Tag Archives: Brazil

Brazil Publishes RDC-157 To Regulate 2017 3-Lot Pilot

ANVISA logoOn May 11, 2017, ANVISA formally published RDC-157/2017 that will serve as the regulations for their 3-Lot Pilot that is to take place in 2017.  We’ve been expecting this new RDC around this time because they were required by the recent Law Number 13.410 of December 28, 2016 (see “Brazil Gets Rational With Their New Pharma Traceability Law”).  ANVISA also held a “public consultation” to allow the public to review and comment on an earlier draft of what is now RDC-157/2016 (see “ANVISA Reveals Draft Serialization Regulation and Asks For Comments”).  The newly adopted RDC-157 is clearly intended to guide the pilot and then ANVISA intends to update it as part of their analysis of the pilot results.  They will likely go through another public consultation before they make it a final regulation that all companies will need to follow.  Bottom line, if you are not part of the 3-Lot Pilot, don’t start implementing a solution until Continue reading Brazil Publishes RDC-157 To Regulate 2017 3-Lot Pilot

Is Your Drug Too Small For The Mandated 2D Barcode?

Is your Drug Too Small?  Sample vial and syringe with barcode attached.
As an experiment, I taped the smallest DSCSA-compliant 2D barcode I could define to these sample vial and syringe from CCL Label. Notice that neither sample includes the required human readable text of the data encoded in the barcode, which means that these examples may not comply in some markets. The barcode on the vial is readable, but the one on the syringe is not readable because of the short radius of the barrel (about 5mm).

RxTrace readers are already well aware that multiple new laws around the world will require prescription drug manufacturers to put a new 2D barcode on their products in the next few years.  But what if your drug package is too small to fit the new mandated 2D barcode and human readable information on the label?  Let’s take a look at what the regulations say in the E.U., Brazil and the United States.  From that, we can come up with some strategies. Continue reading Is Your Drug Too Small For The Mandated 2D Barcode?

ANVISA Reveals Draft Serialization Regulation and Asks For Comments

Last week, the National Agency of Sanitary Surveillance (ANVISA), the healthcare regulator in Brazil, published a draft of their proposed pharma serialization regulations aimed at meeting the requirements of the new law number 13.410 of December 28, 2016 (see “Brazil Gets Rational With Their New Pharma Traceability Law”).  The purpose of this new publication is to solicit comments from interested parties.  It is called “Public Consultation No. 311 of February 15, 2017”.  This is not a final regulation—the public consultation ends on March 17, 2017, after which changes to the text, based on the feedback collected, are likely before it becomes final—but it provides us with a solid view of ANVISA’s thinking, and that amounts to a big win for the industry, and for Brazil.  Now is the time to read it over and submit your comments to help make it even better. Continue reading ANVISA Reveals Draft Serialization Regulation and Asks For Comments

Serializing Product Groupings Under Global Regulations

A “product grouping” is any collection of saleable units of products that are bound together in some way.  They can be “bundles”, homogeneous or non-homogeneous cases, totes, pallets or something like these.  The pharma serialization regulations in some markets call out some of these groupings for special treatment, and some do not.  I’ll try to catalog what we know about product groupings in each of the current, known regulations. Continue reading Serializing Product Groupings Under Global Regulations

Brazil Gets Rational With Their New Pharma Traceability Law

Last week, Brazil President Michel Temer signed law number 13,410, which amends law number 11,903 from 2009, their original pharma serialization and tracing law.  The effect of the new law on the old can be seen here.  The problem for me is that I don’t read Portuguese, so I must rely on Google Translate to translate these texts.  This results in an unofficial translation that has a few imperfections that are obvious, even to non-Portuguese readers, but it appears to be not bad. Continue reading Brazil Gets Rational With Their New Pharma Traceability Law

China’s Retreat From Pharma Serialization: Will This Become A Global Trend?

istock_102889873_smallerChina once had one of the most aggressive pharma serialization mandates of any market.  Their compliance timeline began in 2007 with a list of “essential drugs” and ended in January of this year when, effectively, all drug packages were required to carry a unique serial number.  Shortly after that milestone the government suspended that requirement, pending a new regulation.  Since that time the China Food and Drug Administration (CFDA) has posted several documents related to their new plans (see “China Adds Traceability Requirement To CFDA Drug Quality Management Specification”).  Last month a new notice from the CFDA Continue reading China’s Retreat From Pharma Serialization: Will This Become A Global Trend?

Sponsored: Brazil Officially Suspends All Remaining Serialization Deadlines Of RDC-54

iqpc-serial-labeling-playbook-2016Apparently, the National Agency of Sanitary Surveillance (ANVISA), Brazil’s pharma regulatory body, has passed a resolution that finally suspends all remaining serialization deadlines that were left over in their old RDC-54 regulation.  Remember that they suspended the deadline for the 3-lot pilot from RDC-54 last year (see “The Official Suspension of the Three-Lot Pilot in Brazil“).  I consider this news to be a “rumor” only because I have not yet seen the official word, despite having heard it from a very reliable source.

This is not Continue reading Sponsored: Brazil Officially Suspends All Remaining Serialization Deadlines Of RDC-54

Proposed Pharma Serialization Regulation Progresses in Brazil

395px-Coat_of_arms_of_Brazil.svgThe government of Brazil is trying to recover from the poor design of their first attempt at a pharma serialization and tracing regulation, RDC-54/2013.  That first regulation was at least partially suspended (see “Brazil Suspends Pharma Serialization And Tracing Requirements” and “The Official Suspension of the Three-Lot Pilot in Brazil”).  Everyone seems to be operating under the assumption that the entire RDC-54-2013 will be replaced with a new regulation.  Legislation to do exactly that has been slowly churning its way through the Legislature for the last 9 months.  Word came last week that Continue reading Proposed Pharma Serialization Regulation Progresses in Brazil