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Indonesia Track and Trace Regulations: What They Mean for the Pharma Industry

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Indonesia track and trace regulations are designed to prevent counterfeit, stolen, contaminated, or otherwise harmful drugs from entering the supply chain. The goal is to protect consumers and increase patient safety, as well as boost Indonesia’s competitiveness in the pharma global pharma industry.

The National Agency of Drug and Food Control (BPOM) began rolling out regulations in 2018. In 2022, it established provisions and procedures for implementing 2D DataMatrix codes for drug and food products. The country’s digital platform is called the Track and Trace Anti-Counterfeit (TTAC) system.

Key regulations went into effect in 2023; the next big deadlines are set for 2025 and 2027. So let’s take a closer look at Indonesia track and trace regulations and what they mean for the pharma industry.

Indonesia’s Pharma Market in Context

At the time of writing, Indonesia’s population is approaching 279 million — the fourth largest in the world. It’s no surprise, then, that the sprawling archipelago is the largest pharmaceutical market in Southeast Asia.

According to Business Indonesia, sales of medicines in 2020 were valued at about $7.6 billion (110.6 trillion rupiah); this is expected to increase to more than $11 billion (176 trillion rupiah) by 2025. In terms of U.S. dollars, this equates to a compound annual growth rate of 10.7 percent.

Furthermore, the Indonesian government is making significant investments in the country’s healthcare system. The same Business Indonesia article reported that healthcare spending in 2022 accounted for 9.4 percent of the total government budget.

In this context, Indonesia is seeking to expand and open its pharmaceutical sector to foreign participation and investment. Pharma companies that already have an in-country presence or that want to enter the market must fully understand — and comply with — Indonesia track and trace regulations.

The Framework of Indonesia Track and Trace Regulations

Most of today’s global pharma compliance requirements have a few things in common:

      • Companies must register products with a country’s regulatory body.
      • Companies must send compliance information to a centralized system (e.g., a portal or website like Indonesia’s TTAC).
      • Products must be labeled in a manner that identifies them at the unit level (i.e., serialization) and/or a “higher” level, such as a pallet or case (i.e., aggregation).
      • Regulators prefer GS1 labeling standards [e.g., 2D DataMatrix codes, Global Trade Item Numbers (GTINs), and Serial Shipping Container Codes (SSCCs)]. Read our “Understanding GS1 Barcodes in the Global Supply Chain” article for a comprehensive overview of these standards.

Indonesia track and trace regulations follow this basic framework:

Registration

Imported and locally produced medicines must be registered with the BPOM before they can be distributed. Pharma companies must have a local business agent or partner to register products, and it’s advisable to obtain all permissions before exporting products to Indonesia.

Labeling

The BPOM requires all medicines sold in Indonesia to be labeled for identification, and upcoming regulations will further require products to be labeled for authentication. The BPOM uses GS1 standards.

Identification Barcodes

Starting on December 7, 2023, traditional medicines and over-the-counter drugs — as well as cosmetics, supplements, processed foods, and some raw materials — were required to be labeled with a QR code that identifies the product in the market and verifies that it’s legal. For products that do not have to be serialized, this is the only marking required.

Identification codes must contain a Marketing Authorization Number and an NIE, or Nomor Izin Edar, which can be translated as “distribution permit number,” both issued by the BPOM. Alphanumeric NIEs provide master product data, including where the product was manufactured, and allow verification through a database called Cek Produk BPOM (“Check BPOM Products,” roughly).

Authentication Barcodes

December 7, 2025, is the deadline for serializing and labeling narcotics and psychotropics (e.g., antipsychotics and antidepressants) with a 2D DataMatrix code. By December 7, 2027, all prescription drugs, including biological products, must be serialized and authenticated. Aggregation, following GS1 standards, is also required.

The authentication codes must contain the following information:

      • A GS1 Global Trade Item Number (GTIN)
      • A Marketing Authorization Number from the BPOM
      • A production code or batch number
      • An expiration date
      • A serial number

Companies can obtain codes from the BPOM or from an independent source.

Some products/packs are exempt from the authentication requirement. These include blister packs, strip packs, pre-filled syringes, stick packs, single packaging, and catch covers.

Other Indonesia Track and Trace Regulations: Distribution

The BPOM has other requirements coming into effect between 2024 and 2026:

      • December 7, 2024: Distribution centers with minimum stock keeping units (SKUs) of 1,500 serialized products must submit reports to the BPOM.
      • December 7, 2025: “Second-tier” distribution centers (min. 750 serialized products) must submit reports to BPOM. Note that this coincides with the deadline for serializing and labeling narcotics and psychotropics.
      • December 7, 2026: “Third-tier” distribution centers (min. 400 serialized products) must submit reports to BPOM. This applies to certain categories of pharmacies or clinics.

Electronic Leaflet Pilot (2023-2025)

A pilot for electronic leaflets (e-leaflets) began in July 2023 and is scheduled to conclude in July 2025. Wanting to transition from a paper-based system, the BPOM plans to develop a dedicated mobile app for scanning a single code (likely the mandated GS1 2D DataMatrix code) that will take users to information online. The pilot is being conducted in three phases:

      • Phase I for vaccines and injections (completed)
      • Phase II for prescription drugs, including vaccines and injections (completed)
      • Phase III for over-the-counter and prescription drugs, including vaccines and injections (in progress)

Final Thoughts About Indonesia Track and Trace Regulations

As we said above, Indonesia is seeking to expand and open its pharmaceutical sector to foreign participation and investment. Pharma companies that already have an in-country presence or that want to enter the market must fully understand — and comply with — Indonesia track and trace regulations.

This is where we can help. Our solutions for global pharma compliance will help ensure you’re prepared for Indonesia’s requirements for product identification, serialization, and aggregation.

It’s all part of our 20-year commitment to protecting patients, combatting counterfeit drugs, and securing supply chains. Our solutions report into all global government agencies, help ensure you meet your regulatory obligations, and protect products and people everywhere you do business. Contact us today to learn how it works!

 

 

The U.S. Uyghur Forced Labor Prevention Act and Supply Chain Ethics

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Signed into law on Dec. 23, 2021, the U.S. Uyghur Forced Labor Prevention Act (UFLPA) prohibits the importation of certain goods into the United States and aims to ensure that businesses are not complicit in human rights abuses. It’s one of many regulations around the world that aim to make supply chains more ethical, transparent, and sustainable.

Let’s see what the act says and examine why supply chain transparency is the key to making such legislation viable and successful. For another example of recent laws, see our blog post about Germany’s Supply Chain Due Diligence Act.

What is the Uyghur Forced Labor Prevention Act?

The Uyghur Forced Labor Prevention Act, or UFLPA, is a response to concerns over forced labor and human rights violations in the Xinjiang Uyghur Autonomous Region in northwest China.

It’s worth quoting the U.S. Customs and Border Patrol website at length for a thorough description. It says the act:

“establishes a rebuttable presumption that the importation of any goods, wares, articles, and merchandise mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region of the People’s Republic of China, or produced by certain entities, is prohibited by Section 307 of the Tariff Act of 1930 and that such goods, wares, articles, and merchandise are not entitled to entry to the United States.

“The presumption applies unless the Commissioner of U.S. Customs and Border Protection (CBP) determines that the importer of record has complied with specified conditions and, by clear and convincing evidence, that the goods, wares, articles, or merchandise were not produced using forced labor.”

Furthermore, the act required the Forced Labor Enforcement Task Force, chaired by the U.S. Department of Homeland Security, to develop a strategy for supporting the legislation. This strategy was published on June, 1, 2021, and includes the UFLPA Entity List, which names “entities in Xinjiang that mine, produce, or manufacture wholly or in part any goods, wares, articles and merchandise with forced labor.”

Key provisions

The Uyghur Forced Labor Prevention Act has provisions to combat forced labor and enhance supply chain transparency, including:

      • Import restrictions: As we noted above, the act bans the importation of goods produced wholly or in part in China’s Xinjiang Uyghur Autonomous Region, unless importers can provide clear and convincing evidence that the goods were not produced with forced labor.
      • Enhanced due diligence: The act places the responsibility on companies to exercise due diligence and conduct comprehensive risk assessments of their supply chains to identify any forced labor risks or links to Xinjiang.
      • Publicly available information: Companies must disclose information on their efforts to ensure their supply chains are free from forced labor, including the specific measures they have implemented and the results of their due diligence assessments.
      • Coordination with government agencies: The act requires collaboration between government agencies, including the Department of Homeland Security, Department of Labor, and Department of State, to ensure effective enforcement and implementation of the legislation.

Implications and challenges for businesses

The act has very real implications for businesses operating in the United States. They must have the means to see into their partners’ operations, as well as into the often opaque landscape of secondary and tertiary suppliers. Other challenges include:

      • Not being able to produce audits that meet Forced Labor Enforcement Task Force credibility requirements
      • Traceability challenges in the supply chain (e.g., aggregated and commingled products with difficult-to-prove provenance)
      • Regulations in other countries that make compliance more difficult/complicated
      • Challenges related to sourcing (i.e., not being able to find a crucial raw material or item outside of China)

The government provides resources for businesses concerning the Uyghur Forced Labor Prevention Act. For example, see the U.S. Customs and Border Protection’s UFLPA Operational Guidance for Importers and its FAQs about the act.

Final thoughts

The Uyghur Forced Labor Prevention Act is part of broader regulatory efforts to eliminate forced labor and human rights abuses in global supply chains. Businesses must be prepared (and willing) to audit and assess their operations, engage with their suppliers (and their suppliers’ suppliers), and establish mechanisms to trace the origin of goods to ensure compliance.

And they should be proactive about it. A first step is contacting us to talk about supply chain transparency. Our transparency solutions enable companies to track and trace their supply chains in real time from virtually anywhere in the world. Our technology makes every product a “digital asset” with a certified, provable, and sharable provenance. We can show you how it works with a short demo.

If you’re interested in learning more about supply chain transparency, check out the articles below. “Transparency” means just about the same thing in every supply chain, so consider these as case studies about how it works, why it’s important, and the business benefits it can bring.

 

 

UAE Pharmaceutical Traceability: Ensuring Transparency with the “Tatmeen” Platform

Posted on by rfxadmin

The global push for pharmaceutical traceability and serialization continues at a furious pace. Today, we’re looking at the United Arab Emirates (UAE), whose Ministry of Health and Prevention (MOHAP) in June 2021 announced the “Tatmeen” platform for UAE pharmaceutical products traceability. There are key deadlines this year, so let’s take a look.

UAE Pharmaceutical Products Traceability and the Tatmeen System

MOHAP established Tatmeen, which means “assurance” in Arabic, in Ministerial Decree No. 73 on June 14, 2021. Described as a “central command center,” it’s a GS1-based platform for UAE pharmaceutical products traceability. MOHAP’s partners include the Dubai Health Authority (DHA), Department of Health (Abu Dhabi), and EVOTEQ, a “digital transformation catalyst” based in the UAE, and GS1 UAE.

Tatmeen’s goals should sound familiar:

    • Fight counterfeits and illegal and substandard medications
    • Eliminate unauthorized imports
    • Improve recall management
    • Ensure expired and about-to-expire drugs don’t reach consumers
    • Forecast demand and avoid shortages
    • Move drugs where they’re needed quickly and safely
    • Protect pharma companies, including their intellectual property rights

These other aspects should also sound familiar:

    • Products are scanned at every node of the supply chain
    • Product information is reported into to a central repository (in this case GS1’s BrandSync platform)
    • Scanning captures and verifies data in real time and reports information into a central database
    • Hospitals and pharmacies scan when drugs arrive at their facility and when they’re dispensed
    • Patients and consumers can scan with mobile devices to validate products, report expired products, fakes, and suspected gray market activity

Tatmeen will integrate with the DHA’s electronic medical record system, Salama (incorrectly identified as “Salam” in some industry sources). It will also utilize DHA’s Tarmeez, a paperless drug and medical supplies management system that gives authorized users access to a centralized electronic catalog of all available inventory.

Tatmeen labeling and reporting requirements

All conventional medicines sold, distributed, or stored in the UAE are regulated and must be serialized. These products are exempt:

    • Free samples
    • Products imported for personal use only
    • Medical devices and supplies
    • General sales list (GSL) products

And —surprise, surprise — UAE pharmaceutical products traceability requirements should sound familiar. Secondary packaging must contain four data points in a GS1 DataMatrix code and in human-readable form:

    1. Global Trade Item Number (GTIN)
    2. Randomized serial number (up to 20 characters)
    3. Expiry date (in YYMMDD format)
    4. Batch or lot number

This example is adapted from the MOHAP’s serialization guide:

UAE DataMatrix Code

Aggregation requirements should also ring a bell: All logistic units must be aggregated and labeled with a GS1-128 barcode encoded with a serial shipping container code (SSCC). Manufacturers are responsible for aggregation.

If a brand owner regards an item as a trade item, “it may additionally be identified with a GTIN.” Distributors, wholesalers, and health facilities that unpack and re-pack products to deliver to points of dispensing are required to aggregate the logistic units using their own SSCC codes.

Marketing authorization holders (MAHs), brand owners, manufacturers, or their subsidiaries must register and upload the mandated product master data into the BrandSync platform.

Domestic and foreign manufacturers, third-party logistics providers, batch releasers, contract manufacturing organizations, distributors, licensing agents, and MAHs are responsible for collecting serialized product item traceability records and reporting them to Tatmeen.

UAE pharmaceutical products traceability rollout and 2022 deadline

There was a 6-month “status adjustment” period after Tatmeen was announced for manufacturers and marketing authorization holders to register with the BrandSync platform and begin using 2D DataMatrix codes. This deadline passed on December 13, 2021.

The next major deadline is December 13, 2022. By that date, all supply chain actors in the UAE must obtain a Global Location Number (GLN) from GS1 UAE to identify their organization, where it’s located, and other required information. Relevant stakeholders must also begin reporting serial numbers to Tatmeen and begin aggregation with GS1-128 barcodes and SSCCs.

Final thoughts

We noted a few times that parts of the Tatmeen regulations should sound familiar. If you follow our blog and read our articles about pharmaceutical regulations in other countries — DSCSA in the United States, Chestny ZNAK in Russia, ANVISA in Brazil, ASL BELGISI in Uzbekistan, and so on — everything about UAE pharmaceutical products traceability should ring a bell.

As we said right at the start today, the global push for pharmaceutical traceability and serialization continues at a furious pace. Requirements may vary from country to country, but their essence is the same (e.g., protecting consumers, serialization, traceability, electronic reporting, central repositories, GS1 standards). Tatmeen is just one more example in a very large regulatory ocean.

It’s easy to feel swept up in this current. And, truth be told, if you’re not complying now or preparing to comply by published deadlines, you’re putting your business in jeopardy. If you have questions about Tatmeen or complying with pharmaceutical serialization and traceability regulations in any country, contact us today. In just a few minutes, our supply chain specialists can demonstrate how our award-winning Traceability System ensures you’re compliant in any country, today, tomorrow — always.

For even more information, check out our Global Compliance Page, download our Worldwide Pharmaceutical Compliance Requirements white paper, and catch up on other pharma news in our blog:

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