A UK supplier quotes a product as "UK-licensed". The consignment arrives and the cartons are printed in Greek, or Portuguese, or German, with an English sticker on one face and an English leaflet inside. Your broker asks why the pack does not match the sample in your registration file, and the port inspector asks who the company on the sticker is. Nothing irregular has happened. You have received a parallel import, which is a licensed medicine in the UK legal sense. The question is whether it is the licensed medicine your import permit or registration describes.
This guide is for hospital pharmacists, procurement leads, NGO supply officers and licensed importers who need to know, before ordering, which of the two kinds of UK-licensed pack they are being offered, how the paperwork differs, and what to ask. It is written by a UK MHRA-licensed wholesale exporter that supplies both and states which is which on its quotations. It is not legal advice and does not replace a conversation with your own regulator.
The Short Answer
- Two kinds of pack are UK-licensed. One is placed on the UK market under a UK marketing authorisation and carries a licence number beginning PL. The other is an EEA-sourced pack of the same medicine, over-labelled for the UK under a Parallel Import Licence from the MHRA, and carries a number beginning PLPI. A UK wholesale dealer may lawfully sell and export either.
- The licence holder differs. For a PL pack it is the marketing authorisation holder. For a PLPI pack it is the parallel importer. That one difference drives what the carton says, which company a certificate names, how far back the batch trail runs, and whether the pack matches your registration.
- Your destination decides, not the UK. If your registration or import permit is built on the originator's dossier, a PLPI pack may or may not be accepted. Ask your regulator, and ask your supplier to state the pack type in writing before you commit.
Two Ways a Pack Becomes UK-Licensed
Route one: the UK marketing authorisation pack
A medicine placed on the UK market by, or on behalf of, the holder of a UK marketing authorisation is the straightforward case: the holder answers for the product, the artwork and leaflet are the UK versions, and the carton carries the PL number. This is what most buyers mean by "direct UK-licensed supply", and it is the pack most destination registration files were built around. Whether to buy it through a wholesaler or from the manufacturer is a separate decision, covered in our guide on buying from a UK wholesaler versus a UK manufacturer direct.
Route two: the parallel import pack
The UK has run a parallel import licensing scheme for decades. It now sits in Part 5 of the Human Medicines Regulations 2012, where regulation 49 covers the grant of a UK marketing authorisation or a parallel import licence (legislation.gov.uk). The MHRA's guidance, updated 26 August 2026, describes a scheme that lets a medicine authorised in a European Economic Area member state be marketed in the UK, provided there is no therapeutic difference from the cross-referenced UK product, which must itself hold a UK marketing authorisation (MHRA, GOV.UK).
In practice a UK parallel importer buys the medicine from a licensed wholesaler in an EEA market, brings it to the UK, and at a site holding a manufacturer's licence approved for secondary packaging applies a UK label and inserts a UK leaflet. The MHRA guidance grades applications as simple, where the UK and imported products share a common origin, meaning the holders are in the same group or have a licensing agreement between them; standard, where they do not but the case is not complex; and complex, where the imported product has a feature such as a new excipient, a controlled-release formulation or a metered dose inhaler.
The result is a UK-licensed medicine, examined by the MHRA against the UK reference product. The licence holder is the parallel importer, which carries a licence holder's responsibilities for the packs it places on the UK market. A UK wholesale dealer may buy, sell and export those packs exactly as it may a PL pack.
Why this is not grey market. A pack with a PLPI number has been licensed by the MHRA, assembled at an MHRA-licensed site, with the MHRA requiring the importer to evidence or declare that the EEA supplier holds the relevant licence in its own state. A pack bought abroad and shipped on without any UK licence is not UK-licensed at all, and a UK wholesale dealer should not be offering it to you.
Reading the Carton: PL vs PLPI
Pick up one carton, or ask the supplier for a photograph of the pack it intends to ship, and check the following.
- The licence number. A UK marketing authorisation pack shows a number beginning PL. A parallel import pack shows a number beginning PLPI. The MHRA's Windsor Framework guidance confirms that PLPI numbers and the PLPI prefix were unchanged by the 2025 changes, while the older PLGB prefix had to be replaced with PL (MHRA, GOV.UK).
- Two companies, two languages. The original carton is printed for its source market and names that market's authorisation holder and manufacturer. The UK over-label names the parallel importer as licence holder. The MHRA requires the label to carry all the safety information in the UK product's labelling and to leave the primary packaging intact.
- The leaflet. It should follow the UK reference leaflet as closely as possible; differences are limited to product-specific information such as the PLPI number and the licence holder's details.
- UK Only. Packs placed on the UK market on or after 1 January 2025 must display "UK Only" on the outer packaging, by sticker or print, and stickers must not cover statutory text. Any EU 2D barcode should be removed or covered, because EU Falsified Medicines Directive safety features no longer apply to parallel import licences.
- Batch number and expiry. These are the manufacturer's, printed on the original carton and on the blister or vial, and they stay legible under the over-label.
Side-by-Side: What Actually Changes
Terms vary by product, parallel importer and destination, so treat this as a set of questions rather than a rule.
| Criterion | UK marketing authorisation pack (PL) | Parallel import pack (PLPI) |
|---|---|---|
| UK legal status | UK-licensed under a UK marketing authorisation | UK-licensed under an MHRA Parallel Import Licence cross-referenced to the UK authorisation |
| Licence holder | The marketing authorisation holder | The parallel importer, named on the over-label and leaflet |
| Carton and leaflet | UK artwork and UK leaflet, in English | Source-market artwork with an English over-label, "UK Only" marking on packs placed on the market from 1 January 2025, and a leaflet following the UK wording |
| Batch trail | Manufacturer, UK wholesaler, you | Manufacturer, EEA wholesaler, UK parallel importer, UK wholesaler, you |
| Certificate of Pharmaceutical Product | Issued against the UK marketing authorisation with the holder's written permission | Not automatic on the same basis; settle with the supplier and your regulator which licence and company the certificate must describe |
| Match to your registration | Normally the presentation the dossier was filed on | May differ on licence holder, site, artwork or language; acceptance depends on the regulator and the import route |
| Price driver | UK terms for the UK presentation | Source-market price, exchange rate and UK relabelling cost, which may land above or below the UK presentation |
| Availability driver | UK allocation from the authorisation holder | Source-market supply and the importer's licence for that exact presentation; sometimes the only UK-licensed pack available during a UK shortage |
Documentation: CPP, Licence Holder and Batch Trail
The Certificate of Pharmaceutical Product
The MHRA's export certificate guidance, updated 6 May 2026, states that an application for a certificate for a licensed product must be accompanied by a letter on headed paper from the marketing authorisation holder giving permission to export on its behalf, and that the certificate records the marketing authorisation holder, the active ingredients and excipients, the manufacturing, packaging and batch release sites, and whether the product is on the UK market (GOV.UK). That guidance is written around the marketing authorisation and does not mention parallel import licences.
So the certificate your regulator is used to seeing describes the UK authorisation holder's product and sites, not the parallel importer's over-labelling site or the source-market manufacturer. Whether your regulator accepts it as evidence for a PLPI pack, or wants the PLPI holder's details as well, is a question to put to the regulator before ordering. Our UK pharmaceutical import documentation guide sets out the full document set and who issues each item.
The name on the paperwork
Your permit, registration certificate and invoice each name a licence holder. For a PLPI pack the carton names two companies and the UK wholesaler's invoice may name a third. None of that is wrong, but it is exactly what a port inspector queries, so the supplier should state the PLPI holder, the PLPI number and the source-market manufacturer on the quotation and invoice before dispatch.
Batch traceability through the parallel importer
Under Good Distribution Practice a UK wholesale dealer must trace every batch back to its supplier and forward to its customer, with a Responsible Person accountable for the quality system. For a PLPI pack the chain runs from the manufacturer to an EEA wholesaler, to the UK parallel importer, to the UK wholesale dealer, to you. Each link holds its own records, and the batch number on the pack remains the manufacturer's, so a recall can still be matched to your consignment. Expect the supplier to confirm batch number and expiry per line before dispatch, and do not accept one that cannot name the parallel importer it bought from. Our supplier qualification page covers the records we hold and share.
Destination Registration: Does the Pack Match the Dossier?
This is where the two routes part company. A product registered in your country was registered on a dossier naming a marketing authorisation holder, one or more manufacturing sites and a specific presentation with approved artwork. A UK PL pack is usually that presentation or close to it. A PLPI pack was never designed for your market: its carton was printed for another EEA state, its over-label names a UK parallel importer, and its manufacturing site may differ from the site in your file. Whether that matters depends on who is inspecting and under which route the product enters.
- Import of a locally registered product. The regulator checks that what arrives matches what was registered. A PLPI pack is at its most exposed here.
- Named-patient or special-import permit. Where the product is not registered locally and the regulator issues a permit for a UK-licensed product on a prescriber's request, the questions are usually whether the pack is genuinely UK-licensed and whether its labelling is in a language the regulator accepts. A PLPI pack is UK-licensed, but its outer carton is not in English; some regulators accept the English over-label and leaflet, others do not. This route is the buyer's destination-country mechanism, described on our named-patient supply page.
- Tender supply. Specifications often fix the presentation; a PLPI pack substituted without notice invites rejection at delivery.
We give no country-by-country verdict on PLPI acceptance, because practice changes and the only authoritative answer comes from the regulator concerned. Our regulator comparison tool names the body to ask in each market we serve, and our pages on Saudi Arabia, the UAE and South Africa describe each regulator's import routes.
What Saudi Port Checks Teach About Over-Labelled Packs
One published document shows concretely why a re-labelled pack can be stopped. The Saudi Food and Drug Authority's "Frequent Observations on Shipments of Pharmaceutical, Herbal and Cosmetic Products", version 2.0 dated 12 December 2024, lists recurring reasons shipments at the Kingdom's ports are delayed or rejected (SFDA). For human medicines they include:
- failure to include the manufacturer's and marketing authorisation holder's name and nationality on the invoice;
- the manufacturer's name and nationality not printed on the package, for products registered in the Kingdom;
- registered products arriving with a different expiry period from the one registered with the Authority;
- products not registered in the Kingdom supplied in a language other than Arabic or English.
The SFDA's labelling guidance, version 3.3 of December 2023, lists the manufacturer name and the marketing authorisation holder's name and address among the particulars required on the outer packaging of a registered product (SFDA). Read those documents against a PLPI pack and the friction is obvious: a carton in a third language, an over-label naming a UK company that is not the registered holder, and a manufacturer whose name and nationality may not match the file. None of this means a PLPI pack cannot enter the Kingdom or another GCC market. It means the pack type must be declared and cleared with the regulator in advance.
Price and Availability Trade-offs
Buyers rarely ask for a parallel import by name. They meet one when a UK supplier quotes a lower price, or when the PL presentation is unavailable and the PLPI presentation is the only UK-licensed pack that can be found. On price, a PLPI pack's cost follows its source-market price, the exchange rate at purchase and the cost of UK relabelling and licensing, not the UK authorisation holder's terms. It can land below the UK presentation, and above it when source-market prices move. A PLPI line quoted cheaper than a PL line is not a warning sign; a quotation that does not say which presentation it is pricing is.
On availability, the two presentations draw on different pools. The PL pack depends on the UK authorisation holder's allocation to UK wholesalers; the PLPI pack on source-market supply and on the importer holding a licence for that exact strength and pack size. During a UK supply problem the PLPI presentation can keep a UK-licensed pack available, one of the routes described on our drug shortage supply page, and a source-market shortage removes it while the PL pack remains. Lines difficult in both pools are covered on our hard-to-source medicines page. The trade-off is not quality, since both packs are UK-licensed; it is a possible price advantage against the regulatory work of clearing a pack that does not match your file. Treat any saving on a first import as provisional until your regulator has answered.
The Post-Brexit Position, Verified Against MHRA Guidance
A persistent worry among overseas buyers is that UK parallel importing ended with Brexit, so any EEA-sourced pack in a UK consignment must be irregular. It did not end. The MHRA's guidance, as updated on 26 August 2026, still describes a medicine authorised in an EEA member state being marketed in the UK under a PLPI, and still requires the importer to declare that it obtains products only from suppliers holding an appropriate wholesaler or manufacturer authorisation.
What changed is the internal UK geography. Under the Windsor Framework, from 1 January 2025 EU Parallel Distribution Notices are no longer valid in Northern Ireland, every parallel import into any part of the UK needs a UK-wide PLPI, and licences previously limited to Great Britain converted automatically. The "UK Only" marking and the removal of EU Falsified Medicines Directive safety features from parallel import packs date from the same change, which is why a 2025 or 2026 pack carries a sticker an older sample did not.
Two cautions. This is the position at the time of writing; verify it against the live MHRA pages linked above, because the guidance has been updated repeatedly since 2024. And the MHRA states that it does not consider trade mark infringement when granting a PLPI: that is a matter between the parallel importer and the originator, it does not change the pack's licence status, but it is one reason a brand owner's local affiliate may react to a PLPI pack differently from a PL pack.
UK Export Restrictions Apply to Both
Neither presentation escapes UK export controls. The Department of Health and Social Care and the MHRA publish a list, updated 29 September 2026 at the time of writing, of medicines that cannot be exported from the UK or hoarded because they are needed for UK patients. Exporting or hoarding a listed medicine is treated as a breach of regulation 43(2) of the Human Medicines Regulations 2012 and a contravention of the wholesale dealer licence, and may lead to MHRA regulatory action including immediate suspension of the licence (GOV.UK).
The list is written at the level of the medicine, not the licence type, so a PLPI pack of a listed product is as restricted as the PL pack, and a licensed wholesaler should refuse the line in either form. How the mechanism works, and what to do when it bites a line you depend on, is covered in our article on UK medicine export restrictions in 2026.
Checklist: What to Ask Before Accepting a Parallel-Import Pack
Put these to the supplier in writing and keep the answers with your import file.
- Is each line the UK marketing authorisation presentation or a parallel import presentation? Ask for the PL or PLPI number per line.
- Who is the PLPI holder, and from which EEA market does the pack originate?
- Which manufacturing site is printed on the source carton, and does it match the site in our registration or permit?
- Can you send a photograph of the pack as it will ship, showing the over-label and the batch and expiry panel?
- What batch number and expiry are available for this line, confirmed before dispatch rather than estimated?
- Which company will the Certificate of Pharmaceutical Product describe, and has our regulator accepted that for a parallel import pack before?
- Is any line on the current UK export restriction list?
- Can we verify your wholesale dealer licence on the MHRA register? Euro Biom's is listed as WDA(H) 59239, and our guide on how to verify a UK pharmaceutical supplier explains the check.
Definitions of the terms used here, including marketing authorisation holder, parallel import and Certificate of Pharmaceutical Product, are in our pharmaceutical glossary.
Where Euro Biom Fits
Euro Biom Ltd is a UK MHRA-licensed pharmaceutical wholesale exporter, WDA(H) 59239, with a nominated Responsible Person. We supply only UK-licensed, MHRA-authorised finished medicines, which includes both the UK marketing authorisation presentation and the parallel import presentation, sourced through the UK licensed supply chain: the authorisation holder's channel, licensed UK wholesalers, or MHRA-licensed parallel importers whose licences we have qualified.
What we add is the declaration. Each line on a Euro Biom quotation states which presentation is offered, the PL or PLPI number, the licence holder, and the batch number and expiry confirmation available, so you can check the line against your registration or permit before you commit, and so your broker and port inspector see the same information on the invoice as on the carton. If you need the PL presentation only, we quote it or tell you it cannot be supplied, and we do not substitute one presentation for the other after quotation.
We do not supply unlicensed medicines or specials, vaccines, biologics, biosimilars, insulin, blood or plasma products or controlled drugs, and we do not act as a regulatory consultancy: whether your regulator accepts a PLPI pack is a question for your regulator, and we give you the facts to put to them. Regular buyers can open a pharmaceutical trade account; our WDA licence and compliance pages set out the controls each consignment passes through.
Have a list where the pack type matters? Send it to work@eurobiom.co.uk or through the enquiry form and say which presentation your regulator accepts. We quote line by line, stating PL or PLPI for each, and flag any line that cannot be exported.
Frequently Asked Questions
Need to Know Which Pack You Are Buying?
Send us your product list and the presentation your regulator accepts. We quote line by line, stating PL or PLPI for each, with the batch number and expiry confirmation available, and we respond the same working day.
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