Indian unlicensed-medicine supplier into UK MHRA Specials, EU Article 5 national schemes, Australia TGA, Singapore HSA and GCC compassionate-use channels.
Looking for an Indian supplier of an unlicensed medicine for a named patient, a specials line, a compassionate-use programme or a special-access programme in the UK, EU, Australia, Singapore or the GCC? This is the manufacturer-facing side of that supply: M Care sits between Indian WHO-GMP plants and the local authorised channel (UK MS-licence holder, EU national-scheme importer, TGA-authorised prescriber, HSA Importer's Licence holder, GCC compassionate-use programme), prepares the manufacturer-side documentation pack matched to each regime, and freights the consignment to your bonded warehouse or hospital goods-in. We do not hold any local unlicensed-medicine authorisation ourselves and we say so plainly.
One Indian manufacturer-side supplier across the major unlicensed-medicine regimes.
United Kingdom
Regulation 167 of the Human Medicines Regulations 2012 (named-patient import via WDA(H) wholesaler with unlicensed-medicines authorisation) plus the MHRA Specials (MS) licence route under the Medicines Act 1968 (UK manufacture or assembly of an unlicensed product). We supply finished-dose unlicensed product into Reg 167 importers and APIs with open DMF into MS holders. Detail at named-patient import UK and MHRA Specials.
European Union
Article 5 of Directive 2001/83/EC permits Member States to authorise unlicensed supply for special clinical needs; implementation is national. Germany: Einzelimport under §73(3) AMG. France: AAC under ANSM (compassionate access, the post-2021 successor to ATU). Italy: Legge 648/96. Netherlands, Spain, Sweden, Belgium: equivalent national schemes. We supply into each country's licensed special-access importer.
Australia (TGA)
Special Access Scheme Category A (notification within 28 days for seriously ill patients), Category B (TGA approval pre-supply), Category C (notified streamlined products), plus the Authorised Prescriber scheme for pre-approved doctors. We supply manufacturer-side; the prescriber or sponsor handles the SAS or AP paperwork. Current GMP certificate and CDSCO export NOC accompany every consignment for TGA scrutiny.
Singapore (HSA)
Authorised Prescriber scheme under the Health Sciences Authority lets a registered medical practitioner pre-authorise supply of specified unapproved therapeutic products to named patients. The Singapore Importer's Licence is held by an HSA-licensed distributor that receives the consignment. We supply from Indian WHO-GMP into the Singapore distributor's bonded warehouse.
GCC compassionate use
Case-by-case authorisations rather than a single regime. Saudi SFDA Compassionate Use Programme through the hospital pharmacy and SFDA drug-evaluation department. UAE MoHAP / DHA / DoH case-by-case unregistered import via the licensed local agent. Kuwait, Qatar, Oman, Bahrain ministry-approved channels through hospital pharmacy applications. We match the documentation pack to each authority's compassionate-use template.
Our role, plainly stated
M Care is the Indian merchant exporter on the supply chain. We do not hold any local unlicensed-medicine authorisation in our own name (no UK WDA(H), no EU national-scheme importer status, no TGA sponsorship, no HSA Importer's Licence, no GCC unregistered-import authorisation). Those authorisations are always held by your local channel partner. Our work is manufacturer-facing: sourcing from Indian WHO-GMP plants, preparing the documentation pack, freight, on-arrival reconciliation.
When buyers actually need an Indian unlicensed-medicine supplier.
Molecule discontinued by the originator
The originator stops commercial production (commercial decision, manufacturing change, plant closure), but the clinical need persists. Indian WHO-GMP generics continue producing the molecule at scale. Specialist pharmacies and hospital procurement teams source the unlicensed-route generic from India.
Paediatric strength not commercially produced
The licensed adult strength exists; the paediatric weight-band strength does not. Compounding pharmacies and paediatric hospitals source the API or the paediatric finished-dose from Indian WHO-GMP partners that produce the paediatric strength for other markets (often Global Fund / PEPFAR).
Brand variant the patient has tolerated abroad
A patient who has tolerated a specific Indian generic brand of their molecule needs continuity of supply after moving country, or after the local generic is recalled. Named-patient supply (UK Reg 167, EU national schemes, TGA SAS, HSA, GCC compassionate use) brings the same specific Indian generic across.
Tropical-disease or specialist molecule not registered locally
Antimalarials, antitubercular regimens, antiparasitic agents, niche oncology and rare-disease molecules registered widely in LMIC markets but not in the UK, EU, Australia, Singapore or specific GCC states. Named-patient supply against a returning traveller, an imported clinical case or a refugee-health programme.
Shortage cover for a registered medicine
The licensed local product is in shortage (supply disruption, recall, demand spike). Hospital pharmacy procures the unlicensed alternative against a regulatory waiver or shortage exemption, often from an Indian WHO-GMP source already producing the molecule for tender markets.
Compassionate-use access to a newer molecule
The originator has not yet launched in the destination market, or has launched only in a different formulation. The local prescriber's compassionate-use application authorises supply of the Indian generic for a named patient with a confirmed clinical need, often in oncology, haematology, transplant medicine and rare-disease therapy.
What ships with every unlicensed-medicine consignment.
Manufacturer-side documentation matched to whichever local authorisation the destination importer, MS holder, prescriber or hospital is filing.
Certificate of Analysis (batch-specific)
HPLC assay against the agreed monograph, related substances per Ph.Eur./USP/JP, water content by Karl Fischer, dissolution profile, content uniformity, hardness, friability for solids; sterility, pyrogen, particulate count and container integrity for injectables; reconstituted-product stability for oral suspensions.
Method of Analysis + CoPP
Method of Analysis cross-referenced to the manufacturing site's QC SOPs. Certificate of Pharmaceutical Product (CoPP) issued by CDSCO India in the WHO recommended format, authenticated through the Indian Ministry of External Affairs and the destination-country embassy where the local authorisation requires it.
WHO-GMP / EU-GMP certificate + Manufacturing Licence
Certificate of GMP Compliance for the manufacturing site (WHO-GMP standard, with EU-GMP from a named competent authority where the destination prefers EU-GMP-inspected supply for the MS, EU national scheme, TGA or HSA route). Manufacturing licence apostilled where the local authority requires it.
CDSCO export NOC + Certificate of Origin
CDSCO export No Objection Certificate for the consignment. Certificate of Origin attested by the Indian chamber of commerce. Customs invoice with the destination-required HS code per molecule.
Drug Master File (open part)
Open-part DMF in CTD Module 3 format for the API where the destination MS licence, EU national scheme or GCC application requires API-level technical detail; restricted-part DMF filed separately to the QP / Responsible Person on request.
Cold-chain validation pack (where applicable)
Passive-validated container validation report, continuous in-transit temperature-logger trace (Sensitech / Berlinger Q-tag / ELPRO), pre-dispatch and on-arrival temperature reconciliation. Mandatory for oncology biologicals, peptide hormones, vaccines and any 2-8 deg C molecule.
Molecule · strength · volume · destination · regime. One working day to a quote.
- Send us the specifics. Molecule (INN), grade (finished dose or API), strength, pack or kg, destination country, the local regime under which supply is authorised (UK Reg 167 / MS licence, EU national scheme, TGA SAS or AP, HSA AP, GCC compassionate use), the importer or authorised prescriber or hospital pharmacy on the receiving end, and your target arrival window.
- We confirm route and source. Match the molecule to the right WHO-GMP partner line for the destination (EU-GMP-capable line where the destination prefers it; WHO-PQ-listed line where the molecule is on WHO PQ), confirm the documentation pack the local regime requires, return commercial offer inside one working day.
- Order, produce, release, ship. QC release on the Indian side. Ambient or validated cold-chain dispatch. In-transit temperature logging. On-arrival reconciliation against the importer's goods-in.
- Documentation handover. CoA, CoPP, GMP, manufacturer licence, CDSCO export NOC, DMF (open part), cold-chain validation pack land with the consignment. Notification template prepared where the local authority requires it (MHRA 28-day for Reg 167, TGA SAS Category A 28-day notification, HSA application).
- Pharmacovigilance and resupply. Named PV contact opened for the consignment's shelf life, ADR routing to the Indian manufacturer's QA, forward plan for the next batch so your dispensing window has predictable resupply.
The deeper-detail pages on the regimes we supply into.
UK named-patient import (Reg 167)
Deep-dive on the UK Regulation 167 mechanics: WDA(H) wholesaler, MHRA 28-day notification, the NHS England Specialist Pharmacy Service framework, Northern Ireland post-Windsor-Framework position, NHS Trust Specials units, and oncology / haematology / paediatric Specials.
UK MHRA Specials (MS licence)
Deep-dive on the MS licence route: UK in-country manufacture or assembly under the Specials (MS) Manufacturer's licence, API supply with open DMF, EU-GMP partner lines, the MHRA notification process and the cold-chain Specials lane.
CTD dossier preparation
The full CTD / eCTD dossier service for regulatory registration in any destination market, plus the Module 1 country-specific assembly for unlicensed-medicine notifications.
WHO-GMP & PQ compliance
How we match orders to the right WHO-GMP-listed manufacturer line and the WHO Prequalification status check for Global Fund / PEPFAR / national programme procurement.
UK market detail
The full UK pharmaceutical export-supply page with NHS, private hospital, MHRA Specials and named-patient procurement mechanics in one place.
All export markets →
49 export markets across EU, UK, GCC, Africa, ASEAN, LATAM. Country-specific regulatory and procurement detail per market.
Unlicensed medicine supply, the specific questions.
What is an unlicensed medicine and why would a hospital need one supplied from India?
An unlicensed medicine is a pharmaceutical product that does not hold a marketing authorisation in the destination country. The clinical reason is almost always a special need: a molecule discontinued by the originator, a paediatric strength not commercially produced, a brand variant the patient has tolerated abroad, a tropical-disease medicine not registered locally, an orphan medicine the local importer cannot procure, or a regulatory gap during a shortage. Indian WHO-GMP manufacturers produce the largest generic-medicine catalogue globally and are the natural source of unlicensed supply into the UK, EU, Australia, Singapore and GCC markets where the molecule itself is unregistered or unavailable. M Care is the Indian manufacturer-side exporter; the importer in your country holds the local unlicensed-medicine authorisation under the regime applicable to your jurisdiction.
What's the UK regime for unlicensed medicines and how do you supply into it?
Two parallel UK regimes. Regulation 167 of the Human Medicines Regulations 2012 governs the import of a finished unlicensed medicine for a named patient on the request of a doctor, dentist or supplementary prescriber. The UK importer must hold a WDA(H) wholesale dealer's licence with the unlicensed-medicines authorisation; the import is notified to MHRA at least 28 working days before, with the standard MHRA notification template. Specials (Manufacturer's Specials, MS) licence under the Medicines Act 1968 covers in-UK manufacture or assembly of an unlicensed medicine. We supply finished-dose unlicensed product into Reg 167 importers and APIs with open DMF into MS licence holders. Detail at named-patient import UK and MHRA Specials.
What's the EU regime for unlicensed medicines? Does Article 5 apply?
Yes. Article 5 of Directive 2001/83/EC permits Member States to authorise the supply of unlicensed medicines for special clinical needs, but the implementation is national, not EU-central. Germany operates the Einzelimport (single-import) route under §73 paragraph 3 of the Arzneimittelgesetz, with the pharmacy filing the import for a named patient against a prescription. France runs the Autorisation d'Accès Compassionnel (AAC, the post-2021 successor to ATU) under ANSM, plus Authorisation for Accelerated Access (AAP) for compassionate use of unauthorised products. Italy uses Legge 648/96 to authorise specific molecules for special-need supply. Netherlands, Spain, Sweden and Belgium operate equivalent national schemes. We supply manufacturer-side from Indian WHO-GMP sites; the national-scheme importer in each EU country files the special-access authorisation and the regulatory paperwork carries through the consignment.
What's the Australian regime? TGA Special Access Scheme?
Yes, three pathways under the Australian TGA. Special Access Scheme Category A is a notification route for patients defined as 'seriously ill where death is reasonably likely to occur' — the prescriber notifies TGA within 28 days of supply. Category B requires TGA approval before supply, used for non-Category A patients and most chronic indications. Category C covers products notified by TGA as eligible for streamlined supply. The Authorised Prescriber scheme pre-authorises a specific doctor to supply specified unapproved products to specified patients without per-patient TGA approval — useful for ongoing programme supply. We supply manufacturer-side; the Australian prescriber or sponsor handles the SAS or Authorised Prescriber paperwork. CDSCO export documentation and a current GMP certificate accompany every consignment for TGA scrutiny.
How does the Singapore HSA special-access route work?
Singapore's Health Sciences Authority (HSA) operates the Authorised Prescriber scheme analogous to Australia's TGA: a registered medical practitioner is pre-authorised to import and supply specified unapproved therapeutic products to named patients. The prescriber lodges the application via the HSA's electronic system with patient-specific clinical justification. Imports also need an Importer's Licence held by an HSA-licensed distributor. We supply manufacturer-side from Indian WHO-GMP into the Singapore distributor's bonded warehouse against the prescriber's authorisation. CDSCO export documentation, a current GMP certificate and a Certificate of Pharmaceutical Product (CoPP) accompany every consignment.
What about GCC unregistered-medicine supply?
The GCC operates case-by-case unregistered-import authorisations rather than a single regime. Saudi Arabia (SFDA) runs the Compassionate Use Programme via the hospital pharmacy and SFDA's drug-evaluation department, with patient-specific approval against an Indian or other-origin CoPP and GMP package. UAE (MoHAP, DHA, DoH) authorises case-by-case unregistered import through the licensed local agent. Kuwait, Qatar, Oman and Bahrain each operate ministry-approved channels through hospital pharmacy applications. M Care supplies manufacturer-side from Indian WHO-GMP into the GCC importer or hospital, with the documentation pack matching the local authority's compassionate-use template. Documentation includes CoA, GMP certificate, manufacturer licence, CoPP authenticated through MEA India and the destination embassy, and Arabic bilingual artwork on request.
Does M Care hold any unlicensed-medicine authorisation in the destination country?
No. M Care is an Indian merchant exporter and we say so plainly. We do not hold a UK WDA(H), an EU national-scheme importer status, a TGA sponsorship, an HSA importer's licence or a GCC unregistered-import authorisation in our own name; those local authorisations are held by the importer, MS licence holder, authorised prescriber, distributor or hospital pharmacy in your jurisdiction. Our role is manufacturer-facing: we sit between the Indian WHO-GMP plant and your local authorised channel, prepare the manufacturer-side documentation (CoA, GMP certificate, CoPP, CDSCO export NOC, stability data, DMF for API where applicable) and freight the consignment to your bonded warehouse or hospital goods-in. The local regulatory paperwork is always yours; the supply discipline and documentation is ours.
What documentation accompanies an unlicensed-medicine consignment from India?
Every consignment ships with: a batch-specific Certificate of Analysis against the agreed monograph (HPLC assay, related substances per Ph.Eur./USP/JP, water content, dissolution, content uniformity, sterility and pyrogen tests for injectables); the Method of Analysis; Certificate of GMP Compliance for the manufacturing site (WHO-GMP or EU-GMP as applicable); manufacturing licence; Certificate of Pharmaceutical Product (CoPP) issued by CDSCO India, authenticated through the Indian Ministry of External Affairs and the destination-country embassy where required; CDSCO export NOC; Certificate of Origin (chamber-attested); destination-language pack insert; temperature and humidity logs from pre-dispatch through on-arrival; and the Drug Master File open-part (CTD Module 3) where API or finished-dose technical detail is needed for the importer's QP or PV file. Tightened cold-chain documentation (passive-validated container validation report plus continuous temperature-logger trace) accompanies oncology biologicals, peptides, vaccines and other cold-chain Specials.
One regime, one molecule, one named-patient supply, or a programme. Tell us which.
Molecule, grade, volume, destination country, the local regime under which supply is authorised, your authorised channel (importer / MS holder / prescriber / hospital). We return commercial and documentation inside one working day from the Mumbai desk.