Peptides and Dutch law: what the Geneesmiddelenwet says

Article 1 of the Geneesmiddelenwet says a medicine is a substance meant to be given, or presented as suitable, for one of three things:⁴

1. curing or preventing a disease, defect, wound or pain in people;
2. making a medical diagnosis in people;
3. restoring, improving or otherwise changing body functions in people, through a pharmacological, immunological or metabolic effect.

The EU Court of Justice has explained both tests. “Presentation” is read broadly. It covers what a label says, but also the impression an ordinary, well-informed person gets, even from what is only implied.⁷ For “function”, the substance must be able to change body functions in a way that really matters. Authorities decide case by case. They look at what the product contains and what it does, as far as science can show. They also look at how it is used and at its risks.^8,6

For a peptide tested only in animals, the “function” test can be an open legal question. A product sold with healing or weight-loss claims usually meets the “presentation” test anyway.⁷ See research use only for how this works.

Making, importing or running a wholesale business in medicines needs a licence from the Minister of Health. A wholesaler may not trade at all in medicines that have no marketing authorisation.⁹

Two exceptions matter here. A pharmacy may make medicines on a small scale, to hand over from its own pharmacy, without this licence. And the licence rule does not apply to medicines “clearly meant for the own use of the person who carries them”. That exception is about the licence for importers. It does not switch off the ban in article 40.^9,1

Prescription-only medicines may only be handed over by pharmacists, dispensing GPs and a few other named people, and only against a prescription.¹⁰

No one may prescribe medicines over the internet to someone they have never met in person. The same goes for someone they do not know, or whose medicine history they cannot see.¹¹ Selling medicines at a distance is only allowed under the rules that put EU law into effect.¹²

A Danish journalist wrote on his website about a product that had no licence in Denmark. He wrote that it was meant to ease pain from gout, and that it was on sale in Sweden and Norway. He said he did not work for the maker and had no stake in its sales. He was not paid by the maker for what he wrote. He was prosecuted for advertising.¹³

In 2009 the EU Court of Justice ruled that information from an independent third party can still be advertising. What matters is the purpose of the message. The writer’s link with the company is one factor, weighed together with the kind of activity and the content of the message. The national court then decides.¹³

This is why this site never says where a product can be found, and never judges or recommends a seller.

The IGJ advises against ordering medicines online. Nobody checks them as a doctor or pharmacist would. A product can contain too much active substance, too little, or none. A contaminated product can damage organs. You can also be cheated: you pay and get nothing.¹⁶

If your product did not come from a pharmacy, no regulator has checked what is in it. See product risk for what you can and cannot check yourself.

Administrative fines. The Minister, in practice the IGJ, can fine breaches of the Medicines Act without going to court. This covers trading without a licence (article 40) and advertising (articles 84 and 85).^19,18 The maximum is the highest fine category in Dutch law, €1,100,000 since 1 January 2026.^19,24

Criminal law. A breach of article 40 is also an economic offence. Done on purpose, it is a crime. The maximum is six years in prison, community service, or a fine of up to €110,000. If the goods are worth a lot, the fine can be one category higher.^23,24

Seizure. IGJ and NVWA officials may seize medicines at any time to prevent harm to public health. They can also order a seller to stop, or to take a product off the market.²⁰

These are maximums. They say what the law allows, not what usually happens.

The law treats supply very differently from use. Passing a product on to a friend, selling some on, or ordering for a group are all acts of supply. Supplying and handing over are on the list of forbidden acts in article 40.¹ Done on purpose, that is a crime under the Economic Offences Act.²³