt with clinical inertia, system listing failures, formulary rejections, and supply disruptions, and has the experience to navigate them. Ask for product launches specifically, not project management experience

Qualifying question:

Which products has your team personally launched in the NHS, and what commercial outcomes did you achieve?

5.
Genuine attention

A large CRO or distributor with a broad portfolio will process your product. A focused partner with a smaller book of business will partner it. When problems arise, and in pharmaceutical market access, problems always arise, the difference between a partner who treats your product as a priority and one who treats it as a line item becomes apparent quickly. Evaluate not just capability but the model: how many products is the partner managing, and what does their bandwidth actually look like?

Qualifying question:

How do you manage the relationship with a partner once the agreement is signed, and what does day-to-day contact look like in practice?

What the process looks like in practice

The journey from a product licensed in another market to commercial supply into the NHS follows a defined sequence. Timelines vary depending on the product, its existing dossier, and the regulatory pathway selected, but the stages are consistent.

1.
Opportunity assessment

A commercial and regulatory review of the product: patient population, existing market data, NHS procurement route, competitive landscape, and whether the dossier is transferable to MHRA requirements without significant additional development work.

2.
Dossier adaptation

The existing regulatory dossier is reviewed and adapted to meet UK-specific MHRA requirements. The extent of this work depends on the origin market. Products licensed in markets with similar regulatory frameworks typically require less adaptation.

3.
MHRA submission and authorisation

The adapted dossier is submitted for MHRA review. The partner manages all interactions with the MHRA through this process. A partner with prior MHRA submission experience will anticipate the common points of query and structure submissions accordingly.

4.
NHS commercial activation

Once marketing authorisation is granted, the commercial programme begins: formulary submissions where required, national tender engagement where relevant, ICB-level Medicines Optimisation engagement for systemic adoption, and direct Trust-level procurement conversations.

5.
Distribution activation and system listing

Stock is delivered to the 3PL and made available through the NHS distribution channel. System listing, the configuration of NHS dispensing systems at each target Trust, is confirmed as a separate step alongside formulary and procurement activation.

6.
Ongoing support and European expansion

Post-launch support covers supply management, pharmacovigilance obligations, account management at key Trusts, and ICB-level relationship management. For partners with European ambitions, the MHRA dossier provides a foundation for EU market authorisation applications without starting from scratch.

Entering the UK NHS market successfully is rarely about the product alone. It is about finding a partner who has navigated the system before and can move without losing time at every decision point.

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How Green Park Pharma approaches in-licensing

Green Park Pharma is a UK speciality pharmaceutical company focused on licensed medicines for patients with unmet clinical need. The team holds a long-duration NHS national supply agreement and has taken products through the MHRA licensing process. We distribute through Alloga, one of the UK's leading pharmaceutical 3PLs, serving both NHS and private hospital channels.


The team has over 20 years' experience formulating, licensing, and distributing medicines in the UK, including product launches at UCB, Veriton Pharma, Novo Nordisk, Sanofi, and Pfizer. Green Park Pharma is not a consultancy, the same team handles regulatory work, NHS strategy, and supply chain management. Every partnership receives direct senior-level attention.


GPP Green Park Pharma works with products across formats -  tablets, liquids, and vials, where patients have unmet clinical need. Liquid formulations for patients unable to swallow tablets are our strongest current case study, but the qualifying criterion is the patient, not the format. If you have a product addressing a patient group the UK market has not adequately served, we would like to hear about it.

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Speak to Green Park Pharma

Tell us about your product and we will tell you honestly whether the UK is the right next market and whether Green Park Pharma is the right partner to take it there.

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Sources & References

1.  NHS England. About us. NHS England; accessed 2026.  

https://www.england.nhs.uk/about/


2.  Medicines and Healthcare products Regulatory Agency. Apply for a licence to market a medicine in the UK. GOV.UK; updated 2024.  

https://www.gov.uk/guidance/apply-for-a-licence-to-market-a-medicine-in-the-uk


3.  NHS Specialist Pharmacy Service. Unlicensed medicines: the use of unlicensed medicines in NHS practice. SPS; 2023.  

https://www.sps.nhs.uk/articles/unlicensed-medicines/


4.  NHS England. Medicines optimisation. NHS England; 2023.  

https://www.england.nhs.uk/medicines-2/medicines-optimisation/


5.  NHS England. Integrated care systems. NHS England; 2023.  

https://www.england.nhs.uk/integratedcare/

 

6.  NHS Specialist Pharmacy Service. Regional arrangements for medicines optimisation in the NHS in England. SPS; 2023.  

https://www.sps.nhs.uk/wp-content/uploads/2023/12/3.-JOHANNA-HULME_-H-J-Slides-selection-v0.1_No-notes.pdf

 

7.  NHS Specialist Pharmacy Service. Electronic prescribing and medicines administration (EPMA) implementation. SPS; 2023.  

https://www.sps.nhs.uk/articles/epma/

 

8.  Medicines and Healthcare products Regulatory Agency. Legal requirements for children's medicines. GOV.UK; 2026. 

https://www.gov.uk/government/publications/legal-requirements-for-childrens-medicines

 

9.  Royal College of Speech and Language Therapists. Dysphagia in care homes. RCSLT; 2015.  

https://www.rcslt.org/wp-content/uploads/media/Project/RCSLT/dysphagia-in-care-homes.pdf

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