This is a compilation of the recent regulatory updates from emerging markets. Every week, we post an update of what's new, which you can view here.
- Eurasian Economic Union (EAEU)
- Middle East
- Sri Lanka
- South Africa
- May 30: The government has published a regulation for barcoding of goods destined for human consumption, including medicines. In addition to the GTIN in barcoded form, other mandatory information will be required on product labels. A regulation on pharma serialization is reported to be in development.
- July 11: Nigeria's National Agency for Food and Drug Administration (NAFDA) published a report on a proof of concept conducted for traceability through scanning of COVID medicines. The report is intended to inform future traceability initiatives.
- May 30: With the support of GS1, Zambia, Ghana, and Mauritius have been holding sessions independently on standards awareness, track-and-trace benefits, and local piloting. There is no formally coordinated effort for a common traceability system or centralized regulation in Africa.
- May 2: At the GS1 Summit held April 20 – 22, The Nigerian National Agency for Food and Drug Administration and Control (NAFDAC) communicated that they will be issuing master data guidelines soon. Currently no legal requirements in place for traceability, though there is a “5 Year Plan.”
- January 10: GS1 Africa summarized activity throughout the continent, which consisted primarily of awareness workshops on GS1 standards and traceability in 2020 and continuing into 2021. Countries noted were Kenya, Botswana, Namibia, Senegal, Benin, Burkina Faso, Togo, Ghana, Rwanda, and Ethiopia. The bulk of these efforts has been driven alongside USAID.
- November 24: The South African Development Community (SADC) circulated draft guidelines for product labeling and barcoding with QR codes. The guidelines, which are early stage, are being reviewed by the 16 countries that participate in the SADC and may influence serialization and traceability requirements in those countries in the future.
- March 28: Therapeutic Goods Order (TGO) 106 goes into effect on January 1, 2023 and lays out requirements for medicine packs that a manufacturer may choose to serialize (serialization will continue to be optional) or which include a GS1 Data Matrix code that contains a GTIN. The guideline differentiates the terms “primary pack” (saleable pack) and “primary packaging.
- July 26: Australia’s new medicine coding and identification requirements are being circulated for public consultation. These requirements would formalize barcoding and serialization for all medicines. Today, barcoding is required on many medicines, and serialization for some blood-related products.
- July 21: The Australian government's Therapeutic Goods Association (TGA) has published updates to their guidance documents on TGA 91/92 about the identity of medicines. One of the key updates provides clarification on product coding.
- July 6: The Australian Digital Health Agency published its new Framework for Action, outlining a strategic work plan for implementing digital health over the next four years. The framework features the use of GS1 coding standards, supply chain solutions (master data/GDSN/GLN, and national recall solutions), patient identification, etc. The roadmap is supposed to help establish a foundation for future regulations and requirements.
- June 17: The government announced new barcoding and potential serialization requirements for products under "special pricing arrangements" and high cost medicines. Five different models are being reviewed, one of which would require secondary level serialization. The requirements will go into effect July 1, 2019 and internal consultations are starting June 20 to determine the model.
- June 3: A new circular was issued for supplying medicinal products to the Australia government for government programs. This circular mandates a July 1, 2019 deadline to include serialization.
- June 20: The recently-published Circular No. (12) 2021 and version 1.3 of the Medicines and Barcoding and Serialization Guidelines are minor updates that incorporate the current deadlines: October 1, 2021 for reporting and May 1, 2022 for aggregation.
- May 30: The National Health Regulatory Administration (NHRA) recently updated its Technical Onboarding Guideline, now in version 1.5. While there were no major changes in reporting requirements from version 1.4, this version clarified some technical information.
- May 23: The National Health Regulatory Authority (NHRA) issued Circular No. (12) 2021 to remind Invoicing Companies of the October 1, 2021 traceability reporting deadline and the May 1, 2022 aggregation deadline.
- January 24: The National Health Regulatory Authority (NHRA) held a meeting for manufacturers to understand deadlines and submission requirements for EPCIS files. Next week NHRA is holding a preparatory meeting for solution providers.
- December 13: The National Health Regualatory Authority (NHRA) released v1.2 of its Technical Onboarding Guideline.
- November 15: The NHRA-MVC issued Circular No. (46) 2020 that moved the aggregation requirement to May 1, 2022. An update to the technical guidelines, now v1.1, has also been issued.
- November 8: The National Health Regulatory Authority (NHRA) issued its initial draft of the Technical Onboarding guidelines v1.0 for connection to the Traceability Hub.
- September 27: Bahrain’s government published a circular documenting the next steps for traceability reporting. The steps must be implemented by October 1, 2021.
- January 20: Version 1.1 of the Medicines Barcoding and Serialization Guidelines document was published. The changes to this version included adjustments to the mandatory and optional fields.
- August 5: The NHRA published a new medicines guideline and FAQ with deadlines for master data and barcoding/serialization set for Dec. 31, 2019.
- October 25: A new draft law has been circulated. The main changes relate to the National Product Number and remove the obligation for it to be printed on the packs as part of the verification code. Instead, the National Product Number will be generated by the Bulgarian Drug Authority (BDA), used in the products registries, and digitally linked to the product numbers already printed on the packs.
- August 5: Manufacturers and wholesalers in the country are considering implementation of a track and trace regulation. GS1 is working on a draft position paper to support those local efforts.
- April 1: A new regulatory draft was circulated for Pharmaceuticals and Medical Devices submission of product data. Neither serialization nor reporting was mentioned in the draft.
- July 25: Deadlines with Phase 1 medications appear to be set for November, 2022 based on the latest amendment. Traceability scope for this phase is 400 products in the public healthcare system (RPIS).
- July 18: Deadlines begin with Phase 1 medications in November 2022. Traceability scope for this phase is 400 products in the public healthcare system (RPIS).
- July 4: Industry is seeking clarification on further revisions to medicines/devices traceability requirements as the scope appears to be restricted to supply for the RPIS (public health network). Deadlines have also been pushed out.
- June 27: Further revisions have been published by the Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) for medicines and devices traceability. Scope is now described as medicines/devices in the RPIS (public health network) and not in private pharmacies. Deadlines have also been moved out.
- June 6: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) has published instructions for filling out its “Gradual Plan” template for implementing traceability of medicines, biological products, and medical devices. Phase 1 products, whose traceability deadline is November 26, 2021, will require a PDF-formatted plan to be submitted via email to ARCSA by July 26, 2021. ARCSA has stated that companies will be required to hold traceability event information until a national system is available.
- May 30: GS1 Public Policy is assembling questions to clarify deadlines and requirements in the May 19 resolution from the Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA). The resolution states that companies will be required to
- Hold traceability event information in their own systems until the ARCSA national system is ready
- Present a “Rolling Plan” for implementing traceability for a given phase’s products four months prior to that phase’s deadline.
- May 23: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) issued a draft update on its traceability regime, which appears to suggest that a national system will not be implemented immediately, but that stakeholders will be responsible for maintaining their own traceability data and will need to serialize packs.
- May 2: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) has stated that they will be communicating new dates for the traceability system and for the traceability deadlines. The previously stated deadline was March 26, 2021 for the system guidelines to be published and 26 May 26, 2021 for Phase 1 traceability for products in the public sector.
- March 7: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) updated the list of drugs, biological products and medical devices subject to traceability in Phase 1. First-phase deadline for traceability of selected products in the public health system channel is May 26, 2021. Technical specifications are stated to be available by March 26, 2021. ARCSA has not published formal procedures for administrative/contractual onboarding, generally a precursor to standing up a traceability program.
- December 13: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) published the list of Phase 1 products for traceability in the public health sector by May 26, 2021. Traceability for these products will extend to private channels such as community pharmacies by November 26, 2021.
- December 6: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) has published their traceability regulation in the country’s Official Gazette, establishing a first-phase deadline for May 26, 2021. Products in the various phases have not been announced. The central system and technical guidelines are scheduled to be published by March 26, 2021.
- November 29: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) published an updated guideline that indicates the first-phase deadline as May 2021 for certain medicines as determined by the health authority. It also states that ARCSA will be acquiring a central reporting system by mid-March 2021 and that technical guidelines will be available then.
- November 15: The current draft regulations indicate a phase-in by product and dispensation channel beginning 6 months after the final regulation is published, with deadlines ranging from May 2021 to November 2022 if the final regulation is published at end of November 2020 as communicated. Traceability system guidelines are stated to be published within 60 days of the Resolution publication date, so are expected by January 2021.
- November 8: The Agencia Nacional de Regulación, Control y Vigilancia Sanitaria (ARCSA) issued an updated draft regulation document from the August 2020 version. Technical guidelines still have not been issued.
- September 13: Ecuador's government published new regulations mandating that serialization and traceability reporting be implemented in six months.
- July 11: The Ethiopia Food and Drug Administration (EFDA) reminded MAHs of the August 19, 2021 deadline to share their product master data via email/spreadsheet while it works on an online platform to collect this data.
- May 2: At the GS1 Summit held April 20 – 22, the Ethiopian Food and Drug Authority (EFDA) presented their launch of their master data guidelines and plans for lot-level traceability. New timelines will be released.
- March 28: A 15-minute Facebook streaming event was held to cover the Ethiopian National Traceability System for health commodities and featured the Director of the Ethiopian Food & Drug Administration (EFDA). Presenters covered progress on the EFDA’s digital transformation, which targeted processing of marketing authorization applications and import licenses. In the less than 5 minutes devoted specifically to medicines traceability in the supply chain, leaders stated they would be looking at integration of their systems with the Covax Trust Repository and subsequently make plans for downstream traceability; no timelines were provided.
- December 13: The Ethiopian Food and Drug Administration (EFDA) published a list of Master Data Attributes based on GS1 standards. The deadline for submission is still under discussion.
- August 4: The Eurasian Economic Commission met to discuss the adoption of uniform serialization and cryptographic requirements across the five-member countries of the Eurasian Economic Union (EAEU) based on those being adopted by Russia. Future discussions are expected to address members’ concerns about implementation timelines and complexity as the roadmap is finalized.
- March 21: Discussions continue between the industry and the National Agency of Drug and Food Control (BPOM) on revising the current regulation. BPOM does not appear to be prescriptive on the serialized shipping container code (SSCC) carrier for the aggregation requirement (which will be purportedly included in a revised regulation).
- December 13: The Indonesian food and drug authority, Badan Pengawas Obat dan Makanan (BPOM) held an industry consultation on December 10 to discuss a new draft version of the regulation. This version extends the traceability deadline from 2 years to 3 years from electronic license renewal. Aggregation is required, and there are minor changes in product exemptions in primary packaging.
- January 20: An updated background summary was circulated on the upcoming barcoding, serialization, and reporting requirements that will be phased in from 2020 to 2025.
- April 1: Meetings continue with regulators to discuss the criteria for serialization in 2020. Both 2D DM and QR Codes are allowed today and the industry is advocating for continued allowance of 2D when the 2020 regulation goes into effect.
- February 25: It is expected that technical guidelines will be published in 2018 for the 2020/2025 serialization/track and trace requirements that are in draft form. BPOM has asked the industry for feedback on their potential timelines. Some pharmaceutical companies have been stating they will be ready for serialization using GS1 2D in early 2019.
- February 11: The use of QR codes (not 2D DataMatrix barcodes) has been officially adopted, with an initial focus on Vaccines starting in 2018 for adoption through 2020.
- April 18: While details have not been published, deadlines for obligatory barcoding of drugs and medical devices, based on the amendment of Japan’s Pharmaceutical and Medical Devices Act (PMDA) have been set for December 2022. Serialization does not appear to be a legal requirement.
- January 20: The Ministry of Health circulated an outline of discussions for a proposed new electronic Product Information Leaflet, which will include a QR code.
- January 31: The Jordan Food and Drug Administration (JFDA) published a new circular on barcoding and serialization. The serialization deadline has been changed to June 30, 2021.
- September 9: JFDA has postponed the implementation of barcoding and serialization until Dec. 31, 2019.
- July 25: Current information indicates phased implementation of traceability, with serialization for 93 products beginning in May, 2022 and reporting for that same product scope in January, 2023. The industry is seeking confirmation of this phased approach and consequent dates.
- May 30: Kazakhtelecom published an organizational action plan for medicines traceability. This timeline includes an analysis of the regulatory impact of a drug marking/traceability system that is due to be delivered to the Kazakh government in July 2021.
- May 30: Kazakhtelecom updated their high-level roadmap on their website with the text “Stage 1” alongside mandatory labelling for January 2022. There is no current listing of what products/activities might be in scope for Stage 1.
- April 25: Kazakhtelecom has published a traceability deadline of January 2022 on its website. However, the page does not reference the latest legislation, which does not contain a deadline. In addition, it is believed that the pilot kickoff itself has been delayed.
- April 18: Despite rumors about traceability deadlines, the Kazakh government has not yet published an official date.
- March 14: At a March 5 industry meeting, the Kazakh Ministry of Health reportedly stated they would be issuing a traceability roadmap in Q1 or Q2 2021 and will make a decision as to full deployment, possibly as early as January 1, 2022 for some product groups which will be specified. The “PMT” system appears to be largely modelled on the Russian MDLP and Russia Decree 1556.
- February 21: The Kazakh Ministry of Health published guidelines for its pilot on medicinal product marking and traceability, the system for which is operated by Kazakhtelecom. Serialization requirements, including crypto codes and their acquisition, appear nearly identical to those of the Russian Federation. A detailed description of traceability events has not been described, so it is unknown whether the regime will rise to the same level of complexity as those of Russia. GS1 has reported that the pilot will finish in March 2021.
- March 10: The Kazakhstan Ministry of Health (MOH) continues work on their pilot program for pharmaceutical track and trace regulations. The MOH plans to focus on GS1 standards, but it has yet to be determined if they will align more closely with the European Union/Turkey approach or the Russia approach to GS1 standards.
- July 15: Government is moving forward with their plans for serialization and traceability with a target of draft regulations by the end of the year. Potential timelines: Pilot (2018-2019); voluntary coding (2020-2021); and serialization of all products (2023).
- April 8: Formal general guidelines were circulated for a future track and trace system, with an initial pilot project being slated for 2018-19 and phase in of labeling/reporting in 2020-2024.
- March 11: Government is looking at serialization and traceability of all medicines. An internal letter has been circulated in government ministries but nothing formal has been stated.
- May 2: The Ministry of Public Health is requiring importers and distributors to use the MediTrack information system as of April 5, 2021 for importation and sales.
- November 29: The Lebanese Ministry of Health issued an update to its barcoding guideline and the use of the MediTrack system for uploading product information. No deadline has been communicated.
- October 28: A new government decree extended the implementation date for 2D barcoding until December 31, 2019 for imported medicines and December 31, 2022 for domestically produced medicines. Based on this decision, serialization updates are still pending.
- August 5: Ministry of Health published a statement allowing for pharmaceutical companies unable to make the Jan. 2019 deadline to follow an alternative transitional strategy using stickers.
- May 2: The Minister of Economy and Trade has founded a committee to establish a “National Project for a Pharmaceutical Verification System.”
- August 30: Malaysia’s government issued an update on the country’s serialization and traceability plans, reinforcing its intention to move forward with a 2023 deadline for full implementation of regulations.
- October 7: Malaysian Ministry of Health (MoH) published their formal regulatory requirements this past week, including a timeline for full implementation by 2023 with phased implementation to start in 2020. These requirements include serialization and full track and trace to a central government repository using EPCIS. The overall transaction event model is based on Turkey.
- September 9: Draft regulatory requirements were published by the Ministry of Health for serialization and track and trace reporting to a government system. These regulations will be phased in over the next two years, with firm deadlines still being worked out.
- September 2: The Malyasian National Regulatory Conference (NRC) 2018 in early October will discuss the upcoming serialization and reporting requirements on day 3 of the conference.
- April 1: Draft regulation is expected to be published 6/13 but no data has been released thus far on scale/scope.
- November 22: The government of the UAE circulated a formal announcement for their forthcoming track-and-trace system which was mentioned in their 2019 future vision document. No specifics on requirements or deadlines were included.
- September 13: The Abu Dhabi emirate published a circular announcing new coding and serialization requirements for 2021 as well as information on submitting product master data to the United Arab Emirates portal.
- September 16: The Gulf Health Council has published new barcoding requirements for Gulf Cooperation Council (GCC) countries. Deadlines for these requirements have not yet been set.
- December 16: An article was published in CoinReport, which mentioned that the government will be launching their first blockchain track and trace pilot project designed to remove counterfeit drugs in the country.
- December 16: A new government circular clarified that their barcoding/serialization requirements only cover pharmaceutical products while herbal and other medical products and devices are not in scope for the regulation.
- June 3: A new government circular on serialization regulations with standards GS1 identifiers will be issued March 1, 2019, which will cover all registered Rx, health products, and registered medical devices.
- March 31: The government circulated a draft of Statutory Regulatory Order (SRO) 470 among internal ministries to finalize the adjusted serialization timelines that were first stated in January.
- December 9: An agreement between regulatory and the Supreme Court has laid out new timelines and requirements for coding, serialization, and track and trace implementation.
- October 7: PharmaBureau and DRAP met on September 26 to continue discussing the alignment of regulatory requirements and identification needs with the global framework for serialization and traceability.
- September 23: The Drug Regulatory Authority of Pakistan (DRAP) published a compilation of public comments for review prior to a meeting scheduled for September 28 with a broad group of industry stakeholders. This meeting will discuss the path forward for national serialization regulations and implementation requirements.
- June 10: Government reaffirmed that the AI240 may not be removed from the serialization requirements for the fifth data element, although individual companies may apply for exemptions.
- April 29: An update was published to coding regulations with enhancements to require the barcode not only on the outside box but also on the wrappers/containers of the medicine. This may be a push to introduce Primary level serialization on the medicines in Pakistan.
- March 18: Pakistan Court of Justice determined during a recent hearing that DRAP, Pharma Bureau, and industry will have three months to agree to an implementation timeline for barcoding and serialization, upon which the timeline will be formalized and published and the industry will be required to meet such a timeline.
- February 11: Punjab province regulators announced the removal of Application Identification (AI) coding in barcode to better align with GS1 standards, but the existing barcoding/serialization regulations for the country at large still include them.
- January 14: DRAP published minutes of a Dec. 14 2017 meeting discussing the current state of barcoding of medicines. With only partial compliance by the industry thus far and a new recommended product coding identification scheme, DRAP recommended to the government to extend the deadline for barcoding.
- April 29: Government legislation was published that reaffirmed the alignment of scope under EU FMD and formalized the content of the product identifier.
- August 5: GS1 is working with local authorities to help clarify the use of GTIN-13 with leading 0 vs. GTIN-14.
- An eHealth circular was published with initial thoughts on placing a QR code on pharmaceutical packages to enable identification and product information access. The industry is also considering the use of GS1 2D barcodes with DigitalLink capabilities.
- November 25: The government published draft guidance to gain feedback on electronic labeling of therapeutic products. Deadlines have not yet been outlined for the labeling requirements.
- March 10: The government is beginning to look into digital track and trace requirements and other global approaches as they create their pharmaceutical regulations.
- September 2: Regulators have noted that the final regulatory requirements are expected to be published by the end of September.
- January 14: Department of Health is reviewing comments submitted in 2017 on draft serialization requirements but no final timeline was stated for when the review will be completed.
- March 11: Government added 30 more products to a list of products targeted for the upcoming track and trace regulations.
- April 18: The UAE’s Ministry of Health and Prevention (MoHAP) held a webinar to announce its “Tatmeen” traceability system which is GS1-standards based and runs across the supply chain from manufacturer to patient. A 24-month implementation plan was mentioned, but no start date, reference date, or deadline was provided.
- January 24: The Ministry of Health and Prevention (MoHAP) circulated a survey to some manufacturers and packaging sites on industry readiness to inform planning for their “Tatmeen” traceability system.
- July 21: The SAFEMed project to improve the safety of medicines in the supply chain through identity and traceability was published by the United States Agency for International Development (USAID). This project is distinct from the Ministry of Health’s similar project.
- March 17: The Ukraine Ministry of Health (MOH) published a draft regulatory circular outlining the implementation of a serialization and traceability system from 2019 to 2024. The first step is the launch of a pilot project in Q4 of 2019 that will last until the end of 2020, which includes the development and creation of the main components of the system—labeling, software, changes in legislation, and monitoring. Mandatory labeling on the list of drugs established by the MoH will be introduced in 2021, and that list will be expanded in 2024.
- August 5: The Ministry of Health circulated a list of 15 questions for public feedback regarding data requirements and data management for serialization and traceability. The current draft law "On Medicines" only refers to lot-level traceability and the MoH is also working on potentially cross-tying traceability with medicine reimbursement.
- May 30: The Uzbek government issued Resolution No. 322, which describes traceability pilots and mandatory marking not only for medicines and medical products, but for a variety of other industries as well. The document references the original Resolution No. 737 from November 2020 and cites “Medicines and Medical Supplies” with Eurasian Economic Union Customs Codes 3003 and 3004 in scope for mandatory labelling for February 2022.
- May 23: The Center for Research in Perspective Technologies (CRPT) Turon has published a medicines traceability section on its website.
- April 25: Industry discussion continues on the traceability pilot guidelines since the scope appears to be “medical products'' as opposed to medicines only.
- April 18: Industry discussion continues on the traceability pilot guidelines since the scope appears to be “medical products" as opposed to medicines only. According to the Center for Research in Perspective Technologies (CRPT), beer/alcohol/tobacco labelling has been launched, while medicines are in pilot mode.
- April 11: Industry discussion continues on the traceability pilot guidelines since the scope appears to be “medical products” as opposed to medicines only.
- March 28: The Uzbek Cabinet of Ministers (State Tax Committee, Ministry of Health, and others) issued a temporary regulation on the government’s pilot for medicines traceability. No implementation timelines are given, but serialization and central technical operation are similar to those of Russia traceability, including the use of crypto codes in the marking and traceability system (ASL BELGISI) managed by CRPT Turon.
- January 25: Recent issuance of its Decree 737 indicates the government’s desire to implement traceability in a number of sectors. However, there are no deadlines set for pharmaceutical companies. It is expected that an eventual system will be managed by CRPT, the same operator as the MDLP system in Russia.
- September 23: A draft government circular was published for drug registration, quality documentation, and barcoding using standard barcodes or QR codes. This circular included a few technical details, but did not include final deadlines.
- September 9: A government circular was published that lists the draft requirements to put a QR Code on the outer box of medicines.
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