Prescribing, importing, administering: a physician's legal map in Panama

Why this map matters now

Patients arrive with products bought on social media, vials from other countries or treatments heard about on podcasts. The World Health Organization warns that substandard and falsified medical products are often sold online or in informal markets⁹, and a meta-analysis estimated that 13.6% of essential-medicine samples tested in low- and middle-income countries were of poor quality¹⁰. Panama's legal framework was renewed in 2024 with Law 419 on medicines and its regulation, Executive Decree 27¹². This is a summary of the articles that most affect clinical practice.

Law 419 of 2024: registration and sanctions

• Art. 156.1 classifies as a very serious offense "marketing a product without sanitary registration, except for the exceptions authorized by this Law"¹.
• Art. 156.2: it is also very serious to "distribute or dispense contaminated, altered, falsified or adulterated products"¹.
• Art. 150: fines "from five hundred balboas (B/.500.00) to twenty-five thousand balboas (B/.25,000.00)", "without prejudice to civil or criminal action"; for very serious offenses the fine ranges from B/.15,001 to B/.25,000¹.
• Art. 3(71) defines a prescription as one "issued by a qualified physician"¹.
• In practice: in August 2026 MINSA inspected two establishments offering stem cell therapies and opened administrative files over possible violations, including the presence of products without sanitary registration¹¹. Panamanian researchers had warned that lack of enforcement facilitated the growth of that market¹⁴.

Import and registration exceptions: Executive Decree 27

Personal-use import by courier or traveler requires a prescription from a "qualified professional", and the quantity "must not exceed six months of treatment". Also: "The import of raw material or unfinished products through courier services or travelers is not permitted" (art. 358.3)².

An exception to sanitary registration for a patient requires a prescription and registration of the product by a "high-standard regulatory authority" (art. 209); it is valid for 60 business days with no extension (art. 214) and is free for the patient². A peptide not registered by any high-standard agency does not fit that pathway; this is an inference from the cited articles, not a MINSA ruling¹². For reference: USADA states that BPC-157 is not approved for human clinical use by the FDA or by any health authority worldwide⁸. The FDA, reviewing its possible use in compounding, cited a possible immunogenicity risk and no or only limited safety information; for the thymosin β4 fragment known as TB-500 it said it has not identified any human exposure data⁷.

Penal Code: crimes against public health

• Art. 304: whoever "poisons, contaminates, alters or corrupts food, medicine, excipient or raw material", 4 to 10 years in prison³.
• Art. 305: delivering a medicine "knowing it to be harmful", 3 to 6 years³.
• Art. 306: if illness results, 6 to 12 years; if death results, the penalties for aggravated homicide³.
• Art. 309: "A physician or person with a health career who prescribes or supplies a drug without medical or therapeutic need to justify it or in a dose greater than necessary", 1 to 3 years in prison or the equivalent in day-fines or weekend arrest³.
• Art. 381: practicing a profession without the required qualification, 2 to 5 years³.

Note: the text consulted is the 2019 consolidated version published by the Public Ministry; we did not verify later amendments³.

Informed consent: Law 68 of 2003

Written consent is mandatory for procedures "involving notable and foreseeable risks or drawbacks" (art. 16), and it "must be specific to each procedure" (art. 17)⁴. With products of limited evidence, documenting what is and is not known about the product is part of that consent. The legal literature agrees: with off-label or unlicensed medicines, the duty to inform the patient about benefits and risks is stricter¹².

Advertising and social media

Art. 140 of Law 419 prohibits recommending treatments through mass media, and health professionals who take part in mass media for teaching purposes "may not use trade names or recommend particular brands of medicines"¹. In January 2026 the Medical Association reminded members that its Ethics Code prohibits promotional use of patient testimonials that breaches confidentiality and the promotion of treatments without scientific support, and asked them to "avoid sensationalism and the promise of guaranteed results"⁵. There is precedent for MINSA sanctioning a physician over public statements: a $6,000 fine in 2022 for vaccine misinformation⁶. A review of 88 studies identified, among the risks of social media for health professionals, breaches of confidentiality and legal and disciplinary consequences¹³.