Export restrictions on medicines, country by country: the position in autumn 2026

The map

Every EU country may restrict exports of a medicine to protect its own supply, and the pharmaceutical package under adoption will add a general power from 2028. What differs is the instrument: a published ban list, a prior-authorisation procedure, a notification with a veto window, or a shortage flag. The table is the position as checked on 25 October 2026; the detail follows.

Country	Instrument	2026 position
Greece	Rolling temporary ban on parallel exports and intra-EU movement, by product code	91 codes banned 27 Aug – 27 Nov 2026; new decision roughly quarterly
Portugal	Quarterly prior-notification list plus a monthly export-suspension list	51 presentations suspended in September 2026; quarterly export reporting
Belgium	Prior FAMHP authorisation for listed essential medicines in shortage	Dated list, versions of 30 June and 29 September 2026
Poland	Bi-monthly ministry list; export needs the Chief Pharmaceutical Inspector’s consent	294 items from 9 September 2026, up from 273 in February
Italy	AIFA block list: listed products may not leave the national distribution chain	Updated 21 May 2026; shortage lists refreshed 16 October 2026
Slovakia	Reimbursement-law reform with anti-re-export measures	Approved 6 October 2026; effective 1 November 2026, key parts January 2027
Czechia	“Limited availability” flag bars distributors from exporting; prior-notice regime with a 15-day veto	No new law in 2026; regulator seeking criminal liability for illegal re-export
Germany	Export bans under §52b AMG for products in shortage	No amendment found in 2025–26
Spain	Three-working-day prior notice of exports via the AEMPS system	Unchanged (Circular 1/2025)
Hungary, Romania, Netherlands, Ireland, Nordics	Monitoring or notification regimes	No 2025–26 change found

Country by country

Greece. The medicines agency EOF issues a fresh temporary ban on parallel exports roughly every quarter: 80 products from February to May 2026, 82 from May to August, and 91 product codes under decision 104860 of 27 August 2026, valid to 27 November. Stockpiling of listed products is also prohibited while a ban runs. The list churns rather than only growing; an older ban on 119 products was lifted in 2026. In October 2026 the pharmacists’ association proposed an “export only the surplus over domestic demand” rule, which is a proposal only.

Portugal. Infarmed runs two lists. A prior-notification list of presentations with availability problems is revised quarterly (the latest deliberation of 11 September 2026 took effect on 15 September); exporters must notify before shipping anything on it. A monthly export-suspension list covers products that were out of stock the previous month with medium or high public-health impact, plus exceptional-use products: 59 presentations in February 2026, 51 in September, including oncology and antidepressant lines. Manufacturers and wholesalers also report exports quarterly through the SiExp system by the 15th of the following month.

Belgium. Under the Royal Decree of 19 January 2023 the Minister can make export of a listed essential medicine subject to prior FAMHP authorisation when a shortage of at least a month exists or threatens, the product is urgent and no alternative exists. FAMHP decides within five working days and may order quantities kept in Belgium for the duration of the shortage. The list is a dated PDF on the agency’s site with an end date per product. Since November 2024 the agency can also authorise wholesalers to import packs not authorised in Belgium during a critical unavailability, which is the mirror image of an export ban.

Poland. The Ministry of Health publishes, under Article 37av of the Pharmaceutical Law, a list of medicines, devices and foods for special medical purposes at risk of unavailability; the trigger is reports of absence from at least 5% of pharmacies in a region. Exporting a listed item requires the consent of the Chief Pharmaceutical Inspector. The 2026 lists grew from 273 items in February to 294 on 9 September, including insulins, oncology products and widely traded diabetes and obesity injections. The next notice is due in November. A broad amendment to the reimbursement law, with price support for Polish-made products, was aimed at 1 January 2027 but had not been confirmed as adopted.

Italy. AIFA keeps a list of medicines that may not be removed from the national distribution chain while shortage conditions persist. The determination published in the Official Gazette on 30 May 2026 added two anthelmintics; an earlier update added one product and removed three. The wider shortage lists were refreshed on 16 October 2026.

Slovakia. Parliament approved an amendment to the reimbursement act on 6 October 2026, since signed, that closes the pharmacy ordering channel re-exporters have used: pharmacies must sell back unissued stock to the wholesaler or the authorisation holder, wholesalers and holders may refuse suspicious orders, and penalties are strict. It takes effect on 1 November 2026 with key parts from January 2027. The existing duty to notify the regulator of exports of reimbursed medicines within seven days continues.

Czechia. The 2024 amendment to the Pharmaceuticals Act created a “limited availability” flag that bars distributors from exporting flagged products, on top of the older regime of prior notice with a 15-day ministry veto and fines up to CZK 20 million. No new rule came in 2026, but in June the regulator’s director said fines had not stopped illegal re-export and that criminal liability was being sought.

Germany, Spain and the rest. Germany’s export bans for products in shortage under §52b of the Medicines Act saw no amendment in 2025–26. Spain’s three-working-day prior notice through the AEMPS system is unchanged. No 2025–26 change was found for Hungary (monitoring under the medicines act), Romania (quarterly clawback orders only), the Netherlands, Ireland or the Nordic countries.

What it means if you are…

A parallel exporter. Four countries now publish lists that change monthly or quarterly, one needs an authorisation per shipment, one has just closed the pharmacy channel. The check belongs at release, against the dated list, for every source country; Greece and Portugal in particular can move a product from open to banned between order and shipment.

A generics or launch planner. These lists are also a map of where supply is short. A product on three national lists is a product with demand its current suppliers cannot meet.

A buyer. When a source country bans export, the importing country’s price rises or supply thins; the lists explain why a familiar parallel-import line disappears.

What to watch

Greece’s next decision around 27 November 2026; Poland’s November list; Slovakia’s implementation from 1 November; the Commission’s first Union critical list under the pharmaceutical package, which will give Member States a common reference for these decisions. This piece is revised each quarter; the date at the top is the last revision.