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Enhanced Drug Distribution Security at the Package Level Under the Drug Supply Chain Security Act: Guidance for Industry

FinalCenter for Biologics Evaluation and Research Center for Drug Evaluation and Research08/30/2023

Description

This guidance is intended to assist supply chain stakeholders, particularly trading partners, with requirements for enhanced drug distribution security at the package level under section 582 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) (21 U.S.C. 360eee-1), as added by the Drug Supply Chain Security Act (DSCSA) (Title II of Public Law 113-54). Requirements for enhanced drug distribution security, commonly referred to as the “enhanced system” go into effect on November 27, 2023.

Scope & Applicability

Product Classes

2
prescription drug

Finished dosage form for administration to a patient

saleable returned product

Product returned to a trading partner that is intended for further distribution

Stakeholders

6
trading partner

Entity that may provide notification regarding illegitimate product.

manufacturer

Entity required to conduct postmarket surveillance; entity responsible for submitting postmarket surveillance plans; Entity holding the approved PMA, HDE, or cleared 510(k); The entity responsible for conducting postmarket surveillance and submitting reports.; Entity that can use the checklist as a reference for submissions.

repackager

Trading partner defined in section 581(16) of the FD&C Act

wholesale distributor

Entity required to verify saleable returned product.; Required to verify product identifier for saleable returned product

dispenser

Entity required to verify product identifier of suspect or illegitimate product.; Must verify product identifiers when investigating suspect or illegitimate product

third-party logistics provider

Entity meeting conditions specified in section 581(23)

Regulatory Context

Attributes

3
package level

Smallest individual saleable unit of product

Data Architecture

Refers to centralized, distributed, or semi-distributed models for data storage

expiration date

Required label element for outsourcing facilities

Identified Hazards

Hazards

2
Suspect Product

Product where physical security features have been compromised; product for which there is reason to believe it is potentially counterfeit, diverted, or stolen; Product that is subject to investigation and verification

Illegitimate Product

Subject of investigation by FDA or state officials; product for which there is credible evidence that it is counterfeit, diverted, or stolen; Product that requires verification and response to officials

Related CFR Sections (1)

See Also (8)

Enhanced Drug Distribution Security at the Package Level Under the Drug Supply Chain Security Act: Guidance for Industry | Guideline Explorer | BioRegHub