Substitution

Drug substitution: what the pharmacist may do

From December 9, 2026, a pharmacist may substitute a drug in more situations, including despite a “do not substitute” note, if the situation requires it and with your consent. The patient must be told in every case.

Unless stated otherwise, the pharmacist’s new activities described here apply from December 9, 2026.

In brief
  • There are two types of substitution: same common name, or therapeutic.
  • A “do not substitute” note may be set aside for the same common name, with the patient’s consent.
  • Substitution is always recorded in the file.

What is the difference between the two types?

Substitution by common name replaces the drug with another of the same name, such as a generic or a biosimilar. Therapeutic substitution replaces the drug with a different one, in certain circumstances, through a new prescription signed by the pharmacist.

Can they override a “do not substitute” note?

If the patient’s situation requires it, and with their consent, the pharmacist may make a same-name substitution despite this note. They must first establish that the clinical issues behind the note are absent. If in doubt, they contact the prescriber.

When is therapeutic substitution possible?

  • A supply shortage, after reasonable efforts to obtain the drug.
  • A market withdrawal or announced shortage, no earlier than three months before the planned date for a withdrawal.
  • An administration problem, for example a drug that cannot be crushed for a person with dysphagia.
  • An adverse effect or risk of one, if the prescriber cannot be reached in time.
  • A drug not on a health institution’s formulary.
  • A drug not covered that the patient cannot afford: it may be replaced by a drug on the RAMQ’s general list.

What must the pharmacist do afterwards?

  • Tell the patient and record the substitution in the file, with its circumstances.
  • Inform the prescriber or follow-up professional if they judge it relevant. The guide gives the example of adverse effects.
  • Ensure follow-up, and refer the patient if the situation worsens.

What about designated substances?

The pharmacist may substitute, in their own name, a designated substance prescribed by a practitioner with another designated substance. However, a drug that is not a designated substance cannot be replaced by a designated substance, according to the guide.

Sources: OPQ, summary of what is new (in French) · OPQ, practice guide on professional activities (in French) · OPQ, practice guide on professional activities (in French) · OPQ, practice guide on professional activities (in French)

General information based on the publications cited. This text does not replace professional or legal advice, or the Ordre’s guides.

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