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Identifying Trading Partners Under the Drug Supply Chain Security Act Guidance for Industry

Draft08/18/2017

Scope & Applicability

Product Classes

1
prescription drug products

Products covered by the DSCSA verification requirements.

Stakeholders

10
Manufacturer

Entity responsible for submitting NDINs

Reverse logistics providers

Entities that do not take ownership and are included under 3PL category.

Repackager

Trading partner required to have verification systems; Trading partner required to have verification systems in place.; Trading partner required to validate transaction history and verify product identifiers; must quarantine illegitimate product; receives returned product that it intends to further distribute

Wholesale Distributor

Trading partner required to have verification systems; Trading partner required to have verification systems in place.; Trading partner required to verify product identifiers with manufacturers; must maintain systems for disposition; must first verify that the product identifier imprinted upon or affixed to the package

Dispenser

Trading partner required to have verification systems; Trading partner required to have verification systems in place.; Trading partner such as a pharmacy required to verify at least 3 packages or 10 percent of suspect product; must identify and quarantine illegitimate product; may return product, saleable and non-saleable, to the trading partner

Third-party logistics provider

Entity that provides resources for the distribution of a product but does not take ownership.; Entity providing warehousing or logistics services without taking ownership of the product.; Entity providing logistics services without taking ownership of product; Defined as entities providing warehousing or logistics services; Provides warehousing or logistics services without taking ownership

Returns Processors

Entities involved in reverse logistics; Entities that do not take ownership and are included under 3PL category.

Common Carriers

Entities that warehouse but do not own product

affiliate

Entity that controls or is controlled by the applicant; Business entities related to the applicant

co-licensed partner

entity sharing a drug application

Regulatory Context

Attributes

1
direct ownership

transfer of title distinguishing WDDs from 3PLs

Related CFR Sections (1)

Related Warning Letters (10)

  • CGMP/Active Pharmaceutical Ingredient (API)/Adulterated/Misbranded

    Darmerica, LLC

    2025-12-23
  • OTC/Unapproved New Drug/Misbranded

    Supergoop!

    2025-08-12
  • OTC/Unapproved New Drug/Misbranded

    K & Care Organics

    2025-08-12
  • OTC/Unapproved New Drug/Misbranded

    Fallien Cosmeceuticals Ltd. dba Fallene Ltd.

    2025-08-12
  • Failure to List/Misbranded

    Shenzhen Hengkaifeng Commerce and Trade Co., Ltd

    2025-05-27
  • Electronic Drug Registration and Listing System (eDRLS)/Violations

    Prodose, Inc. formerly known as Spirit Pharmaceuticals LLC

    2025-04-29
  • CGMP/Finished Pharmaceutical/Adulterated

    Jagsonpal Pharmaceuticals Limited

    2025-02-18
  • CGMP/Finished Pharmaceuticals/Adulterated/Misbranded/Failure to Register

    Omni Lens Pvt. Ltd.

    2024-10-22
  • Failure to Register and List

    Media Networks Sydney Pty Limited

    2024-08-20
  • Failure to Register and List

    Zen Enterprises LLC

    2024-04-23

See Also (8)