Ukraine to allow OTC medicine sales at petrol stations, restrict retail prices for medicines at pharmacies in public hospitals

From 3 March 2026, Ukraine will allow petrol stations to sell OTC medicines under specific licensing and storage conditions, and pharmacies in public healthcare facilities will be required to sell medicines priced according to the three cheapest options in the National Price Catalogue for the same INN, dosage, and form.

The Cabinet of Ministers of Ukraine passed these measures on 26 December 2025 through resolutions No. 1802 and No. 1803, which introduced amendments to the Licensing conditions for manufacture, wholesale and retail trade, and import of medicinal products.

Key changes

OTC medicines sales at petrol stations (Resolution No. 1803)

Petrol station can sell OTC medicines by staff or via vending machines without establishing a pharmacy or pharmacy unit, if:

• the storage requirements are met; 
• incoming quality control is performed by an authorised pharmacist.

Petrol stations must:

• apply for and obtain a retail pharmaceutical licence;
• have a designated area for storing medicines separately from other goods.

The Ukrainian government has legitimised a new retail channel for OTC medicines, creating significant business opportunities for petrol retailers. This development opens the door for:

• direct OTC sales at petrol stations under proper licensing and compliance;
• strategic partnerships and joint ventures between petrol and pharmaceutical retailers;
• expansion beyond OTC medicines, specifically food supplements and medical devices since their retail sales is not limited to licensed pharmacies.

Price restrictions for pharmacies in public healthcare facilities (Resolution No. 1802)
Pharmacies inside public (i.e. state and municipal owned) hospitals and clinics may only sell medicines priced among the three cheapest positions in the National Price Catalogue (by INN, dosage, form).

This restriction does not apply to: 

• medicines reimbursed under the “Affordable medicines” programme; 
• narcotic, psychotropic, and precursor-containing medicines (with certain restrictions);
• extemporaneous preparations (i.e. compounded per prescription).

The restriction to sell only medicines priced among the three cheapest positions in the National Price Catalogue is an unusual move that will:

• limit product assortment, reducing a retailers’ revenue from higher-margin products and demotivating expansion at public healthcare facilities;
• require procurement strategy adjustments to comply with pricing rules;
• encourage focus on reimbursed medicines and extemporaneous preparations, which remain exempt from the discussed price restrictions.

For more information on these new pharmaceutical regulations in Ukraine, contact your CMS client partner or the CM expert: Borys Danevych.