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A pharmacist has told the House of Lords that substances used in assisted dying would not be considered medicines when used to bring about death, as this purpose is not covered by the Human Medicines Regulations.
During oral evidence given to the House of Lords Terminally Ill Adults (End of Life) Bill Committee on 5 November 2025, Greg Lawton, a pharmacist and barrister, said that regulations define a “medicinal product” as a substance with properties of preventing or treating disease in human beings or that can be used for restoring, correcting or modifying a physiological function.
“The drugs being used would not be medicines if being used to facilitate suicide. Such a purpose is not encompassed by the definition of medicinal product in the human medicines, regulations and case law,” he said.
Lawton added that when a person thinks of a medicine, they do not associate it with a drug that causes death, which means that legal provisions related to medicinal products would not apply.
The proposed legislation was introduced as a private members bill by MP Kim Leadbetter in 2024. It has since passed the first stage of progress through the House of Commons and it is now being examined in detail in the House of Lords.
Speaking at the oral evidence session, Rachel Arrundale, interim director of partnerships at the Medicines and Healthcare Regulatory Agency, said that if the bill became law, approving the substances to be used in assisted dying would undergo the “same sort of rigorous assessment” as medicines do.
“It’s our understanding in most parts of the world the substances in use [for assisted dying] are in fact licensed medicines, licensed for other purposes, other indications in the UK,” Arrundale added.
“There may well be quite a lot of clinical data available about those substances and use for other reasons. And we can draw on experience from other jurisdictions.”
The committee noted that previous studies used to assess assisted dying drugs were observational rather than clinical trials.
During the session, Laura Wilson, director for Scotland at the Royal Pharmaceutical Society (RPS), suggested that a clinical trial “would be quite a difficult thing to do, given that the outcome is death”.
“We’re certainly not of the opinion that a clinical trial would be appropriate — what we understand as a [typical] clinical trial,” she added.
Wilson also stressed that if the bill were passed, the decision on what drugs could be used and how should be made by a panel of experts based on the best evidence available and subject to ongoing evaluation and review, which would be flexible enough to change the process based on this evidence.
“In the UK, we do operate with robust medicines governance practices, but that’s not to say they’re all perfect, and I do believe that that ongoing monitoring would be needed to ensure that where there are improvements that can be made, they are,” she added.
In the same session, Lord Kamlesh Patel noted that when drugs were administered for assisted dying in other countries, the role of the pharmacist was considered “extremely helpful” in explaining to patients what the drug was and what the effects might be.
He asked whether pharmacists choosing to be involved in the process in the UK would welcome such a role.
Wilson responded: “Pharmacists are medicines experts. So it makes sense that that would be a role that they were entrusted with and deliver very effectively.”
“The role of the pharmacist within the current bill is quite clear. However, pharmacists do have an increasingly clinical role with patient contact… if that was a role that was considered for pharmacists and was enabled by the bill, I think it would be very welcomed,” she explained.
“Pharmacists also have a massive role in medicines governance, so we would advocate for their inclusion into any sort of medicine protocols that were being decided and any medicines management systems that were being put in place to deal with the approved substance with this bill.”
The inquiry also made reference to The Pharmaceutical Journal‘s reader survey on assisted dying, in which 54% of 755 respondents said they supported assisted dying in principle.
Wilson told the committee that these results would not change the RPS’s neutral stance on the issue.
She pointed out that when the Society first published a statement on assisted dying in 2013, survey results revealed around 40% of members in favour of assisted dying, 40% against and the rest undecided.
“At that time our national boards, who are our elected officials, decided to take the view that even if one pharmacist was opposed or one pharmacist was in favour and all the rest were the other, we should still support both sides, and we declared a neutral stance at that time,” she added.
