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Wholesale Dealers Records

It has been brought to our attention that the record keeping requirements for wholesale dealers, as set out in the Veterinary Medicines Regulations and Veterinary Medicines Guidance Note no. 8 are excessive when applied to wholesalers operating solely under the Exemptions for small pet animals scheme. The main reason such records are required to be kept is to ensure that products are easily traced in the event of an emergency product recall being needed.

The VMD agreed to consider this issue and with a representative from the Ornamental Aquarium Trade Association (OATA), visited a wholesaler on a fact finding mission to gain a better understanding of how the Regulations impact on wholesale businesses.

What we were shown was that keeping detailed records of all incoming transactions, to include batch numbers, is onerous and that the actual record keeping process itself involved some considerable costs which outweighed the value of the product sales. It was also demonstrated that the records kept by wholesalers often duplicate information held by manufacturers.

The Exemptions for small pet animals scheme aims to fill a therapeutic gap in the market for certain minor species and it was not our intention to create an unnecessary burden for businesses.

Having fully considered this issue we are assured that should the need arise, products can be easily recalled by asking retailers to return everything they have in stock. The records kept by manufacturers, plus the supply records kept by wholesalers will enable us to facilitate such a recall.

We are therefore of the opinion that wholesale dealers marketing products under the Exemptions for small pet animals scheme will no longer be required to keep wholesale records that duplicate manufacturers records. Wholesalers will of course wish to keep records pertinent to their business. We will not be amending the legislation to reflect this, simply revising our current internal policy. This change in policy will be effective from 1 January 2012.

Last Updated: 11 January 2012

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