On May 22nd, 2015, India’s Directorate General of Foreign Trade (DGFT) quietly published Public Notice #13 with the subject “Implementation of the Track and Trace system export of drug formulations”. It was an amended version of Public Notice #4, dated April 1, 2015 with a similar subject. Get it? April Fools!
I have to admit, I fell for it. Did you? In my essay on April 17 titled “India’s Pharma Export Regulations Update And The NECC Story” I said of the original notice,
“The new requirements will either result in the shutdown of the country’s entire drug export business, or they will force the Directorate General of Foreign Trade (DGFT) to push out the deadlines to avoid that business calamity.”
How embarrassing. But in my defense, I did not know that the DGFT was such a big fan of April Fools’ Day. And now, looking back, it seems so obvious. I mean, look at the date it was published. How could we have taken it seriously when it was so obviously impossible. Or I should say, “how could I have taken it so seriously…”. You probably caught what I missed.
Anyway, now we have the serious version with an effective date of October 1, 2015 rather than July, everyone exporting drugs from India had better pay attention. I’m not sure an extra three months makes it workable, but this new serious version also says the following things must be done on an “optional basis” until further notice, which will help a lot:
- human readable serial number on primary packaging (the serial number encoded within the barcode was already exempted until further notice);
- aggregation data collection and reporting between primary and secondary packaging;
- the barcode on mono cartons.
These were the things that made the April Fools’ version such a good joke. My only complaint is that the DGFT took so long before letting us all know their first version was not intended to be taken seriously. Good April Fools’ jokes usually start out sounding really serious and shocking–this one did a great job of that–but then, by the time you get down to the end, they make it clear that it’s just a joke. Waiting an additional seven weeks before letting us in on the joke kind of takes the humor out of it.
Adam Fein is king of this kind of thing. I look forward to April 1st every year because I know Dr. Fein will post a really great April Fools’ joke on his Drug Channels blog. Here are some great examples to help the DGFT improve its act next year:
- 2015: BREAKING NEWS: Rite Aid Acquires Candy Maker, Launches New Rewards Program
- 2014: BREAKING NEWS: Walgreens to Start Selling Marijuana in Retail Drugstores
- 2013: Walmart Adds Low-Cost Surgical Procedures
- 2012: April 1st fell on a Sunday, sorry, no April Fools’ essay that year.
- 2011: BREAKING NEWS: Amazon.com to Acquire Rite Aid
- 2010: Hidden Requirements in New Health Care Bill
- 2009: Wal-Mart to Buy Walgreens
All classic April Fools’ jokes. And even though yours wasn’t quite as good as Dr. Fein’s, thanks DGFT for that zany original document! Now I have two reasons to look forward to April 1st each year!