Using pharmacy-to-pharmacy marketplaces? Read this Suspicious Sales Surveillance Report

March 24, 2026

Online pharmacy-to-pharmacy marketplaces help pharmacies with inventory management, but they also carry a higher risk of being exploited by criminals selling black market medicines that are a threat to American patients. Because of that, pharmacies who use these platforms should be vigilant about avoiding and reporting suspicious sales.

The FDA has criteria for what constitutes suspicious product, and a lot of what pharmacies might find in pharmacy-to-pharmacy marketplaces qualifies as suspicious.

Recently, PSM worked with a partner that specializes in online sales surveillance of eight leading pharmacy-to-pharmacy marketplaces. We asked them to identify medicines offered at prices that are too good to be true when compared with purchasing prices from a prime wholesaler.

This is some of what they found on just one day, March 12, 2026.

Why we’re concerned

In the past, a non-trivial amount of diverted product that was bought back from patients (and therefore unsafe to dispense!) has appeared on these marketplaces. Brand protection teams have also discovered completely counterfeit products in legitimate packaging on these platforms.

One of the only companies in this space doing proactive outreach and partnership with brand protection teams is InStockRX. They are currently calling for brand protection team partners to work with them on monitoring their platform for suspicious sales.

When we raised the idea of cooperation between manufacturer brand protection teams and other pharmacy-to-pharmacy platforms, some of those platform operators replied, “Hell no.”

We’re excited to see the first fruits of these partnerships between InStockRX and security teams become public.

DSCSA obligations as a dispenser

As a reminder, FDA's guidance on what is suspicious includes qualities that may apply to these sales, which may involve products that are:

  • in high demand or in shortage,
  • already the subject of black market sales,
  • listed at “too good to be true” prices, or
  • sold by suppliers new to the buyer.

FDA also advises all trading partners to be alert to packaging discrepancies that might indicate a suspect product, such as:

  • excessive adhesive or residue,
  • a product name that differs from the FDA-approved product,
  • misspellings and labeling variations,
  • foreign language labels or foreign identification numbers,
  • absent lot numbers or expiration dates, or
  • missing anticounterfeiting technologies (holograms, color shifting inks, neckbands, or watermarks).

Review FDA's guidance on suspect product.

Products that raise these flags should trigger a quarantine and an investigation. If you're purchasing these products online, keep in mind that these "bargains" may come with extra work to quarantine and verify the product.

The DSCSA requires pharmacy dispensers to quarantine and verify anything that qualifies as suspicious product. That can be hard to do and may take valuable time that more than offsets bargains found on these platforms. We would be remiss if we failed to point out that dispensing a counterfeit product that’s trademarked could also ensnare you in a civil suit over trademark violation – an expensive legal entanglement that is difficult to defend against.

It is also important to note that these sales require trading partners to provide, receive and keep records of transactional data (including serial information) unless they clearly fall into an FDA waiver, exemption, or exception. If a sale is made under the named patient exemption, which is common on pharmacy marketplaces, the seller and buyer must be ready to provide evidence of an actual patient. These exemptions do not cover inventory transactions to fill or refill stock.

If you choose to buy off these marketplaces, be prepared to do the work required, which may include quarantine and verification or, frankly, immediately returning product that looks suspicious.

Or, don't buy suspicious products at all.