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

What Are the 3 Major Requirements of EU FMD?

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

Table of contents

In 2016, the Delegated Act on safety features was published, introducing tough laws that enable harmonized, European-wide measures to rigorously control the safety and supply of medicines for human use. This part of the EU Falsified Medicines Directive (EU FMD) specifically outlines how pharmaceutical companies, parallel importers, wholesalers, and pharmacies must all address—and meet—three extensive requirements by February 9, 2019:

 

1. Serialization 

 

Serialization must happen at the secondary or saleable-unit level in Europe. To enable verification, you need to first serialize product and send that serialized data to a central repository that can perform queries against it.

 

To enable serialization, verification, and government reporting, EU FMD requires that manufacturers mark packages with four data elements—a product identifier, serial number, lot or batch number, and an expiry date—all of which must be stored in a GS1 2D DataMatrix code.

 

A fifth data element may also be added to the package based on a particular member state’s legal requirements, such as a national reimbursement number to help with reimbursement of drug product under a socialized medicine program.

 

To ensure that your product can accommodate the new code, you’ll have to evaluate your product artwork. In Europe, this is particularly critical for multiple market packs that may have to meet disparate artwork regulations in different European countries. In some cases, for example, you may need to have two or more 2D matrixes included on one sales pack.

 

2. Verification and Safety Features

 

Verification – the process by which product must be verified at one or more stops along the supply chain. By law, this point-of-dispensation verification is required—pharmacy dispensers must verify drug product identity prior to dispensation. For example, the legitimacy of a barcode serial number on a sales pack in a pharmacy can be confirmed by comparing it to data that’s stored in a national repository serving that country.

 

Safety features – elements such as anti-tampering devices and barcodes carrying product and pack data are incorporated into a medicinal product’s packaging and identification to facilitate verification. Safety features under EU FMD contain two parts related to the packaging and identification of a medicinal product for human use:

 

  • A unique identifier encoded in a 2D barcode enables identification and verification of each pack.  
  • Anti-tampering technologies determine whether product packaging has been compromised. The law does not specify which anti-tampering devices must be included on the pack. 

 

3. Compliance Reporting

 

On its journey from production to dispensation, a serialized drug package triggers certain compliance reporting activities for the marketing authorization holder (MAH). These focus specifically on the product and its market package, including product code, lot or batch number, expiry date, doses per pack, target markets, and serial number. 

 

This information must be submitted to the European Medicines Verification System (EMVS) for all applicable medicine packs intended for sale in the market. In some cases, such as for parallel importation, reporting is also required by supply chain partners.

 

Data retention is also a key provision for the MAH, with EU FMD requiring that each MAH retain records of every operation that involves the unique identifier. Records must be available for a minimum of one year after the expiry date of the product, or five years after the pack has been released for sale or distribution, whichever is longer.

 

In terms of how information is shared with a government system, EU FMD compliance reporting for an MAH goes well beyond simply executing a file submission. For the EU, compliance reporting includes:

 

  • The collection and preparation of master and serialized pack data.
  • An understanding of how to manage notifications governing each target market for each product shipped into the market.
  • Management of master data, serialized pack data, product status, and exceptions through the European hub. 

 

<a href="/category/blog" hreflang="en">Blog</a><a href="/category/european-union-falsified-medicines-directive" hreflang="en">European Union Falsified Medicines Directive</a><a href="/category/global-compliance" hreflang="en">Global Track & Trace</a><a href="/category/regulatory-compliance" hreflang="en">Regulatory/Compliance</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