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HDMA Statement on Federal Pharmaceutical Traceability Legislation

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Pedigree

The definition of a “pedigree” varies state by state. Under the Prescription Drug Marketing Act (PDMA), the law that established the standards for prescription drug distributor licenses, those distributors who are not authorized by the manufacturer to handle and sell their products must pass on an “identifying statement” to those who are the purchasers.

That statement identifies each prior sale, purchase or trade of the prescription drug. It is important to know that although the identifying statement and pedigree have become synonymous, the federal guidance and regulations implementing the official PDMA never use the word “pedigree.”

Each state is required to follow PDMA as a “baseline,” but can enact additional regulation or legislation as it sees fit. Some states have legally listed specific requirements for “pedigree,” but current definitions and the documentation required in order to meet the pedigree compliance standards are not uniform.

Some states have outlined specific paper-based requirements, while other states plan to implement electronic track-and-trace solutions that can further address security issues with modern technology.

HDMA is committed to achieving uniform pedigree requirements across the country that promote a safe and secure supply chain while maintaining effective and efficient distribution of prescription drugs.


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Issue Contact: Liz Gallenagh (Government Affairs), Anita Ducca (Federal Regulatory Affairs), Kristen Freitas (Federal Affairs), Dan Bellingham (State Affairs), Perry Fri (Industry Relations), John Howells (Industry Relations)

 
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