Three quarters of surveyed companies within the EBA’s Health Care Committee report shortages of imported medicines in retail

02/ 04/ 2026

76% of surveyed companies that are members of the European Business Association’s Healthcare Committee reported shortages of imported medicines in the retail market. These findings indicate that the issue is no longer limited to isolated operational disruptions, but rather reflects a systemic shortage of medicines. According to market participants, the stability of pharmaceutical supply is affected by a combination of factors, including war-related risks, regulatory barriers, and procedural unpredictability. Taken together, these factors place additional pressure on supply chains and affect the availability of certain medicines. Company assessments indicate that cases of shortages or risks of supply disruption affect a wide range of medicines, including cardiovascular, ophthalmological, neurological and oncology treatments, as well as biological therapies for patients with autoimmune diseases. In some cases, there is already a real risk of certain therapies being withdrawn or a lack of therapeutic alternatives for patients. Key drivers of shortages According to the Association’s survey, companies most frequently identified two major risks to uninterrupted medicine supply: lengthy and unpredictable procedures for obtaining GMP compliance confirmation in Ukraine, and the loss of inventory due to missile strikes on warehouse infrastructure—each cited by 69% of respondents. A further 56% of companies highlighted systemic issues with the operation of the National Price Catalogue, which complicates planning and the import of medicines. According to respondents, applications for inclusion in the catalogue or for price changes may be processed for two months or longer, without explanation or clear visibility regarding their status. Other challenges include low stock levels at distributors (25%), which may also result from inventory losses due to attacks, production or supply limitations by manufacturers (19%), customs delays (13%), and other factors (13%). GMP compliance confirmation procedure The most sensitive issue for the market remains the procedure for obtaining GMP compliance confirmation in Ukraine. Regulatory authorities in countries with Stringent Regulatory Authorities (SRAs) issue GMP certificates only after a full inspection of manufacturing processes, confirming compliance of all intermediate and contracted facilities with GMP standards. Therefore, undergoing an additional national procedure is perceived by companies from SRA countries as duplicative. Moreover, companies regularly face practical challenges in applying this procedure, which the Association’s Committee has repeatedly raised in communications with public authorities. These include deviations from established review timelines, prolonged processing of applications without clear status updates, repeated requests for additional documentation, and a lack of transparent communication mechanisms with applicants. As a result, the GMP confirmation process is often extended indefinitely, creating risks for timely import and supply of medicines. Issues with the National Price Catalogue Another source of supply delays identified by companies is the functioning of the National Price Catalogue. Requests for additional clarifications are often submitted with significant delays, further prolonging the process. At the same time, Association members note that current legislation does not define a clear procedure for price revision or transparent criteria for decision-making. In practice, applicants may be required to provide additional financial and economic justifications not предусмотрені by the existing procedure. This results in technical and operational disruptions in supply chains and, in some cases, blocking of product distribution or postponement of procurement. Overall, the lack of clear legal requirements and proper process synchronisation creates regulatory unpredictability for businesses, complicating planning and negatively affecting the stability of medicine supply for patients. Loss of inventory due to attacks The situation has been further exacerbated by the loss of warehouse facilities and medicine stocks as a result of missile attacks. These inventories had been built up by companies to cover prolonged waiting periods within regulatory procedures, particularly for GMP confirmation; their destruction has significantly reduced market resilience. According to market estimates, a single attack destroyed approximately 20% of the country’s monthly supply of medicines. Currency factor An additional risk factor is price fixing in hryvnia without a mechanism for prompt adjustment in line with exchange rate fluctuations. During periods of devaluation, this may lead to a loss of economic viability for imports, prompting distributors to postpone procurement. Additional technical issues Companies also reported delays in processing, failure to meet deadlines, “manual intervention”, technical malfunctions of electronic tools, and inaccuracies in data retrieved from state registers. A separate issue is the lack of proper synchronisation between the National Price Catalogue, the State Register of Medicines, and the Reimbursement Register, which can lead to blocked product distribution or delayed procurement. Measures taken by companies Member companies of the Association’s Health Care Committee are already implementing practical measures to ensure uninterrupted supply. These include alternative warehousing solutions, ordering additional production batches from parent companies, redistribution of products between countries, building additional inventories, and adjusting production plans. Some companies are also developing business continuity plans in case of damage to warehouse infrastructure. In addition, the Association has initiated amendments to licensing conditions to allow the use of additional or alternative storage facilities during martial law. At the same time, businesses are not limited to operational measures. Through the Committee, companies are engaged in systematic dialogue with public authorities to remove regulatory barriers affecting supply stability. The fewer such barriers, the faster medicines reach the market and the shorter delivery timelines become. Outlook and required actions According to optimistic estimates by some companies, the situation may stabilise as early as April 2026. However, other market participants believe that without abolishing or significantly simplifying the GMP reconfirmation procedure, full stabilisation is unlikely before 2027. In the short term (from several weeks to 3–5 months), partial recovery of supply is possible if lost inventories are replenished and regulatory review processes are accelerated. In the long term, companies link market stabilisation to systemic regulatory changes — primarily reform of GMP procedures, stable administration of the National Price Catalogue, and overall regulatory predictability. Among practical solutions, companies propose introducing a mechanism for recognising GMP certificates issued by SRA countries based on certificate numbers in international databases or certified copies. This would reduce administrative burden, shorten procedures, and improve supply predictability. The Committee also notes that at the beginning of the full-scale war, a temporary simplification allowed the import of medicines from SRA countries without mandatory GMP confirmation in Ukraine. However, this provision was отменено by a resolution of the Cabinet of Ministers dated 13 October 2023 (No. 1077), reintroducing the requirement and increasing administrative burden and delivery timelines. At the same time, according to publicly available information, no cases of substandard medicines linked to the absence of GMP confirmation in Ukraine were reported during the period of simplification. Another concern for businesses is the establishment of a new regulatory authority — the State Control Body or the Ukrainian Pharmaceutical Agency. The transfer of functions from the State Service of Medicines to a new body may create risks of disruption to critical functions, including quality control and inspections. The business community therefore emphasises the need for a clear transition roadmap and sufficient staffing to avoid additional risks of medicine shortages. For reference: The survey was conducted among member companies of the European Business Association’s Health Care Committee in February 2026. A total of 17 pharmaceutical companies participated.

76% of surveyed companies that are members of the European Business Association’s Healthcare Committee reported shortages of imported medicines in the retail market. These findings indicate that the issue is no longer limited to isolated operational disruptions, but rather reflects a systemic shortage of medicines.

According to market participants, the stability of pharmaceutical supply is affected by a combination of factors, including war-related risks, regulatory barriers, and procedural unpredictability. Taken together, these factors place additional pressure on supply chains and affect the availability of certain medicines.

Company assessments indicate that cases of shortages or risks of supply disruption affect a wide range of medicines, including cardiovascular, ophthalmological, neurological and oncology treatments, as well as biological therapies for patients with autoimmune diseases. In some cases, there is already a real risk of certain therapies being withdrawn or a lack of therapeutic alternatives for patients.

Key drivers of shortages

According to the Association’s survey, companies most frequently identified two major risks to uninterrupted medicine supply: lengthy and unpredictable procedures for obtaining GMP compliance confirmation in Ukraine, and the loss of inventory due to missile strikes on warehouse infrastructure—each cited by 69% of respondents.

A further 56% of companies highlighted systemic issues with the operation of the National Price Catalogue, which complicates planning and the import of medicines. According to respondents, applications for inclusion in the catalogue or for price changes may be processed for two months or longer, without explanation or clear visibility regarding their status.

Other challenges include low stock levels at distributors (25%), which may also result from inventory losses due to attacks, production or supply limitations by manufacturers (19%), customs delays (13%), and other factors (13%).

GMP compliance confirmation procedure

The most sensitive issue for the market remains the procedure for obtaining GMP compliance confirmation in Ukraine. Regulatory authorities in countries with Stringent Regulatory Authorities (SRAs) issue GMP certificates only after a full inspection of manufacturing processes, confirming compliance of all intermediate and contracted facilities with GMP standards. Therefore, undergoing an additional national procedure is perceived by companies from SRA countries as duplicative.

Moreover, companies regularly face practical challenges in applying this procedure, which the Association’s Committee has repeatedly raised in communications with public authorities. These include deviations from established review timelines, prolonged processing of applications without clear status updates, repeated requests for additional documentation, and a lack of transparent communication mechanisms with applicants.

As a result, the GMP confirmation process is often extended indefinitely, creating risks for timely import and supply of medicines.

Issues with the National Price Catalogue

Another source of supply delays identified by companies is the functioning of the National Price Catalogue. Requests for additional clarifications are often submitted with significant delays, further prolonging the process.

At the same time, Association members note that current legislation does not define a clear procedure for price revision or transparent criteria for decision-making. In practice, applicants may be required to provide additional financial and economic justifications not предусмотрені by the existing procedure.

This results in technical and operational disruptions in supply chains and, in some cases, blocking of product distribution or postponement of procurement. Overall, the lack of clear legal requirements and proper process synchronisation creates regulatory unpredictability for businesses, complicating planning and negatively affecting the stability of medicine supply for patients.

Loss of inventory due to attacks

The situation has been further exacerbated by the loss of warehouse facilities and medicine stocks as a result of missile attacks. These inventories had been built up by companies to cover prolonged waiting periods within regulatory procedures, particularly for GMP confirmation; their destruction has significantly reduced market resilience.

According to market estimates, a single attack destroyed approximately 20% of the country’s monthly supply of medicines.

Currency factor

An additional risk factor is price fixing in hryvnia without a mechanism for prompt adjustment in line with exchange rate fluctuations. During periods of devaluation, this may lead to a loss of economic viability for imports, prompting distributors to postpone procurement.

Additional technical issues

Companies also reported delays in processing, failure to meet deadlines, “manual intervention”, technical malfunctions of electronic tools, and inaccuracies in data retrieved from state registers. A separate issue is the lack of proper synchronisation between the National Price Catalogue, the State Register of Medicines, and the Reimbursement Register, which can lead to blocked product distribution or delayed procurement.

Measures taken by companies

Member companies of the Association’s Health Care Committee are already implementing practical measures to ensure uninterrupted supply. These include alternative warehousing solutions, ordering additional production batches from parent companies, redistribution of products between countries, building additional inventories, and adjusting production plans.

Some companies are also developing business continuity plans in case of damage to warehouse infrastructure. In addition, the Association has initiated amendments to licensing conditions to allow the use of additional or alternative storage facilities during martial law.

At the same time, businesses are not limited to operational measures. Through the Committee, companies are engaged in systematic dialogue with public authorities to remove regulatory barriers affecting supply stability. The fewer such barriers, the faster medicines reach the market and the shorter delivery timelines become.

Outlook and required actions

According to optimistic estimates by some companies, the situation may stabilise as early as April 2026. However, other market participants believe that without abolishing or significantly simplifying the GMP reconfirmation procedure, full stabilisation is unlikely before 2027.

In the short term (from several weeks to 3–5 months), partial recovery of supply is possible if lost inventories are replenished and regulatory review processes are accelerated.

In the long term, companies link market stabilisation to systemic regulatory changes — primarily reform of GMP procedures, stable administration of the National Price Catalogue, and overall regulatory predictability.

Among practical solutions, companies propose introducing a mechanism for recognising GMP certificates issued by SRA countries based on certificate numbers in international databases or certified copies. This would reduce administrative burden, shorten procedures, and improve supply predictability.

The Committee also notes that at the beginning of the full-scale war, a temporary simplification allowed the import of medicines from SRA countries without mandatory GMP confirmation in Ukraine. However, this provision was отменено by a resolution of the Cabinet of Ministers dated 13 October 2023 (No. 1077), reintroducing the requirement and increasing administrative burden and delivery timelines.

At the same time, according to publicly available information, no cases of substandard medicines linked to the absence of GMP confirmation in Ukraine were reported during the period of simplification.

Another concern for businesses is the establishment of a new regulatory authority — the State Control Body or the Ukrainian Pharmaceutical Agency. The transfer of functions from the State Service of Medicines to a new body may create risks of disruption to critical functions, including quality control and inspections.

The business community therefore emphasises the need for a clear transition roadmap and sufficient staffing to avoid additional risks of medicine shortages.

For reference:

The survey was conducted among member companies of the European Business Association’s Health Care Committee in February 2026. A total of 17 pharmaceutical companies participated.