Drug Tracing ‘Stabilization Period’

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FDA has published two compliance policy guidances establishing a one-year stabilization period to accommodate the additional time that trading partners in the drug supply chain may need to adhere to Drug Supply Chain Security Act (DSCSA) requirements for electronic drug tracing at the package level. The requirements that were to take effect on 11/27 include requiring trading partners to provide, receive, and maintain documentation about products and ownership only electronically. FDA says the stabilization period will give until 11/27/2024 to allow trading partners to implement, troubleshoot, and mature their electronic interoperable systems.

FDA says it “expects trading partners to use this stabilization period to build and validate interoperable systems and processes, manage products and data, and ensure continuity of the supply chain and product availability to patients. This period is not intended to provide, and should not be viewed as providing, a justification for delaying efforts to comply with the DSCSA.”

The first compliance policy guidance, Enhanced Drug Distribution Security Requirements Under Section 582(g)(1) of the Federal Food, Drug, and Cosmetic Act—Compliance Policies, takes effect immediately and describes the agency’s compliance policies on enforcement of the requirements for enhanced drug distribution security requirements.

A revised final compliance policy guidance, Wholesale Distributor Verification Requirement for Saleable Returned Drug Product and Dispenser Verification Requirements When Investigating a Suspect or Illegitimate Product—Compliance Policies, describes the agency’s compliance policies on enforcement of requirements for wholesale distributors and dispensers to verify a product’s product identifier in certain circumstances.

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