UK DHSC revises medicines export-restriction list: adds Nelarabine, removes ten products (November 2025)

Mechanism

DHSC maintains a standing list of medicines subject to a domestic-supply-protection export restriction under regulation 43(2) of the Human Medicines Regulations 2012 — a post-Brexit / post-shortage-era instrument that bars wholesale dealers from parallel-exporting or hoarding named products so as to keep them available for UK patients. The list is revised on a rolling basis (multiple times a year, most recently again on 10 July 2026 per the GOV.UK publication history) as shortage risk shifts across products.

The 6 November 2025 revision added Nelarabine, a chemotherapy agent used for T-cell acute lymphoblastic leukaemia/lymphoma, and removed ten products previously restricted — including the neuromuscular blocking agents Atracurium and Cisatracurium and the antibiotic Erythromycin — implying DHSC assessed supply risk for those ten as resolved. Non-compliant wholesale dealers face immediate MHRA licence suspension, the same enforcement mechanism used across the whole list.

Downstream implications

• Signals continued UK reliance on administrative export controls (rather than stockpiling

alone) to manage medicine-shortage risk five years post-Brexit; the mechanism is now a standing piece of regulatory architecture rather than an emergency measure.

• Removal of ten products from restriction is itself informative — DHSC's shortage-risk

assessment reads as improving for anaesthesia/neuromuscular-blocker and antibiotic supply chains even as it tightens for a niche oncology product.

Open questions

• No public DHSC rationale disclosed for why Nelarabine specifically entered supply risk in

November 2025 (manufacturing disruption vs. demand shift) — GTA source access requires authentication and GOV.UK does not publish per-product justification.