The Dutch route

A brand company owns the customer, the funnel and the platform. A Netherlands-licensed pharmacy dispenses and ships. Prescribers are contracted, often licensed somewhere other than the destination country. It exists because the Netherlands is the one EU jurisdiction of scale that combines open pharmacy ownership with legal prescription mail order.

The live examples are nameable: Kamille Apotheek B.V. (Venlo, KvK 88967425) fulfils for Voy Germany and Formel Skin. Helix Pharmacy B.V. (Heerlen, KvK 84408871) fulfils for DoktorABC. Prime Pharmacy B.V. (Belfeld, KvK 81205864) serves Apomeds, Medikaat and Formel Skin. Stadsapotheek Venlo dispenses for Fernarzt in the documented Berlin–London–Venlo structure.

The ABDA factsheet, which is the source almost everyone works from, states that only 7 of 27 EU member states permit mail order of prescription medicines at all: Germany, Denmark, Estonia, Finland, Malta, the Netherlands and Sweden. Everywhere else the destination country closes the door regardless of what the Dutch pharmacy is licensed to do.

Two entries on that list of seven are wrong, in opposite directions.

Lithuania belongs on it and is missing. Ministry of Health order V-1491, effective 12 July 2022, established remote retail trade in prescription medicines, and the VVKT maintains a public register of authorised remote pharmacies, nineteen of them at the point of writing.

Malta is on it and does not belong. The Malta Medicines Authority, on the page that serves as Malta’s national register under article 85c(4) of Directive 2001/83/EC, states that the legislation caters for physical community pharmacies and does not provide for the establishment of internet pharmacies, and that none exist. Reading Cap. 458 and its subsidiary legislation confirms it: no mention anywhere of distance selling, the internet, information society services or the EU common logo. Malta appears never to have transposed article 85c. What it does permit is inbound receipt by Maltese residents of medicines bought from pharmacies established elsewhere, which is a patient-side permission, not an operator-side one.

So the count survives at seven and the membership changes: Germany, Denmark, Estonia, Finland, Lithuania, the Netherlands and Sweden. The lesson is not that the number was wrong. It is that two of seven entries failed when checked against national primary sources, which is a poor hit rate for a fact that every logistics plan in this category rests on. Check the remaining five before relying on them.

Austria is categorically closed. France, Belgium, Ireland, Italy, Spain, Poland, Czechia, Slovakia, Slovenia, Croatia, Bulgaria, Romania, Latvia, Cyprus and Luxembourg are closed, several by instruments issued or restated in 2025 and 2026. Luxembourg goes further than closure: the Ministry states that permitting prescription distance selling is not planned. The UK is a third country post-Brexit.

Even corrected, the conclusion holds. The Dutch route is an NL-to-Germany route, with the Nordics and Baltics as small extras. That is still a very good route, Germany is the largest telehealth-driven GLP-1 market in Europe, but it is one country, not a continent. Swapping Malta for Lithuania trades 0.55m people for 2.8m, not a strategy.

The commercial rationale for dispensing from the Netherlands into Germany is that an EU mail-order pharmacy escapes Germany's fixed Rx pricing, which a German pharmacy cannot. The ECJ said so in Deutsche Parkinson Vereinigung (C-148/15, 2016) and the BGH reaffirmed it for Rx bonuses in July 2025.

But a 2024 Munich appellate ruling is reported to have upheld price binding against foreign senders as justified consumer protection, and the 2020 VOASG reinstated uniform pricing through social-insurance law. These cannot both be fully right for the same category of sale.

This is the single highest-value unresolved question in the atlas. If price binding applies, the Dutch route buys legality but not price freedom, and the entire commercial case changes. One German pharmaceutical lawyer, one afternoon.

Article 67 of the Dutch Geneesmiddelenwet still prohibits internet prescribing to a patient the prescriber has never met. It has never been repealed. What the whole market runs on is the Beleidsregel voorschrijven via internet of 11 April 2023, a formal non-enforcement policy conditional on a physical exam not being medically necessary and the prescriber having and consulting the patient's medication history. Video, audio and chat count. Phone alone and fax do not.

A future minister can withdraw it with a Staatscourant notice. And the inspectorate is visibly leaning in: it ordered Prime Pharmacy to stop dispensing in July 2025, it is investigating around ten online prescription companies, and in February 2026 it told a national TV programme that in the Netherlands a new patient must always be phoned or seen.

The Dutch route is a compliance-arbitrage structure, and arbitrage structures have a shelf life. It exists because Germany forbids what the Netherlands allows, and it survives because a Dutch minister currently chooses not to enforce article 67. Both can change with a signature.

That does not make it a no. It makes it a time-boxed yes, something you enter knowing the exit, not something you build a decade on.