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Standardization of Data and Documentation Practices for Product Tracing Guidance for Industry

DraftCenter for Drug Evaluation and Research Center for Biologics Evaluation and Research Center for Devices and Radiological Health03/02/2018

Description

This guidance elaborates on the standards for the interoperable exchange of transaction 16 information, transaction history, and transaction statements required by section 582 of the 17 Federal Food, Drug, and Cosmetic Act (FD&C Act) (21 U.S.C. 360eee-1). Section 582 was 18 added by the Drug Supply Chain Security Act (DSCSA) (Title II of Public Law 113-54) and 19 facilitates the tracing of products through the pharmaceutical distribution supply chain by 20 requiring trading partners ( manufacturers, repackagers, wholesale distributors, and dispensers) 21 to exchange transaction information, transaction history, and transaction statements (referred to 22 collectively in this guidance as product tracing information) when engaging in transactions423 involving certain prescription drugs. This requirement took effect on January 1, 2015, for 24 manufacturers, repackagers, and wholesale distributors, and on July 1, 2015, for dispensers.

Scope & Applicability

Product Classes

6
prescription drug

Finished dosage form for administration to a patient

grandfathered products

Products that entered the pharmaceutical distribution supply chain before January 1, 2015

Grandfathered Product

Products exempt from certain tracing requirements under section 582(a)(5)(B)

prescription drugs

products subject to DSCSA tracing requirements

biological products

Regulated by CDER and CBER

HCT/Ps

Human cells, tissues, or cellular or tissue-based products defined in 21 CFR Part 1271

Stakeholders

10
wholesale distributors

Entities subject to verification requirements for saleable returned 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 providers

Entities considered trading partners but with specific requirement exemptions

trading partners

Entities defined in section 581(23) of the FD&C Act involved in drug distribution

trading partner

Entity that may provide notification regarding illegitimate product.

Manufacturers

Responsible for declaring acceptable market names on labels.

repackagers

responsible for assigning new NDC or lot numbers to repackaged products

Regulatory Context

Attributes

3
dosage form

The physical form of the drug product.

authorized trading partner

Entity having applicable registrations and licenses

individual saleable unit

defined in section 581(11)(B) of the FD&C Act

Identified Hazards

Hazards

1
illegitimate product

Product determined to be counterfeit, diverted, stolen, or unfit for distribution.

Related CFR Sections (2)

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  • CGMP/Finished Pharmaceuticals/Adulterated/Misbranded/Failure to Register

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  • Failure to Register and List

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See Also (8)