Exploring the Feasibility of offering a GDP-Compliant Medicine E-Commerce Fulfilment Service

Abstract

This thesis examines how the Dutch legislative and institutional framework determines the opportunities and limitations for non-pharmaceutical fulfilment providers in the B2C fulfilment of medicines. It explores the legal, organisational and market conditions that would allow a non-pharmaceutical company to offer an e-commerce fulfilment service that complies with Good Distribution Practice (GDP), with using PostNL Fulfilment as a case study. An exploratory mixed-methods research design is employed, combining literature and desk research on the Dutch pharmaceutical supply chain and legislative context, a stakeholder analysis, semi-structured interviews with pharmacists and other stakeholders, and the development of eight fulfilment scenarios. These scenarios are analysed using a framework of legal requirements and market-oriented design criteria. An actor-level implication analysis then assesses the institutional and administrative consequences.

The results show that pharmaceutical logistics in the Netherlands are regulated by a pharmacy-focused licensing system based on roles and locations, in which pharmacists remain responsible for dispensing medicines and ensuring patient safety. Non-pharmaceutical participation is therefore only possible through carefully regulated hybrid arrangements that ensure compliance with GDP, verifiable separation of responsibilities and robust contractual oversight. While none of the examined scenarios are explicitly on legal basis, the feasibility decreases as the executing party's role becomes more similar to that of a full logistics back office, comparable to the operational structure typically observed in conventional non-pharmaceutical fulfilment services. This is due to interpretative grey areas at the interface between dispensing and logistics, as well as the centralisation of multiple pharmacies and the associated distribution of roles and medication flows. Market feasibility is greatest in predictable segments with large volumes (e.g. repeat prescriptions), although it remains structurally constrained by the highly regulated nature of the pharmaceutical supply chain, which is characterised by a limited number of dominant actors who largely shape market access and operational conditions. In general, scalable implementation requires step-by-step expansion and clarification of regulations/legislation and governance designs that can be monitored and audited.