Executive Summary:
This Public Notice amends the Handbook of Procedure 2015-2020, focusing on implementing a track and trace system for exported drug formulations. It details barcode printing requirements at different packaging levels and data maintenance in a parent-child relationship. The notice extends certain exemptions for Small Scale Industries (SSI) manufacturers regarding data uploading until specific dates.
Key Points / Main Content:
Barcode Printing Requirements:
* Manufacturers/exporters must print barcodes according to GS1 Global Standards for tracking.
* Primary Level: 2D barcode with GTIN, batch number, expiry date, and serial number. Barcode labeling is exempt until further notice, but details must be printed in human-readable form.
* Secondary Level: 1D or 2D barcode with GTIN, batch number, expiry date, and serial number. Barcoding on mono cartons is optional until further notice.
* Tertiary Level: 1D barcode with GTIN, batch number, expiry date, and Serial Shipping Container Code (SSCC).
Parent-Child Relationship Data:
* Manufacturers/exporters must maintain data in a parent-child relationship for primary, secondary, and tertiary packaging levels.
Exemptions and Deadlines:
* All manufacturers were initially exempt from maintaining the parent-child relationship and uploading it to the central portal until 31.03.2016.
* SSI drug manufacturers have an extended exemption from maintaining the parent-child relationship until 31.03.2017 but must upload tertiary-level data to the central portal.
* Non-SSI units with manufacturing dates on/after 01.04.2016 and SSI units with manufacturing dates on/after 01.04.2017 can only export drugs if both tertiary and secondary packaging have barcodes and relevant data is uploaded.
Data Upload and Responsibility:
* Manufacturers/exporters must upload data to the central portal before releasing drug formulations for sale/distribution.
* Manufacturers/exporters are responsible for data correctness, completeness, and timely uploading.
Exemptions based on Importing Country Requirements:
* Rules i to iv are not applicable for drug formulations manufactured for export purposes, where the government of the importing country has mandated a specific requirement and the exporter intends to avail the option of printing the barcodes in their format after duly obtaining the permission of DCGI or its nominee.
SSI & Non-SSI Exemptions based on Manufacturing Date:
* Export of drugs manufactured by nonSSI units and having manufacturing date prior to 31.03.2016 and export of the drugs manufactured by SSI units and having manufacturing date prior to 31.03.2017 are exempted from requirement of data uploading on Central Portal
Clarifications:
* Relevant guidelines, exemption procedures, data requirements, and clarifications are available on the central portal (http:dava.gov.in).
Customs Compliance:
* Drug manufacturers/exporters must satisfy customs authorities that export consignments meet notification conditions.
Supersession:
* This notice supersedes Public Notice No. 13/2015-2020 dated 22.05.2015, extending the implementation dates for the track and trace system.
Impact Analysis
Drug Manufacturers/Exporters:
Impact: Must implement barcode system at various packaging levels and maintain parent-child data relationships. Subject to new deadlines for compliance based on SSI status and manufacturing date. Responsible for data accuracy and timely uploads.
Action Required: Implement barcode printing as per GS1 standards, maintain parent-child data, upload data to the central portal, comply with new deadlines, and ensure customs compliance.
Small Scale Industries (SSI) Drug Manufacturers:
Impact: Granted extended deadlines for data maintenance and uploading compared to non-SSI units.
Action Required: Upload tertiary-level data to the central portal and comply with the extended deadline of 31.03.2017 for maintaining parent-child relationships.
Customs Authorities:
Impact: Need to verify that export consignments meet the conditions of this notification.
Action Required: Ensure that drug manufacturers/exporters comply with the barcode and data uploading requirements.
Directorate General of Foreign Trade (DGFT):
Impact: Responsible for prescribing relevant data to be uploaded on the Central Portal
Action Required: Ensure that drug manufacturers/exporters comply with the barcode and data uploading requirements.
Key Entities Referenced
Foreign Trade Policy, 2015-20: A trade policy that is amended from time to time, and is used as the basis for the current notification.
Directorate General of Foreign Trade: The organization issuing the public notice regarding amendments to procedures for export of drug formulations.
Handbook of Procedure, 2015-20: A document that is being amended by the Directorate General of Foreign Trade regarding the implementation of a track and trace system.
Track and Trace system: A system for tracking and tracing export consignments of drug formulations, involving barcoding and data uploading.
GS1 Global Standard: A standard used for printing barcodes at different packaging levels to facilitate tracking and tracing of products.
Global Trade Item Number (GTIN): A 14-digit code used for unique and universal global product identification, encoded in barcodes.
Drugs Cosmetics Act: Indian law governing the manufacture and distribution of drugs and cosmetics, relevant to the licensing of drug formulations.
Drug Control Authority: Authority responsible for issuing licenses for drug manufacturing as per the Drugs and Cosmetics Act.