Commentaries: Art. 20

Doctors and veterinary surgeons who practise their profession on both sides of the border in accordance with current international agreements may import and export ready-to-use medicinal products in small quantities without a licence insofar as this is indispensable for practising their profession.
Any person holding a cantonal licence to dispense medicines as a public pharmacy, hospital pharmacy or drugstore does not require an operating licence from Swissmedic for the wholesale trade in medicines occasionally conducted with other holders of a cantonal dispensing licence in the canton in which they are established. If the medicines are sold to more than five customers a year or if distribution is transferred to a third party, an operating licence from Swissmedic is required.
For wholesale trade activities in accordance with paragraph 2, the GDP rules described in Annex 4 applymutatis mutandis .
The cantonal authorities must be notified of wholesale trade activities in accordance with paragraph 2.