Why the UK must put medicines at the forefront of a new EU relationship

Why the UK’s priorities need to change in terms of medicines regulation, which will ultimately determine whether future patients will benefit from affordable medicines supply.

Whisky, frozen prawns, olives and sausages have all featured prominently in the UK’s early trade negotiations with partners from India to the EU and, most recently, China​1–4​. However, in the search for growth, we risk overlooking a far more fundamental question: how do we use these high‑level discussions to safeguard access to the medicines the NHS depends on?

Put simply, we need to focus less on artisan cheese and more on antibiotics.

The NHS runs on off‑patent medicines — generics and biosimilars. These products account for more than 85% of all patient prescriptions and, through competition, save the government more than £20bn each year​5,6​. Around one-quarter of NHS medicines are manufactured in the UK, but all rely on supply chains that stretch across Europe, India and China​7​. In a crisis, we depend heavily on the continued goodwill and cooperation of international partners and now, outside the EU, the UK is no longer guaranteed access to the medicines it needs. We must compete with other countries for limited allocations and make the commercial case for adequate supply.

Our relationship with the EU is reaching a critical juncture. Since Brexit, the UK has chosen to maintain near‑total alignment with EU medicines regulation to avoid unnecessary friction. But this has come despite clear imbalances in the Trade and Cooperation Agreement​8​.

This uneven playing field has encouraged significantly more factories … to be located on the continent rather than here

For example, medicines manufactured in the UK cannot be released for sale in the EU unless they undergo additional EU‑based testing and certification — even though the UK accepts EU‑tested medicines without equivalent barriers. This uneven playing field has encouraged significantly more factories, and the economic and resilience benefits that come with them, to be located on the continent rather than here.

Beyond this, further areas of divergence are developing fast, and the UK must now decide whether to follow because some EU legislation still applies to Northern Ireland, which in turn is reliant upon Great British alignment and supply chains. Or should the UK forge its own path? These choices must be front and centre in any future discussions with the EU about our trading relationship — our medicines supply could depend on it.

The decisions we make today will determine whether patients benefit from a resilient, competitive supply of affordable medicines — or whether we drift into a regulatory system designed for a different market, with different pressures and different priorities.

A crucial example is the EU’s on the reform of its pharmaceutical legislation, four years in the making​9​. It represents a major overhaul of everything from licensing to environmental rules to supply chain obligations. However, the UK should resist the temptation to simply mirror it as has been our instinct previously, because some of the processes duplicate what we already have. Sovereignty gives us the freedom to choose whast works for our system — and the responsibility to reject what does not.

Future discussions with the EU should create space for the UK to scrutinise this legislation properly and, where necessary, develop a bespoke but complementary approach. That means prioritising predictability for manufacturers, minimising friction at borders, seizing environmental opportunities where it makes good business sense and ensuring proportionate, workable rules that support — rather than hinder — supply resilience.

Medicines resilience needs to be elevated as a strategic priority of the same stature as defence

The Critical Medicines Act (CMA) is another area for consideration​10​. Via the act, the EU is well advanced in its plans for a strategic response to the resilience of the medicines supply chain. The UK’s plans are much less developed and we risk being left behind by a coordinated EU approach. Our involvement in the act should be another key negotiating point and the UK should be considered a favoured nation for medicines production in the same way as the four European Free Trade Association (EFTA) countries. This would benefit both parties and the medicine resilience of the continent.

More widely, medicines resilience needs to be elevated as a strategic priority of the same stature as defence. Only three countries in Europe have fully capable nuclear weapons in the form of the UK, France and Russia​11​. As the UK has broad discussions with the EU around sharing of military capability​2​, medicines resilience should form part of the same quid pro quo conversations.

If whisky and olives can make it onto the negotiating table with international partners, surely the medicines that keep our health service running must too.

The UK cannot afford to treat medicines regulation as a side dish in its talks with the EU — it belongs at the centre of the plate.


  1. 1.
    Chinese whisky tariff cut to come into force on Monday. BBC News. January 2026. Accessed March 2026. https://www.bbc.co.uk/news/articles/c4g54xzzze0o
  2. 2.
    Francis S. The new UK-EU deal at a glance. BBC News. May 2025. Accessed March 2026. https://www.bbc.co.uk/news/articles/czdy3r6q9mgo
  3. 3.
    Comprehensive Economic and Trade Agreement between the United Kingdom of Great Britain and Northern Ireland and India. Department for Business and Trade. July 2025. Accessed March 2026. https://www.gov.uk/government/collections/comprehensive-economic-and-trade-agreement-between-the-united-kingdom-of-great-britain-and-northern-ireland-and-india
  4. 4.
    Cooke M. Cheese, olives and sausages could become cheaper for British shoppers under EU deal. The Independent . August 2025. Accessed March 2026. https://www.independent.co.uk/news/uk/politics/brexit-eu-deal-cheese-sausages-b2814830.html
  5. 5.
    Prescription Cost Analysis – England 2024/25. NHS Business Services Authority . June 2025. Accessed March 2026. https://www.nhsbsa.nhs.uk/statistical-collections/prescription-cost-analysis-england/prescription-cost-analysis-england-202425
  6. 6.
    Medicines UK: Our approach. Medicines UK. Accessed March 2026. https://www.medicinesuk.com
  7. 7.
    Manufacturing. Medicines UK. Accessed March 2026. https://www.medicinesuk.com/key-issues/manufacturing/
  8. 8.
    The EU-UK Trade and Cooperation Agreement. European Commission. April 2021. Accessed March 2026. https://commission.europa.eu/strategy-and-policy/relations-united-kingdom/eu-uk-trade-and-cooperation-agreement_en
  9. 9.
    Reform of the EU pharmaceutical legislation. European Medicines Agency. December 2025. Accessed March 2026. https://www.ema.europa.eu/en/about-us/what-we-do/reform-eu-pharmaceutical-legislation
  10. 10.
    Critical medicines Act. European Commission. March 2025. Accessed March 2026. https://health.ec.europa.eu/medicinal-products/critical-medicines-act_en
  11. 11.
    Which countries have nuclear weapons? ICAN. Accessed March 2026. https://www.icanw.org/nuclear_arsenals
Last updated
Citation
The Pharmaceutical Journal, PJ March 2026, Vol 317, No 8007;317(8007)::DOI:10.1211/PJ.2026.1.402538

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