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TL;DRPharmaceutical wholesale (Pharmagroßhandel) is the German distribution stage between manufacturer and pharmacy, in which a licensed wholesaler buys finished medicines from manufacturers, holds them in stock and supplies pharmacies, usually several times a working day, under a wholesale distribution authorisation granted by the competent state authority.
In Germany the activity is licence bound. Under §52a AMG, anyone operating a pharmaceutical wholesale business needs a wholesale distribution authorisation (Großhandelserlaubnis), granted by the competent authority of the federal state in which the site is located. The applicant must show suitable premises and equipment for proper storage and distribution, must name a responsible person with the required expertise, and must commit in writing to the rules for proper wholesale operation. Pharmacies acting within normal pharmacy business are exempt, and manufacturers holding a permit under §13 or §72 AMG are automatically entitled to wholesale their own products. The authority decides within three months.
The economic function is transaction reduction. Rather than every pharmacy ordering every article directly from every manufacturer, the wholesaler consolidates the range in one warehouse and one order. PHAGRO, the German full-line wholesalers' association, states that its members hold on average 107,000 different articles in stock and deliver to each German pharmacy three times a day on average.
The Versorgungspflicht is the statutory public-supply obligation in §52b AMG. Marketing authorisation holders and wholesalers that actually place an authorised medicine on the German market must ensure an appropriate and continuous supply of that medicine so that patient demand in Germany is covered. The obligation is graded by role.
Note what the statute does not say: it fixes no delivery deadline in hours. The wording is "werktäglich innerhalb angemessener Zeit", on working days within an appropriate time. The familiar same-day or next-morning service level is a market standard, not a statutory figure.
§52b also carries reporting duties around supply shortages. Under §52b Abs. 3a AMG, marketing authorisation holders must immediately inform hospitals of known supply shortages of prescription medicines used in inpatient care. Under §52b Abs. 3e AMG, on request by the BfArM, marketing authorisation holders, manufacturers and wholesalers must report electronically on available stock, production including the manufacturing site of the active ingredients actually used, sales volume and impending shortages. Hospital pharmacies and hospital-supplying pharmacies must report available stock on the same basis. §52b Abs. 3f adds a regular reporting cycle, at most every eight weeks, for finished medicines on a BfArM list, and the BfArM may also require regular reporting from wholesalers. Under §52b Abs. 3d AMG the federal higher authority may order measures including quota allocation and stockholding. See also Lieferengpass and Versorgungsmangel.
The distinction that matters commercially is between the full-line wholesaler carrying the supply obligation and the short-line or specialist wholesaler that does not carry it in the same breadth. Only the full-line wholesaler is defined in §52b Abs. 2 Satz 2 AMG. Short-line and specialist wholesale is a market category, not a defined statutory term.
| Criterion | Vollsortimenter (full-line wholesaler) | Kurz- / Spezialgroßhandel (short-line / specialist) |
|---|---|---|
| Legal definition | Defined in §52b Abs. 2 Satz 2 AMG | Not separately defined; covered by §52a AMG licensing |
| Range | Complete, manufacturer-neutral range of pharmacy-only medicines | Selected range: fast movers, a therapeutic area, cold chain, narcotics, imports |
| Minimum stock | At least two weeks' average demand, four weeks for medicines on the §35 Abs. 5a SGB V list | No statutory minimum stock requirement |
| Supply obligation | Full: demand-appropriate, continuous delivery to customer pharmacies (§52b Abs. 3 Satz 1) | Limited: same duty, but only for the range actually held (§52b Abs. 3 Satz 2) |
| Manufacturer's duty to supply it | Yes, manufacturers must deliver to full-line wholesalers (§52b Abs. 2 Satz 1) | No equivalent statutory entitlement |
| Typical role | Base supply for the whole pharmacy market | Price-driven or logistics-driven top-up supply |
For finished medicines for human use, §2 AMPreisV sets the wholesale mark-up when the wholesaler supplies pharmacies or veterinarians: a fixed surcharge of 73 cent plus VAT, and on top of the manufacturer's list price excluding VAT a variable surcharge of at most 3.15 percent, capped at 37.80 euro. The basis is the price at which the manufacturer supplies under §78 Abs. 3 or 3a AMG. The graduated percentage bands set out in §2 Abs. 2 and Abs. 3 AMPreisV apply to finished medicines intended for use in animals.
The cap is the structural point. On a 10 euro manufacturer's list price the wholesaler may take about 1.05 euro. On a 1,200 euro price the variable part is capped at 37.80 euro, so the total mark-up is roughly 38.53 euro, a much smaller share of the value handled. High-priced medicines therefore consume working capital and risk without proportionate compensation. PHAGRO puts the average wholesale share at 2.7 percent of the final price. How the wholesale mark-up sits inside the full price cascade up to the pharmacy retail price is set out under Apothekenverkaufspreis, and the statutory rebates that also load that cascade under Herstellerabschlag.
Ordering is almost fully electronic. PHAGRO reports that 98 percent of pharmacy orders reach the wholesaler digitally and that a wholesaler needs on average 35 minutes from order receipt to readiness for despatch. The dominant interface is MSV3, the German standard for real-time availability queries and electronic ordering between pharmacy and wholesaler: the pharmacy system asks whether an article is deliverable and then places the order with an immediate status response. Structured business documents such as orders, despatch advices and invoices between manufacturers and wholesalers additionally run over EDI. Every one of these messages is keyed on the PZN, which is why the article master data behind the PZN determines whether an order can be placed at all.
For anyone building or buying software around this stage, the wholesale question is rarely "who delivers" and almost always "what is the current state of this article". Three fields carry most of the weight: the distribution status, which says whether the article is currently in distribution or has a date of withdrawal from distribution; the shortage report, which says whether the marketing authorisation holder has notified the BfArM; and the price cascade, which says what the article costs at each stage. On pharmazie.com these sit together per PZN:
The honest limitation: pharmazie.com does not hold a wholesaler's live warehouse stock as a data field. Distribution status, shortage reports and prices are master data updated daily from licensed sources, not a stock ticker. Availability queries and ordering via the MSV3 client are live and in production; only the MSV3 server side, offering supply yourself, is in a 2026 pilot phase. For direct-supply products no live availability exists at all, because no wholesaler holds the article.
