Guidance Delays Drug Supply Chain Security Enforcement

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FDA has made available a final guidance on enforcing Drug Supply Chain Security Act (DSCSA) requirements for wholesale distributor verification of saleable returned products and dispenser verification of the product identifier for suspect and illegitimate products. The guidance, Wholesale Distributor Verification Requirement for Saleable Returned Drug Product and Dispenser Verification Requirements When Investigating a Suspect or Illegitimate Product—Compliance Policies, says that FDA does not intend to take action against wholesale distributors who do not, prior to 11/27/2023, verify a product identifier prior to further distributing returned products as required by DSCSA. This provides wholesale distributors an additional three years to comply with this requirement. It also does not intend to take action against dispensers who do not verify the product identifier for suspect or illegitimate product in the dispenser’s possession or control. This also provides dispensers an additional three years to comply with the requirement.

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