The European Union’s Falsified Medicines Directive (EU FMD) is just a few months away. On February 9, 2019 the law takes effect and those companies who aren’t serialized and traceable will not be able to sell their goods. The pressure of this deadline necessitates action – immediate action – but, according to a letter from the European Medicines Verification Organisation (EMVO) to all Marketing Authorisation Holders (MAHs), about 1500 MAHs have yet to begin the EMVO onboarding – a critical step in ensuring compliance with the FMD.
Pharmaceutical Journal, in their coverage, stated “only 841 companies have completed the first stage of connection: the signing of a participation agreement. Of those, only 106 companies have progressed to become fully connected to the production environment of the EU Hub.” So far, only 5 percent of all MAHs are fully compliant with the FMD.
The EMVO, in its letter and in previous letters, has stated that the onboarding process can take up to six months, and the last time to ensure no delays or complications would have been to start onboarding by June of 2018. June of 2018 has past, and unlike the US DSCSA, there has been no announced delays in the enforcement of the FMD.
What to do now:
Companies that haven’t begun the onboarding process should begin as soon as possible. The EMVO stated that it will not be responsible for any MAH that fails to complete onboarding or fails to begin the onboarding process on time. This places enormous pressure on companies to begin the onboarding process; as of now there is no guarantee that the onboarding process will be done by February 9, 2019.
Fortunately, onboarding with the EMVO is easier when MAHs choose the right solutions provider. rfxcel is pre-certified with the EMVO, allowing new onboarding partners to skip steps in the technical onboarding process. To ensure compliance by the FMD deadline you should begin the EMVO onboarding process immediately.
Connecting to the EMVO is critical for compliance with the FMD, but more integral is actually being able to serialize all products at a unit level with a 2D barcode including a batch number, expiry date, global trade item number (GTIN) and a randomized serial number. If your manufacturing line is not already prepared for serialization, then you have bigger problems than not having started the onboarding process for the EMVO. Companies that are not compliant by February 9, 2019 will likely be placed in a very inconvenient position – they must either send their finished goods to a CMO already compliant with FMD to serialize their products, or they must manufacture an excess and release their products before February. Our advice is to get started immediately. Perhaps you’ll have to use a combination of some or all of these approaches, but you’ll be closer to the finish line and compliance if you get started today.
The rfxcel Difference:
rfxcel is already pre-approved by the EMVO, allowing our customers to skip steps in the EMVO onboarding process. Beyond being able to provide an expedited onboarding process, we promise to provide our customers with a short implementation process, extensive data verification, a system that the customer is in control of, and straightforward pricing.
It is not too late to begin onboarding with the EMVO. Contact rfxcel today to learn how we can help you comply with the FMD.