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 is Article 23 and What Does it Mean for Wholesalers?

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

Table of contents

EU FMD is intended to define and enforce a safe supply chain where the safety features of a product are verified and decommissioned by a hospital or pharmacy before it is dispensed to the patient. If a product leaves the supply chain prior to being dispensed through a hospital or pharmacy, EU FMD requires that it still must be verified and decommissioned.

Chapter V, Article 23 of the Delegated Regulation states that Member States may require, where necessary, that a wholesaler verifies the safety features and decommissions a medicinal product before it supplies that product to an institution other than a dispensing hospital or pharmacy. Examples of those institutions include universities, veterinary surgeons, and government bodies. You can read the full Delegated Regulation here.

How Article 23 is implemented is open to interpretation by each Member State’s national healthcare authority. For example:

  • A government may purchase medicines in order to stockpile them in the event of a national emergency. The national authority could decide to exercise Article 23 to require the wholesaler that sells those products to the government to first verify and decommission them.
  • In the UK, the MHRA (the UK healthcare authority) could decide to implement Article 23 to require hospitals with a wholesaler license to decommission medicines it provides to non-healthcare institutions, such as social care and charitable organizations.

Discussions are ongoing with national authorities to define how each will implement Article 23. The recommendation to wholesalers is to register with their National Medicines Verification Organization (NMVO) in advance of the February 2019 deadline, as verification and decommissioning happens through the National System. The NMVO and national authorities will also provide updates on the implementation of Article 23.

How TraceLink helps

TraceLink’s Edge Track can help wholesalers capture, process and exchange serialized product data, and effectively manage product decommissioning. Establishing one connection to the TraceLink network also allows wholesalers to exchange product data with upstream and downstream partners, drastically reducing connection and integration costs while ensuring that they remain in compliance with national systems. The ability to connect quickly with partners will be even more important to help manage product recalls and returns.

<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