Wholesale distribution16. What is the legal regime regarding wholesale distributionof drugs?The wholesale distribution of drugs is mainly governed by the Lawon Securing Quality, Efficacy and Safety of Pharmaceuticals,Medical Devices, Regenerative and Cellular Therapy Products,Gene Therapy Products, and Cosmetics (PMDL). Any companywanting to wholesale drugs in Japan must hold a wholesaler'slicence issued by the prefectural governor competent for eachbusiness establishment (Article 25 and paragraph 1, Article 31,PMDL). Supplying wholesale refers to selling or supplying drugs tothe proprietor of a pharmacy, a marketing authorisation holder, amanufacturer, a retailer of drugs, or a hospital, a clinic, or any othersuch persons or places (other than the end-user of the medicinalproduct). Wholesale supply will be permitted if there is a marketingauthorisation in place for the drug in Japan. A wholesaler canwholesale drugs that are non-prescription drugs to store retailersand door-to-door retailers engaged in household distribution(Article 156, PMDL Enforcement Regulations). In principle, awholesaler must have a pharmacist based at each businessestablishment in charge of overseeing the business establishment(paragraphs 1 and 2, Article 35, PMDL).
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