The Ministry of Health has published a draft resolution, according to which the Cabinet of Ministers may include nalbuphine in the list of narcotic drugs, psychotropic substances, and precursors. The Suspilne investigative editorial office contacted the Ministry of Health for comments on the draft resolution, and spoke with experts.
What is nalbuphine and why is it only now being added to the list of narcotic drugs?
In December 2024, Suspilne journalist Anastasiia Ivantsiv published an article about nalbuphine withdrawal, raising the issue of the popularity of this synthetic opiate.
After the publication, health minister Viktor Liashko admitted the problem, noting that in 2024, pharmacies in Ukraine sold three million packages of nalbuphine, but only six thousand prescriptions were issued for it.
In February, the Ministry of Health promised to add the drug to the list of those that can be purchased exclusively by electronic prescription.
At the end of May 2025, the Suspilne investigative editorial office released the investigative documentary “Nalbuphine: A Profitable Addiction”. Nalbuphine, a semi-synthetic opioid that causes addiction, continued to be sold in Ukraine with ordinary paper prescriptions, like antibiotics or medical alcohol. Therefore, it was possible to buy this addictive drug in unscrupulous pharmacies both without a prescription and by repeatedly using the same prescription.
As the journalists found out during the investigation, in 2024, pharmaceutical companies received more than 1 billion hryvnia in revenue from the sale of nalbuphine. Compared to 2023, pharmaceutical companies’ revenues from the sale of this drug increased by 44%, and compared to 2021 – by 215%.
While working on the documentary, the Suspilne journalists recorded an interview with Yevhenii Honchar, then acting director of the Department of Medical Services of the Ministry of Health (now he is a deputy minister).
Honchar noted that the first step would be to add nalbuphine to the list of drugs sold exclusively by electronic prescription. And if this step does not work, Honchar said, then the Ministry of Health will consider adding nalbuphine to the list of narcotic drugs.
The Ministry of Health changed the rules for dispensing nalbuphine in June 2025. From that time, this drug can be purchased exclusively with electronic prescription.
In August, the Ministry of Health website published for discussion a draft resolution of the Cabinet of Ministers of Ukraine “On Amendments to the List of Narcotic Drugs, Psychotropic Substances, and Precursors”.
According to the draft resolution, list No. 1 of Table II will be supplemented with the item “Nalbuphine”. This list refers to narcotic drugs and plants with restricted circulation. These include, for example, codeine, cocaine, and morphine.
These drugs can only be purchased in pharmacies licensed to sell narcotics, and with a special prescription.
The Ministry of Health ignored the question, and the private company demanded to disclose the source
In the explanatory note to the draft resolution of the Ministry of Health, it is indicated: “The change to the List was developed based on the results of processing the analytical report prepared by the Center for Public Health in connection with a significant number of requests for medical help from persons addicted to nalbuphine (530 such persons in 2024). Patients mostly have primary addiction and begin to abuse nalbuphine to treat a post-surgery or other pain syndrome. Currently, medicines with the active substance “Nalbuphine” are prescribed without special forms [...]. This simplifies their prescription and circulation, but at the same time reduces control over use. The specified system of control over the prescription of nalbuphine is not effective in preventing its abuse.”
The Suspilne investigative editorial office addressed the press service of the Ministry of Health to comment on the draft resolution. In particular, we asked to indicate whether the publication of the draft means that the sale of nalbuphine by electronic prescription has not brought the desired result.
We also asked to clarify the stage of consideration of the project and to provide up-to-date information on nalbuphine sales before and after June 2025, when the procedure for its implementation changed.
We still have not received answers to our questions sent on September 10.
However, in July, more than a month after the nalbuphine documentary was released, Suspilne received a letter from Proxima Research company, an international provider of data, technology, and services for healthcare. It is this company that publishes pharmacy sales reports, which the investigative editorial team used.
We did not receive a response to our repeated requests to the company representatives for cooperation during the work on the film. A source, who had access to Proxima Research data, shared with journalists information on pharmacy sales of nalbuphine. These data, in particular, helped to demonstrate the growth of sales and profits of pharmaceutical companies from the sale of nalbuphine in recent years.
In a letter to Suspilne, Proxima Research asked to remove all mentions of the company and its research, citing the fact that the journalists allegedly did not receive written permission to use the data.
Such a requirement – written permission – is indeed provided for on the company’s website in the “Terms of Use” section. However, as the journalists found out, there was not such a section before the end of June 2025, that is, it appeared after the investigation into nalbuphine had been published. This was verified with old versions of the website saved on the WaybackMachine platform.
“It should have been done 10 years ago”
The Suspilne investigative editorial office contacted the representatives of the “SVOI” charitable foundation, which works, in particular, with palliative patients and publicly insisted that nalbuphine should be added to the list of narcotic substances.
“This will change everything,” says Lesia Lytvynova, head of the “Palliative Care” program and co-founder of the foundation. “What is nalbuphine? It is an opioid analgesic, which for some reason is not included in the list of opioid analgesics. This makes it possible to buy it without control. It is the same morphine, only synthetic, of poor quality and cheap. And it, unlike morphine, is addictive.
Nalbuphine began to be actively used 10 years ago. From the very beginning, it was not supposed to be available for sale. Its only advantage is that it acts instantly. This is a terrible topic and it has been relevant for many years.
We receive patients who constantly use nalbuphine, and it is difficult to stop addiction. And doctors do not want to give another prescription, because another prescription is a different responsibility. And there is no control here, people can do whatever they want. I had a patient with cancer. He had pain in his tailbone, not related to the main disease. The doctor prescribed nalbuphine and said, “Inject it if it hurts”. That is it. And he injected it, and then – oh, the person has a withdrawal syndrome.”
Iryna Koshkina, executive director of the “SVOI” charitable foundation, says that adding nalbuphine to the list of narcotic drugs will significantly affect its uncontrolled sale.
“Inclusion of the drug in the list of narcotic drugs means that the drug will be prescribed according to form No. 3 (it was earlier called a pink prescription). Form No. 3 is prescribed only electronically. And this means separate reporting and sales in pharmacies that have a license to sell narcotic drugs,” comments Koshkina. “The license provides for a protected room with bars, a metal safe screwed to the floor, a security alarm, and so on. Accordingly, if a drug is included in the list of narcotic drugs, trading it without an appropriate license means criminal liability. And it is not easy to get a license.”
According to Koshkina, the problem that arose with nalbuphine is much broader. It concerns the general approach to pain relief in Ukraine.
“Many doctors do not know how to prescribe adequate pain relief. They know nalbuphine, and that is all,” she says. “To prescribe normal pain relief, you need to understand in which cases we prescribe fentanyl, in which cases – oxycodone, in which cases – tramadol, in which way chronic pain differs from acute pain, what breakthrough pain is during chronic pain syndrome, and so on. Most of the pain relief cases are covered by the “Affordable Medicines” reimbursement program. There are already fentanyl patches and morphine there. If you need pain relief, then you need a doctor. If your doctor does not know how to do it, then this doctor should be fired as unfit for work. Or trained. As far as I remember, there are several courses on pain relief at the National Health Service Academy.”
For more details about nalbuphine, the addiction it causes, and the profits pharmaceutical companies make from it, see the investigative documentary “Nalbuphine: A Profitable Addiction”.
This publication was funded by the European Union. Its contents are the sole responsibility of the author and do not necessarily reflect the views of the European Union.
