Skip to main content
Register for FutureLink Barcelona 2026 Today→
TraceLink — Network for Greater Good
AI Mode Agents AI Solutions Network Resources About
LOG IN TraceLink Classic OPUS Platform
Resources

Breadcrumb

  1. Home
  2. Resources
  3. Resource Center

EU FMD and Risk-Based Verification in the Warehouse: Top Questions Answered

banner-image
  • Download PDF
  • Share
    • LinkedIn
    • Facebook
    • Mail
    • Twitter

Table of contents

 

Under EU FMD, if you are a wholesale distributor and bring product into your facilities that you didn't purchase directly from the Marketing Authorization Holder (MAH) or a designated wholesaler, then you need to verify that product. There is a common misperception amongst companies preparing for EU FMD that warehouses will only have to verify 10% of products. In fact, the law will require that you verify every single product that meets those criteria before it can be resold.

Here are six commonly asked questions and answers regarding EU FMD compliance and risk-based verification:

After EU FMD goes into effect on February 9, do I have to go back and verify products in my warehouse that aren't serialized?

Wholesalers are required only to verify products that bear the safety features (the anti-tamper device and the unique product identifier) mandated under EU FMD. The application of those safety features is optional until February 9, 2019 when the law goes into effect. There is no requirement to go back and verify products that come in without safety features before that date.

How is verification going to impact my warehouse operations?

Under EU FMD, you will have to implement the new process of risk-based verification into your warehouse operations, including figuring out staffing and creating standard operating procedures (SOPs) for how it will work.

Besides those issues, there is going to be a point in time when you start to receive more of the same product already in your warehouse, but the new product will be serialized. That new serialized version of the product will need to be verified and scanned, while the old non-serialized product will not. Having the two versions of the same product stored together could lead to potentially picking a serialized product for distribution without verifying/scanning it, which would result in your warehouse being non-compliant. One way to handle this is to segregate the new serialized product in your warehouse and manage that separately from the older non-serialized product, so the non-serialized product is distributed first.

We participate in the Good Distribution Practices (GDP) wholesale standards and are active in cross-docking activities, where products come into our warehouse from a supplier and are distributed directly to a customer with little if any handling or storage time in our warehouse. Do we need to verify cross-docking shipments according to EU FMD?

Yes, verification is required for cross-docking as the products are leaving the physical possession of the wholesaler. The only time that you wouldn't have to verify when cross-docking is if the product was being distributed to another wholesaler in your same parent company.

When my wholesale business imports products from one EU market to another, and we receive shipments and hold them before delivery to the buyer, do we need to verify those products?

Yes, you would need to verify the products being imported since you are receiving them into your warehouse. There is one caveat to this requirement—products that are shipped directly from the manufacturer or a designated wholesaler do not require verification, but any damaged products from the manufacturer would need to be decommissioned.

Can inbound verification be done on the aggregate level for the sake of warehouse operational efficiency?

The National Systems do not support aggregation, so packs must be scanned individually instead of on an aggregate level. Aggregation enables you to associate the "child" items of the saleable units with their "parent" case to build a "parent-child" relationship of those serial numbers and scan just the parent case instead of having to scan each saleable unit.

What's the most efficient way to perform risk-based verification in the warehouse?

TraceLink's Smart Inventory Tracker manages risk-based verification for warehouse operations. It's a mobile application that can be used on handheld scanners or smartphones in the warehouse to verify and decommission products, including in the case of saleable returns. Smart Inventory Tracker enables the scanning and interpreting of a serial number, and stores it in a company's TraceLink serialization repository.

 

 

 

<a href="/category/european-union-falsified-medicines-directive" hreflang="en">European Union Falsified Medicines Directive</a><a href="/region-type/european-union" hreflang="en">European Union</a>

Table of contents

Contact Us
Learn more about TraceLink's solutions for EU FMD compliance.
CONTACT US
Contact Us
Learn more about TraceLink's solutions for EU FMD compliance.
 

Thank you for contacting us; we’ll be in touch shortly.

Cookie Settings

When you visit any website, it may store or retrieve information on your browser, mostly in the form of cookies or similar tracking technologies. Please see below for an overview of the categories of cookies and similar technologies used on this site. You can allow or deny some of all of them, except Strictly Necessary Cookies which are required to provide the site to you. However, blocking some types of cookies may impact your experience of the site and services we are able to offer.

Please see our Cookie Policy for more details, including a list of the cookies we use. You can change your consent options at any time by following the “Cookie Settings” link in the Cookie Policy.
'Strictly Necessary' cookies let you move around the Site and use essential features like secure areas, shopping baskets and online billing. Without these cookies you would not be able to navigate between pages or use certain vital features of our Site, so we do not require your consent for their use. These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the internet. For example, we use these Strictly Necessary cookies to identify you as being logged in to the Site. You can set your browser to block or alert you about these cookies, but if you do so, some parts of the Site will not work.
'Performance' cookies collect information about how you use the Site, such as which pages you visit, the time spent on the Site and if you experience any errors. We use performance cookies to provide aggregated statistics on how the Site is used and help us improve the Site including by measuring any errors that occur.
'Functional' cookies are used to provide services or to remember settings to improve your visit. We use 'Functionality' cookies to remember your settings and choices and show you when you're logged in to the Site.
‘Targeting' cookies are linked to services provided by third parties, such as 'Like' buttons and 'Share' buttons. The third party provides these services in return for recognizing that you have visited the Site. We also use 'Targeting' cookies to gather information that could be used to display content that we think may interest you.
Register for FutureLink Barcelona 2026 Today→
TraceLink — Network for Greater Good
Log In OPUS Platform · TraceLink Classic
AI Mode
Featured Report The Agentic Supply Chain Operating Model →

Agentic Business Processes

External Manufacturing Logistics Transportation Commerce Compliance

Products

Digital Transaction Exchange Process Collaboration Global Track-and-Trace Regulatory Compliance Real-Time Intelligence

Resources

Resource Center TraceLink University Partners Community Customers Events

About TraceLink

Company Overview Newsroom Culture & Careers Open Jobs Legal & Trust Center Corporate Social Responsibility Network Directory Glossary

Hot Topics

Eliminate Stockouts Improve OTIF Reduce Costs Increase End-to-End Visibility Accelerate Order-to-Cash Optimize Inventory Levels Scale Cross-Partner Execution
Need assistance? Contact Technical Support→

Contact Us Today

Transform your supply chain operations with a human-agent workforce.

Contact Us →

Stay Up-to-Date

Subscribe to receive industry insights and evolving trends.

Thanks — you're subscribed.

© TraceLink Inc. 2009–2026 All Rights Reserved