Mr. Ollie Ryan:

I thank the Chair and I thank the committee for allowing us time to speak. I am a member of Merchants Alliance Ireland, which represents all the license merchants in Ireland. Over the past 20 years, we have been allowed to stock a lot of POM products, which are prescription-only medicine products that are freely available to be dispensed by a licensed merchant. Over the past 20 years, we have never received any prescriptions for those products. In the current format, we do not see a future for us in the industry. I will read out a few examples of where we are at. To use the example of mastitis or intramammary tubes sales in 2022, the rules changed for the category of products, which meant that co-op vets were no longer allowed to prescribe intramammary products for animals. In the past two and a half years, these products have been exclusively prescribed by vets. In this time, the use of these products has remained constant, not decreased, as was the intention of the regulation at the outset. Prior to 2022, co-op dispensed approximately 40% of these antibiotic tubes. However, today, though co-ops are actually allowed to dispense these products, they only dispense about 2% of them. The result here is the use of intramammary antibiotics has not reduced but the shift in route to supply has and is overwhelmingly in favour of the vets.

The Department of Agriculture, Food and the Marine and the statutory instruments acknowledge the need for vets be able to prescribe antiparasitic products in these areas where they do not clinically assess the animal. Despite this provision being the proper assessment protocol, however, the terminology and its interpretation ensures it is almost legally impossible for a vet to comply with. There have been various promises made for further clarity. However, this has been less than forthcoming since September 2024. The complexities around the terminology will likely result in increased confusion. This statutory instrument effectively eliminates licensed merchants from the animal health market.