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DSCSA 2023: Understanding DSCSA Authorized Trading Partners, Part 1

The Drug Supply Chain Security Act (DSCSA), enacted in 2013, was envisioned as a 10-year plan to secure the U.S. pharmaceutical supply chain through enhanced track and trace systems and processes. Milestones have come and gone, 2023 isn’t that far off, and now everybody is talking about DSCSA authorized trading partners.

Why are DSCSA authorized trading partners on everyone’s mind? It’s because these supply chain stakeholders — manufacturers, wholesale distributors, repackagers, third-party logistics providers (3PLs), and dispensers — are pivotal to the regulatory rollout, which is scheduled to conclude on November 27, 2023. From here on out, the focus will be getting DSCSA authorized trading partners ready to comply with the regulations.

The U.S. Food and Drug Administration (FDA) has clarified the definitions of and guidance for DSCSA authorized trading partners, but we want to distill that further into an easy-to-understand explanation. In Part 1 of our “DSCSA 2023” series, we’ll take a look at manufacturers and wholesalers; Part 2 will talk about repackagers, 3PLs, and dispensers. In Part 3, we’ll break down the specific requirements for 2023.

DSCSA authorized trading partners: an overview

Under the DSCSA, authorized trading partners may engage in transactions only with other authorized trading partners. In other words, manufacturers, wholesale distributors, repackagers, 3PLs, and dispensers and their trading partners must all be authorized trading partners. If you are not a DSCSA authorized trading partner, your access to the U.S. pharma supply chain will be severely restricted or denied altogether.

Below, we explain how the DSCSA defines manufacturers and wholesale distributors.


To be considered a manufacturer, you must meet one of three criteria:

  1. You manufactured the product.
  2. You’re an approved application holder or a co-licensed partner of the approved application holder; if the latter, you must have obtained the product directly from the application holder or entity that manufactured the product.
  3. You’re an affiliate of the manufacturer and obtained the product directly from the application holder or entity that manufactured the product.

A manufacturer is considered a trading partner if it accepts or transfers direct ownership of a product from or to another manufacturer, a repackager, a wholesale distributor, or a dispenser. As defined in 1-3 above, a manufacturer is a DSCSA authorized trading partner if it:

  1. Is registered with the FDA in accordance with Section 510 of the Food, Drug, and Cosmetics Act, Ҥ360. Registration of producers of drugs or devices
  2. Is compliant with Section 510 of the FD&C Act
  3. Is compliant with Section 510 of the FD&C Act

Wholesale distributors

To be considered a wholesale distributor, you must distribute a drug to a person other than a consumer or patient.

A wholesale distributor is considered a trading partner if it accepts or transfers direct ownership of a product from or to another wholesale distributor, a manufacturer, a repackager, or a dispenser. To be a DSCSA authorized trading partner, a wholesale distributor must have a valid license under state law or FD&C Act Section 583, “National Standards for Prescription Drug Wholesale Distributors,” in accordance with Section 582(a)(6), “Wholesale distributor licenses,” as amended by the DSCSA and in compliance with reporting requirements under Section 503(e), “Licensing and reporting requirements for wholesale distributors.”

Of note: manufacturers that distribute their own drugs are not required to meet licensure requirements for wholesale distributors. In fact, the FDA excluded several other entities from the definition:

  • A manufacturer’s co-licensed partner
  • A 3PL
  • A repackager
  • Entities excluded from “wholesale distribution” pursuant to Section 503(e)(4) — a dispenser, a dispenser-affiliated warehouse or distribution center, or a dispenser who transfers product to another dispenser for a specific patient need

However, “jobbers” are considered wholesale distributors. The FDA defines jobbers as those who do wholesale distribution on a small scale or sell products only to retailers and institutions. Dispensers that transfer product to another dispenser without a specific patient need are also jobbers — which means they’re also considered wholesale distributors.

Final thoughts

If you follow our blog, you know we’ve been covering the DSCSA for a long, long time. We’ve hosted webinars, including the recent “Plan for DSCSA Readiness,” written white papers , and been active in industry initiatives, particularly the Verification Router Service (VRS), for which we led an FDA-approved pilot to extend testing of the system, and the Open Credentialing Initiative (OCI) to meet the requirements for DSCSA authorized trading partners.

So check back soon for Part 2 of our “DSCSA 2023” series, which will discuss repackagers, 3PLs, and dispensers. In the meantime, contact us if you have questions about the DSCSA. Our supply chain experts will be happy to speak with you and demonstrate how our solutions have made us the leader in pharmaceutical compliance.

New Russian Serialization Pilot for Biologically Active Food Additives

A new Russian serialization pilot for biologically active food additives was announced last month. It’s scheduled to run from April 1 of this year to March 1, 2022.

The government has not said much beyond about the pilot. It has revealed a lot more about the Russian serialization pilot for beer and beer-based drinks, which it announced last October. Read our blog post about that to get all the details.

Let’s take a look at what we do know about the Russian serialization pilot for biologically active food additives. After that, we’ll give you a sneak peek at what we’re doing to make sure stakeholders in every industry regulated by Russia’s National Track and Trace Digital System, known as Chestny ZNAK, know exactly what to do to comply with the strict requirements.

Russian serialization pilot for biologically active food additives

As we said above, the Russian government hasn’t said much about the new pilot, which was formalized through a draft decree entitled “On Conducting an Experiment on the Labeling of Biologically Active Food Additives by Means of Identification in the Territory of the Russian Federation.”

Chestny ZNAK has shared a list of what products will be labeled and their corresponding Eurasian Economic Union Combined Nomenclature of Foreign Economic Activity (TN VED) codes. It’s also been reported that the Center for Research in Perspective Technologies (CRPT), which operates Chestny ZNAK, will provide equipment to pilot participants.

Here are the products that will be included in the Russian serialization pilot for for biologically active food additives. It’s a long list. Be sure to scroll down to our “Final Thoughts” to read about our plans for Russian supply chain compliance!


Pilot Dates: April 1, 2021–March 1, 2022

TN VED CodeDescription
1210 20 9000Oil seeds and oleaginous fruits; miscellaneous grains, seeds, and fruit; industrial or medicinal plants; straw and fodder
1212 21 000 0Locust beans, seaweeds, and other algae, sugar beet and sugar cane, fresh, chilled, frozen or dried, whether or not ground; fruit stones and kernels and other vegetable products (including unroasted)
1504 10 1000Fish liver oils and their fractions with Vitamin A content not exceeding 2500 iu/g
1504 20 900 0Other fish fats, oils, and their fractions, other than fish liver oils, other than solid fractions
1516 10 900 0Other animal fats and oils and their fractions
1517 90 990 0Other edible mixtures or preparations of animal or vegetable fats or oils or fractions of different fats or oils of this chapter, other than edible fats or oils
1702 90 950 0Other, including invert sugar and other sugar and sugar syrup blends containing in the dry state 50% by weight of fructose
1704 90 550 0Throat and cough lozenges not containing cocoa
1806 31 0000Other product containing cocoa, in blocks, slabs, or bars, filled
1806 32 100 0Cocoa and cocoa preparations (other preparations containing cocoa, not filled, but with added cereal grains, fruits, or nuts in blocks, slabs, or bars)
1806 32 900 0Other preparations containing cocoa, but not filled, in blocks, slabs, or bars
1806 90 700 0Preparations containing cocoa and intended for manufacture (preparation) of drinks
1806 90 900 0Other preparations containing cocoa
2101 12 920 1Preparations with a basis of extracts, essences, or concentrates of coffee
2106 10 800 0Other protein concentrates and textured protein substances
2106 90 590 0Other sugar syrups with flavoring or coloring additives
2106 90 920 0Other food preparations not containing butter fat, sucrose, isoglucose (i.e., high-fructose corn syrup), glucose, and starch, or containing less than 1. 5% by weight of butter fat, 5% by weight of sucrose or isoglucose, 5% by weight
2106 90 980 3Mixtures of vitamins and minerals for use as a balanced dietary supplement
2106 90 980 9Other food preparations not elsewhere specified or included
2106 90 9801Sugar- (sucrose) free chewing gum and/or with a sugar substitute product
2202 90 100 9“Others” under Code 2202: “Beverages and spirits and vinegar”
2202 99 190 0Other beverages not containing preparations of headings 0401 to 0404 or fat obtained from preparations of headings 0401 to 0404:

  • 0401: Milk and cream, not concentrated nor containing added sugar or other sweetening matter
  • 0402: Milk and cream, concentrated or containing added sugar or other sweetening matter
  • 0403: Buttermilk, curdled milk and cream, yogurt, kephir (a.k.a. kefir), and other fermented or acidified milk and cream, whether or not concentrated or containing added sugar or other sweetening matter or flavored or…
  • 0404: Whey, whether or not concentrated or containing added sugar or other sweetening matter; products consisting of natural milk constituents, whether or not containing added sugar or other sweetening…
2936 21 000 0Vitamins A and their derivatives
3002 90 500 0Cultures of microorganisms
3204 19 000 0Synthetic organic coloring matter and preparations based thereon, including mixtures of coloring matters of the subheadings 320411 to 320419:

  • 320411: Disperse dyes and preparations based thereon
  • 320412: Acid dyes, whether or not premetallized, and preparations based thereon; mordant dyes and preparations based thereon
  • 320413: Basic dyes and preparations based thereon
  • 320414: Direct dyes and preparations based thereon
  • 320415: Vat dyes (including those usable in that state as pigments) and preparations based thereon
  • 320416: Reactive dyes and preparations based thereon
  • 320417: Pigments and preparations based thereon
  • 320419: Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments, and other coloring matter; paints and varnishes; putty and other mastics; inks
3503 00 100 9Other gelatin and its derivatives
3507 90 900 0Other prepared enzymes not elsewhere specified or included

Final thoughts

Our team in Russia fields many, many questions about Chestny ZNAK, and industries that must comply with the supply chain regulations. They love hearing from people and helping them understand the rules for doing business in Russia.

If you follow our blog (and we know you do), you know we’re the leader in Russian compliance. You also know we write a lot about Russian supply chain regulations. Most recently, we covered the pilot for beer, updated labeling requirements for cheese and ice cream products, and “notification mode” in the pharma supply chain. We also did a Chestny ZNAK refresher course.

So, when we heard about the Russian serialization pilot for biologically active food additives, we thought it was time to update our white papers for 2021. There have been a lot of changes over the last year. Deadlines have changed. Other pilots have ended. Requirements and process have evolved. We’re including all the latest information from Chestny ZNAK and providing much greater detail about products and requirements.

The papers — including Russian versions — be ready soon. We’ll let you know when they’re available. In the meantime, our 2020 white papers are still online. You can also visit our website for more information about our solutions for Russian compliance and contact our team in Moscow directly.

rfxcel Enters into Acquisition Agreement with Antares Vision Group

The combination of rfxcel’s industry-leading traceability software platform and Antares Vision’s solutions for intelligent track and trace will create significant value for customers.

Reno, Nevada, Feb. 19, 2021 (EINPRESSWIRE). rfxcel, a global leader in digital supply chain traceability solutions, today announced that it had entered into an acquisition agreement with Italy’s Antares Vision Group, a leading global provider of intelligent track and trace, inspection, and smart data management solutions for the life sciences and food and beverage sectors.

rfxcel CEO Glenn Abood said the agreement marked the start of an expansive era for the company he co-founded with Chief Strategy Officer Jack Tarkoff in 2003. “This is an exciting new chapter for rfxcel,” he said, “a time for the company and our customers to look to the future.

“Becoming part of Antares Vision Group will give us new ways to strengthen our relationships with our customers and provide them with enhanced solutions as they do their important work in the life sciences, food and beverage, consumer goods, and government industries. Plus,” Abood continued, “the integration of our companies’ capabilities will enable us to drive into new markets and geographies as the undisputed leader in supply chain track and trace solutions. It really is a ‘win-win’ for our global teams and our customers.”

The Antares Vision Group will leverage rfxcel’s capabilities and signature rfxcel Traceability System (rTS) software suite to help customers accelerate their transition toward digital and sustainable supply chains characterized by full transparency and visibility. Together, the companies will provide a full stack, end-to-end digital supply chain solution that will optimize and streamline customers’ operations while providing complete end-to-end visibility, from product ingredients and raw materials to the end customer experience.

rTS is a digital supply chain visibility platform comprising up to eight discrete solutions that work in concert to harmonize, optimize, automate, and monitor virtually every aspect of supply chain operations, including serialization, regulatory compliance, Internet of Things (IoT)-enabled monitoring, and raw materials and finished goods traceability. rfxcel also offers a Mobile Traceability app that extends the power of rTS to users at every node of the supply chain, from remote fields and warehouses to retail outlets.

Emidio Zorzella, chairman and CEO of Antares Vision, said he and co-founder Massimo Bonardi were “delighted” about the agreement with rfxcel. “Demand for traceability and serialized products and services has increased significantly over the last few years,” he said, “and this transaction accelerates our ability to offer best-in-class propositions in all our key reference sectors, life science and food and beverage. We look forward to welcoming the management and employees of rfxcel to the Antares Vision Group and working together to serve our customers across the world.”

Abood added that both companies shared the same goals and Antares Vision would help rfxcel accelerate its plans. “The rfxcel management team is delighted to join with Antares Vision to offer customers the most complete end-to-end solution for track and trace on the market today.”

For more information about the acquisition agreement or the companies’ solutions, contact Herb Wong, rfxcel’s vice president of marketing and strategic initiatives, at or 925-824-0300.

About rfxcel

Founded in 2003, rfxcel provides leading-edge software solutions to help companies build and manage their digital supply chain, lower costs, and protect their products and brand reputations. Blue-chip organizations in the life sciences (pharmaceuticals and medical devices), food and beverage, worldwide government, and consumer goods industries trust rfxcel’s signature Traceability System (rTS) to power end-to-end supply chain solutions in key areas such as track and trace, environmental monitoring, regulatory compliance, serialization, and visibility. The company is headquartered in the United States and has offices in the United Kingdom, the EU, Latin America, Russia, India, Japan, the Middle East, and the Asia-Pacific region.

About Antares Vision

Listed since April 2019 on the AIM Italia market of the Italian Stock Exchange, Antares Vision Group guarantees the protection of products, people and brands through inspection systems for quality control, track and trace solutions for anti-counterfeiting and supply chain transparency, smart data management tools for maximized efficiency and digitalization of the supply chain, from the point of production to the end consumer. The Antares Vision Group is active in the life science sector, including the pharmaceutical, medical device, and hospital segments, as well as in other industries, including, primarily, food and beverage, cosmetics, and in consumer-packaged goods. The Group reaches over 60 countries worldwide with complete and flexible solutions, hardware, and software, with related services: it has five offices in Italy (Brescia, Parma, Piacenza, Latina and Vicenza), 15 foreign branches (Germany [2], France [2], USA [3], Latin America [2], India, Russia, Hong Kong, China, Croatia, and Serbia), three Innovation and Research Centers (Italy) and a worldwide network of more than 40 partners. With the 20 years of experience in vision technologies of the two founding partners, the Antares Vision Group is the supplier of 10 of the 20 leading pharmaceutical companies in the world (by turnover), with more than 25,000 inspection systems, which ensure everyday product safety and quality, 6,500 quality controls, and more than 3,500 serialization modules on lines installed all over the world. With the aim of continuing and supporting the growth and development strategy, during 2019, Antares Vision finalized participation agreements with T2 Software, a Brazilian company specialized in smart data management solutions, and Orobix, an Italian company leader in artificial intelligence services, and acquired 100 percent of FT System, leader in control and inspection in the beverage sector. In 2020, Antares Vision acquired 82.83 percent of Tradeticity, a Croatian company specialized in software management of traceability and serialization processes, 100 percent of Convel, an Italian company specialized in automated inspection machines for the pharmaceutical industry, the assets of Adents High Tech International, a French company specialized in software for serialization and traceability, and 100 percent of Applied Vision, a global leader in inspection systems for glass and metal containers in food and beverage. In 2019, Emidio Zorzella and Massimo Bonardi won the Ernst & Young “Entrepreneur of the Year” award for innovation. For more info:

What Does the EU COVID-19 Vaccine Distribution Plan Look Like?

The EU announced its COVID-19 vaccine strategy on June 17, 2020. Among other things, it called for ensuring the quality, safety, and efficacy of vaccines, securing quick access to vaccines, and ensuring equitable access to an affordable vaccine as early as possible. It also called for adapting the EU’s regulatory framework and taking advantage of regulatory flexibility to address the urgent need.

Let’s take a look at what the EU has said about its COVID-19 vaccine distribution plan and answer some frequently asked questions about its vaccine administration.

What vaccines are being used in the EU?

The European Commission says it wants to “build a diversified portfolio of vaccines based on different technologies, to increase the chances that one or more of the vaccine candidates are approved by EMA.”

The EU authorized the BioNTech-Pfizer COVID-19 vaccine on December 21, 2020, and the Moderna vaccine on January 6, 2021. It did this after the European Medicines Agency (EMA) assessed their safety, quality, and efficacy.

On January 8, the Commission reported that it had concluded contracts for 600 million doses of the BioNTech-Pfizer vaccine and 160 million doses of Moderna’s vaccine. It also reported securing contracts for millions of doses from AstraZeneca, Sanofi-GSK, Johnson and Johnson, and CureVac, and that it had concluded “exploratory talks” with Novavax and Valneva.

Then, on January 29, the Commission announced that AstraZeneca agreed to publish the redacted contract it signed on August 27, 2020, and that CureVac agreed to publish the Advance Purchase Agreement with the EU.

The Commission says it has secured more than 2.3 billion doses of COVID-19 vaccines, adding that if all the vaccine candidates are found to be safe and effective, EU Member States could donate part of their doses to lower- and middle-income countries.

Who will receive the vaccine and when?

As of January 8, the EU said that all Member States would have access to COVID-19 vaccines at the same time, based on the size of their population. On January 29, the Commission enacted a measure requiring Member States to authorize vaccine exports, stating this will “ensure timely access to COVID-19 vaccines for all EU citizens and … tackle the current lack of transparency of vaccine exports outside the EU.”

The Commission says the number of doses will be limited during the initial stages the immunization effort and before production can be ramped up. As in other countries, authorities have said that there will not be enough doses to vaccinate everybody right away; it will take time.

Most members have defined who will get the vaccine first and are further refining sub-groups to assign priority. Frontline healthcare professionals and people over 80 years old top the lists. For more insight about the rollout, see this December 2020 report from the European Centre for Disease Prevention and Control about preparedness in the EU, the European Economic Area, and the UK. The Centre also has a useful “Situation Update” page that tracks the pandemic in the EU.

Vaccine supplies will increase over time, the Commission says, and all adults should be able to get vaccinated during 2021. It predicts that at least 80 percent of people over the age of 80 and 80 percent of health and social care professionals should be vaccinated by March 2021. By this summer, the Commission says 70 percent of the EU’s adult population should be vaccinated. These projections, however, are probably optimistic, as the rollout has been slow and fewer doses than expected have been delivered.

Final thoughts

As we said in our blog post about COVID-19 vaccine distribution in the United States, the world is in an “all hands on deck” situation. We like to think we’ve been part of the effort since the pandemic began.

In April 2020, we joined the COVID-19 Healthcare Coalition, offering our Accurate Immunization Management (AIM) and rfxcel Integrated Monitoring (rIM) solutions. rIM is a real-time environmental monitoring solution that uses Internet of Things (IoT)-enabled devices to monitor products while they’re in transit; it’s a powerful, ideal solution for the pharma cold chain, which is vital to vaccine distribution.

AIM ensures that the right person gets the right vaccine at the right time. It can track COVID-19 vaccines — indeed, any vaccine — in any supply chain, monitor inventory, and facilitate safe, timely delivery to any location. We designed AIM to be fast, flexible, and compliant in any country. At a time when the world is depending on supply chains to function at peak performance, AIM is a tool to help get vaccines properly delivered and dispensed.

Furthermore, our signature rfxcel Traceability System has proven itself in the pharma supply chain, helping ensure products are safe and legitimate and that consumers know exactly what they’re getting. Contact us today to learn more our solutions and how we can help you secure your supply chain, no matter what industry you’re in or where you do business.

Russia Pharma Serialization Update: “Notification Mode” Expedites Product Circulation

Russia pharma serialization has been underway for a little more than three years. The country’s National Track and Trace Digital System, which is known as Chestny ZNAK and covers a dozen industries, has been continually tweaked and refined since it was created a little more than three years ago.

Some important updates to Russia pharma serialization were made public toward the end of 2020. Here’s a quick rundown of what the government announced.

“Notification mode” will simplify Russia pharma serialization processes

As we noted last year, Russia’s Drug Circulation Monitoring System (MDLP) was compelled to develop new reporting requirements after technical problems created serious issues in the pharma supply chain.

In late October, the MDLP moved into so-called “notification mode” to help supply chain actors continue importing, distributing, and selling medicines in the event of errors or failures in Chestny ZNAK’s reporting system. This applied to over-the-counter and prescription medicines manufactured in Russia or imported into the country, including from the Eurasian Economic Union (EAEU).

Then, in early November, Decree 1779, “On Amendments to the Regulation on the Monitoring System for the Movement of Medicines for Medical Use,” consolidated measures to simplify and expedite reporting. This is why notification mode has also been referred to as “simplification mode” for Russia pharma serialization.

In essence, stakeholders can proceed with distribution or dispensing 15 minutes after they submit the required product information to the Government Information System for Marking (GIS MT), which catalogs all marked goods, even if they do not receive confirmation that the information has been accepted/approved in the system. (The “product information” pertains to Russia pharma serialization requirements, such as serial numbers and Global Trade Item Numbers.) The decree also simplifies importation, giving custom officials a 2-hour window to request product information.

For now, these Russia pharma serialization rules are to remain in effect until July 1, 2021. After that, notification mode will stop.

Final thoughts

As the leader in Russia pharma serialization, rfxcel knows the regulations are stringent and challenging. To help, we offer useful resources online, like this refresher course and white papers and webinars that explain the regulations in easy-to-understand language.

These are great places to start, but the best way to ensure you’re prepared to comply with Russia pharma serialization laws is to talk with us directly. Consider our credentials:

  • We’re an official integration, software, and tested solution partner with the CRPT.
  • We’ve demonstrated that our solutions, including our signature rfxcel Traceability System (rTS) and Compliance Management (rCM), can meet the stringent Russia pharma serialization requirements and ensure you stay compliant.
  • rTS works seamlessly with Chestny ZNAK, including a Russian-language user interface that makes integration and startup much quicker.
  • We’ve prepared for Russia pharma serialization and Chestny ZNAK since 2018.
  • We’re one of the few providers with active pharma implementations in Russia.
  • We’ve tripled our workforce in Russia over the last year. Our team in Moscow provides our clients, which include major global pharmaceutical and consumer goods companies, the quickest time to market while fully automating their compliance reporting.

Contact us today learn more about how we can help you with Russia pharma serialization and Chestny ZNAK compliance. No matter how far along you are in your preparations to comply, you should talk to us — even if you’re already working with another provider. Our powerful software ensures you’ll be prepared and always be compliant with Russia’s complex regulations.

rfxcel Welcomes Lincoln Manning as Chief Revenue Officer

Reno, Nevada, Sept. 17, 2020. rfxcel, the global leader in digital supply chain traceability solutions, today announced that Lincoln Manning has joined its executive team as chief revenue officer. Mr. Manning will be responsible for all aspects of revenue generation, including worldwide sales, ecosystem partnerships, sales operations, and systems engineering for the company’s verticals, which include the life sciences (pharmaceuticals and medical devices), food and beverage, government, and consumer goods.

“We are glad to have Lincoln on our team,” said rfxcel CEO and Co-Founder Glenn Abood. “He brings a wealth of experience from diverse industries that he’ll be able to leverage across rfxcel. We are particularly excited about his devotion to and excellence in anticipating what customers need and doing what it takes to ensure they succeed. This is one of our corporate values.

“Lincoln also has a track record of building and strengthening sales teams. Our sales teams are solid in every market, but Lincoln will take them to the next level, helping us maintain our leadership where we’re already established and build our presence where we’re still growing.”

Prior to joining rfxcel, Mr. Manning held executive-level positions at software and digital marketing companies. He led sales, marketing, and customer success teams to increase revenue, reinvent business ecosystems, navigate post-merger corporate change, and reset reseller channels.

“There couldn’t be a more perfect time to be joining rfxcel,” Mr. Manning said. “Our mission of keeping the supply chain safe in key verticals is more important today than ever. I believe rfxcel is uniquely positioned globally to ensure products are safely delivered to patients and consumers, because of our agility and ability to respond to customer needs in today’s ever-changing environment.”

Mr. Abood co-founded rfxcel with Chief Strategy Officer Jack Tarkoff in 2003, so Mr. Manning joins the company as it celebrates 17 years of supply chain innovations and growth. Recent successes include conducting major pharma pilots for the U.S. Food and Drug Administration and the Brazilian government; tripling the size of its team in Russia and being named an official software and integration partner of the Center for Research in Perspective Technologies (CRPT), which operates Russia’s National Track and Trace Digital System (Chestny ZNAK); releasing the latest version of its award-winning rfxcel Traceability Solution; increasing its presence in the Middle East; and being named 2020 Software Company of the Year by Nevada’s Center for Entrepreneurship and Technology (NCET).

“Lincoln’s joining us at a busy time,” Abood said. “We’re keeping our customers’ supply chains running during the pandemic, improving our products and developing new solutions, and expanding our operations globally. Lincoln will be a huge asset as we continue to secure and optimize the pharma, food and beverage, government, and consumer goods supply chains. By strengthening our commitment to our customers, he’ll strengthen rfxcel. We’re all excited to have him on the team.”

For more information about rfxcel’s solutions, contact Herb Wong, vice president of marketing and strategic initiatives, at or 925-824-0300.


About rfxcel

Founded in 2003, rfxcel provides leading-edge software solutions to help companies build and manage every aspect of a digital supply chain, lower costs, and protect their products and brand reputations. Blue-chip organizations in the life sciences (pharmaceuticals and medical devices), food and beverage, worldwide government, and consumer goods industries trust rfxcel’s signature Traceability System (rTS) to power end-to-end supply chain solutions in key areas such as track and trace, environmental monitoring, regulatory compliance, serialization, and visibility. The company is headquartered in the United States and has offices in the United Kingdom, the EU, Latin America, Russia, India, Japan, the Middle East, and the Asia-Pacific region.

The L1-L5 Solution Providers, Explained

Jargon. For better or for worse, it’s a fact of life — more so for people like us who work in the highly technical field of supply chain management. From ANSI to XML, an alphabet soup of shop talk can rain down upon us without warning, often leaving us scratching our heads (or at least searching online). L1-L5 solution provider? What does that mean?

And if we say rfxcel is an L4 and L5 solution provider, what does that mean? With as little jargon as possible, let’s find out. (Hint: It has nothing to do with alleviating back pain.)

What does the “L” stand for in L1-L5 solution provider?

The “L” in “L1-L5 solution provider” stands for “level,” as in the level of serialization in a supply chain. To put a finer point on it, it means the level of serialization and information management in a supply chain. And if you hadn’t guessed, there are five levels:

  • Level 1: Device
  • Level 2: Packaging
  • Level 3: Site
  • Level 4: Enterprise
  • Level 5: Network

The list above progresses from the smallest or most localized level, the L1 device level, to the most expansive and all-encompassing level, the L5 network level. Generally, L1, L2, and L3 are grouped together because they’re happening where products are created and packaged; L4 and L5 are paired together in the realm where those products enter the greater supply chain to make their way to their final destinations.

When talking about L1-L5, let’s work backwards from largest to smallest. This way, we can “zoom in on” the details and put everything in a more vivid context.

Level 5: Network

L5 is where rfxcel has its roots and where we built our reputation for supply chain excellence. The network level is where all serialization and regulatory data is managed, including with your trading partners, regulatory authorities and their repositories, and customers. It ensures you’re communicating with partners and complying with regulations.

Level 4: Enterprise

rfxcel’s roots also run deep in L4, which manages and verifies all your serialization and regulatory data/compliance reporting before sending it to L5. It also generates your serial numbers and manages all your business processes. When you design your solutions for L1, L2, and L3, you must decide how they will integrate with your L4 solution.

Level 3: Site

This is where we enter your actual manufacturing facilities and processes. L3 manages the line systems (i.e., L2) at your site to ensure that they are working optimally. L3 is optional; if present, it serves as the “middle man” between L4 and L2, requesting serial numbers from the former and allocating them to the latter.  L3 will also verify the L2 data before it is submitted to L4.

Level 2: Packaging

L2 systems control the L1 hardware and manage the serial numbers which are printed and applied on packages by L1 devices. L2 systems will communicate with the L4 (or L3,f present) to send/receive serial numbers as needed.

Level 1: Device

L1 comprises devices on a packaging line that enable serial numbers to be affixed to packaging and products, such as barcode printers, label printers, and labelers. It also includes cameras and scanners used for quality control, such as visual inspections of products and labeling.

rfxcel is an L4 and L5 solution provider that integrates with L2 and L3

As we said above, we’ve built a reputation for excellence for L4 and L5, the enterprise and network levels. This is our business: Creating innovative software solutions that optimize key supply chain requirements and functions — from the nuts and bolts of serialization and regulatory compliance to environmental monitoring and data analytics — and bring true end-to-end track and trace capabilities to any supply chain.

Our solutions ensure you’re communicating with all your trading partners, all regulatory bodies and their repositories, and your customers. We’ll help keep your lines running smoothly. We’ll yield rich, actionable data that you can use to improve your operations, connect with your customers, and build consumer trust and brand reputation.

We create one uniform, harmonized supply chain that takes care of everything from unit-level serialization and global compliance network needs to closing the last mile all the way to the person buying your product.

Final thoughts

All levels are important. They rely on one another to make things work. When you’re planning a serialization solution, you have to think very carefully about how they’ll interact and communicate.

rfxcel makes sure your data is accurate, travels quickly between and among levels, and meets the requirements of your partners and government authorities — no matter what systems you have in place now or will get in the future. Interconnectivity and interoperability are the cornerstones of all our implementations.

If you have questions about L1-L5, are looking to build a solution, or are considering switching solution providers, contact us today to talk with one of our supply chain experts and see what our award-winning rfxcel Traceability System can do.

DSCSA Saleable Returns Verification Requirement: Just the Facts

Note: On October 23, 2020, the FDA delayed enforcement of the DSCSA for dispensers and wholesale distributors. Read the details here.

The Drug Supply Chain Security Act (DSCSA) is transforming every aspect of the U.S. pharmaceutical supply chain. The law has many parts, but today we’re focusing on the DSCSA saleable returns verification requirement, one of its key mandates. Let’s jump right in.

First, what is the DSCSA?

The DSCSA went into effect on November 27, 2013. It is actually Title II of the Drug Quality and Security Act (DQSA) and calls for product tracing, product identifiers (PIs), authorized trading partners, and verification requirements for manufacturers, wholesale distributors, repackagers, and dispensers (pharmacies).

The goal of the DSCSA is to facilitate product tracing in the pharmaceutical supply chain and, ultimately, promote patient and consumer safety and ensure the authenticity of products. Non-compliance is “prohibited … and subject to enforcement action under the [Federal Food, Drug, and Cosmetic Act].” In a nutshell, if you’re out of compliance, you’re out of business.

What is the DSCSA saleable returns verification requirement?

Millions of pharmaceutical products are returned for resale every year in the United States. These are known as “saleable returns.” Under the DSCSA saleable returns verification requirement, wholesalers must verify saleable returns before they can be reintroduced to the supply chain. In other words, every returned drug has to be vetted — declared as safe and legitimate — before it can be sold again. This is accomplished by verifying the drug’s PI, which has four components: a Global Trade Item Number (GTIN), a unique serial number, a lot ID, and an expiration date.

The DSCSA saleable returns verification requirement for distributors was originally scheduled to take effect on November 27, 2019; however, as we discussed in a previous blog post, the FDA in late September 2019 announced that it did “not intend to take action against” wholesalers that did not meet the requirement before November 27, 2020. This 1-year postponement gave pharma supply chain stakeholders more time to prepare to comply.

Of course, November 27, 2020, is only a few months away. Are you going to be ready? More on that below.

How does the DSCSA saleable returns requirement work?

The easiest way to understand the DSCSA saleable returns requirement is to think of the U.S. pharma supply chain as having only two members: wholesalers and manufacturers. And the law requires them to talk with one another about returned drugs. Here’s what we mean.

To meet the DSCSA saleable returns verification requirement, a wholesaler must initiate a verification request (to a manufacturer) to verify the returned products before it can resell them. The manufacturer that receives that request must provide a verification response within 24 hours. This is why wholesalers are called requestors and manufacturers are called responders.

The 24-hour deadline, however, doesn’t meet business realities. Why? Because, as we mentioned above, millions and millions of drugs are returned every year. The volume is just too great. Therefore, wholesalers need manufacturers to provide verification responses almost instantaneously — at the sub-second level, not in a few minutes, let alone an entire day.

Enter the Verification Router Service (VRS).

The VRS and the DSCSA saleable returns verification requirement

VRS is a huge topic, and to get into the details is outside the scope of what we’re talking about today. Put simply, the VRS enables the rapid, secure exchange of data between requestors and responders to meet the DSCSA saleable returns verification requirement.

The Healthcare Distribution Alliance (HDA) is the driving force behind the VRS, which facilitates the “talk” between wholesalers (requestors) and manufacturers (responders) to verify every drug. Here, a third member joins the DSCSA saleable returns “family”: A solution provider that enables the verification requests to be routed between wholesalers and manufacturers.

The VRS is an automated service that verifies if a PI is valid. There are multiple VRS providers, and each is responsible for determining if a specific group of PIs is valid. A wholesaler can call any VRS provider to verify if a PI is valid. If a provider does not manage that particular PI, it will automatically route the verification request to the appropriate provider. All of this happens in real time, and the VRS ensures that information is accurate and up to date.

Final thoughts

rfxcel is the industry thought leader in the DSCSA saleable returns verification requirement and the VRS. Not only did we extend testing of VRS, we implemented a VRS pilot program for the Food and Drug Administration. We’re applying our expertise in supply chain track and trace, serialization, and compliance solutions to help the pharma industry prepare for November.

And we can help you too. Contact us today to talk with one of our supply chain experts and see how our award-winning rfxcel Traceability System can ensure you comply with the DSCSA saleable returns verification requirement — and meet all your other supply chain needs.


India Pharma News: FDA Recalls, COVID-19 Vaccine & Ideas Summit 2020

The last time we checked in on the India pharma supply chain, the country had announced restrictions on the export of active pharmaceutical ingredients and medicines, launched its national iVEDA portal for drug authentication and track and trace, and changed a deadline for regulations concerning drug exports.

There have been some India pharma headlines in the last week or two, so let’s do a summer roundup.

FDA Recall of India Pharma Products

The U.S. Food and Drug Administration (FDA) and the Indian government work together on pharma supply chain issues. From January 28–30, 2020, for example, a joint action called Operation Broadsword prevented approximately 500 shipments of illegal and unapproved prescription drugs and medical devices from reaching U.S. consumers.

Now, two Indian pharma companies are voluntarily recalling lots of Metformin Hydrochloride Extended-Release Tablets because FDA analysis revealed they could contain nitrosodimethylamine (NDMA), a known carcinogen, above the acceptable limit. The recall affects both 500mg and 1000mg tablets. Metformin is commonly used to treat type 2 diabetes. A complete list of all metformin products being recalled is available on the FDA website.

There are two other FDA recalls affecting Indian pharma companies. About 1,500 bottles of Clozapine are being recalled after 50mg tablets were found in bottles of 100mg tablets, and one lot of Aripiprazole tablets are being recalled because bottles labeled as containing 30 2mg tablets actually contain 100 5mg tablets. Clozapine is used to treat mood/mental disorders and Aripiprazole is used to treat schizophrenia and bipolar disorder.

India pharma company anticipates COVID-19 vaccine early next year

The chairman of Ahmedabad-based Zydus Cadila says he expects phase 1 and phase 2 studies of its novel coronavirus vaccine to be completed in three months. It is currently testing the vaccine, ZyCoV-D, for safety and efficacy. It will be compared with placebo.

As reported in the Hindu Times, Chairman Pankaj Patel said the vaccine could be ready in “about seven or a little more than seven months … provided the data is encouraging and the vaccine is proven to be effective during the trials.” He said Cadila might be able to produce up to 100 million doses a year.

Zydus Cadila is also planning to produce remdesivir, which is being used worldwide to treat COVID-19. Patel the company could produce up to 400,000 doses of the medicine in the first month after it wins regulatory approval to manufacture it in India.

India Ideas Summit 2020

The United States India Business Council (USIBC) is holding its 45th annual meeting next week. Together with the U.S. Chamber of Commerce, it will host the Ideas Summit, also an annual event, from July 21-22. It will be a virtual gathering, naturally.

This year’s theme is “Building a Better Future.” Looking to a “post-COVID world,” diplomats, scholars, senior business executives, think tanks, and other thought leaders will discuss topics ranging from geopolitics and equitable growth to the future of healthcare and digitization and technology trends.

They will also focus on global supply chains. This month, the USIBC released a white paper entitled “Positioning India to Capture Global Supply Chains & Grow Economic Opportunity.” The 22-page paper is of interest to anyone who follows supply chains and recognizes India’s position in global markets. It touches on the work of the USIBC Task Force on Supply Chain Standards and Practices and how the country is working to attract new supply chains. Read the white paper here.

Final thoughts

India will undoubtedly continue to cultivate its position in the global pharmaceutical industry. It’s actively modernizing its supply chain. For example, in April it replaced its Drugs Authentication and Verification Application (DAVA) with the Integrated Validation of Exports of Drugs from India and its Authentication (iVEDA) portal.

We’ve worked in the India pharma market for many years and understand its complexities, challenges, and benefits. Our signature rfxcel Traceability System (rTS) and rfxcel Compliance Management (rCM) solution have helped our customers keep up with India’s regulations and remain competitive.

Contact us today to see how we can maximize your impact in India.

rfxcel Continues Winning Streak in Russian Serialization, Track and Trace

Once again, Russia’s Center for Research in Perspective Technologies (CRPT) has named rfxcel an official partner, this time for software and integration for dairy, bottled water, footwear, wheelchairs, tires, perfumes, bicycles, and light industry. We’re pretty excited about this. We had already been named an official software, integration, and tested solutions partner for medications. Our team in Moscow has worked hard to make us the leader in Russian serialization and track and trace for all industries; you should contact them if you have any questions about doing business in Russia.

The CRPT is a public-private partnership that manages Russia’s National Track and Trace Digital System, known as Chestny ZNAK. Our rfxcel Traceability System (rTS) works seamlessly with the system, including a Russian-language user interface that makes integration and startup much quicker.

Let’s take a quick look at what’s going on with the dairy and bottled water industries in Russia, and why we’re leading in Russian serialization and track and trace.

The CRPT and Russian Serialization/ChestnyZNAK “Experiments”

The CRPT follows best practices by conducting “experiments” — what we would call pilots — for products before the officially enter the ChestnyZNAK system. The pilot for dairy ran from July 15, 2019, to February 29, 2020; for bottled water, the pilot began April 1, 2030, and is scheduled to end March 1, 2021.

A pilot for bicycles wrapped at the end of May 2020, and a current one for wheelchairs is  expected to end June 1, 2021. Pilots for children’s goods (e.g., baby food, clothing, toys, and games) and medical devices will apparently be announced soon.

Requirements for Dairy and Bottled Water

Russia’s supply chain regulations are notoriously strict. This is one reason being named an official CRPT partner is a feather in our cap: We’ve demonstrated that our solutions, particularly our signature rfxcel Traceability System (rTS) and Compliance Management (rCM), can meet the requirements and ensure companies stay compliant.

We’re currently working on some other materials about the regulations for dairy and bottled water (and tires and other products), so check back soon to see those. In the meantime, however, here’s some basic information to tide you over.


All products must be labeled with a DataMatrix code. The code must contain the following:

  • The goods code (14 numerical digits)
  • An individual serial number (13 digits) generated by the CRPT or a company’s economic agent
  • A verification key provided by the CRPT (4 digits)

According to the language in the regulations, companies may include an expiration date (6 characters for non-perishables, 10 for perishables), but that is not mandatory.

Product packaging mush have a 15×15 mm space for the codes. If a product has a cap, such milk in a PET bottle, the material and surface texture must be able to accommodate printing (e.g., ink or laser).

Bottled water

The regulations recognize six categories of bottled water. In addition to three unexplained “other” categories, these include:

  • Waters, including natural or artificial mineral, carbonated, free from sugar or other sweetening or flavoring substances. (The regulations also mention “ice and snow” under this category.)
  • Mineral and carbonated waters, including natural mineral waters:
  • Non-carbonated waters

The DataMatrix code must contain the same information as the codes for dairy. And like dairy, companies have the option to include other information, such as an expiration date or a minimum retail price.

Final thoughts

Our success with the CRPT is due to a lot of hard work and our commitment to designing the best solutions for Russian serialization, track and trace, aggregation, and compliance.

When Chestny ZNAK was enacted into law on December 29, 2017, we began honing our operations in Russia. About this time last year, we reported that we had doubled the size of our team in Russia; since then, it’s tripled in size. We’re one of very few supply chain solution providers with active implementations in Russia, and we’re working with more and more companies as our reputation grows.

Our continued success with the CRPT, ChestnyZNAK, and Russian serialization boils down to the quality of our solutions and the knowledge and skill of our people, who have expertise in key areas of supply chain management and technology. They all speak Russian, of course, and they know the regulations inside and out. They understand how to meet our customers’ needs while ensuring they’re fully compliant with Russian serialization, aggregation, and supply chain compliance requirements.

Contact us today learn more about how rfxcel can help you with Russian serialization and the ChestnyZNAK regulations. And be sure to ask about our other track and trace and compliance solutions. Sure, we’re the leader in Russian serialization, aggregation, track and trace, and supply chain compliance solutions, but we can optimize any supply chain anywhere in the world. Ask us how!