Does the UK GTIN product code require 13 or 14 characters?

GTIN product codes require 14 characters.

For more information, please refer to the EMVS Pack Coding Guidelines.

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Does Article 37(d) require that a National Medicine Verification Organisation (NMVO) directly alerts the relevant national competent authorities, the EMA and the Commission about a falsification? Is there is a time limit for such alerting?

The use of the term “provide for” in Article 37(d) of Commission Delegated Regulation (EU) 2016/161 means that an NMVO has to ensure that the National Competent Authorities (NCA), the EMA and the Commission are informed.

Is aggregation permitted, in particular for use of downstream wholesalers?

The Delegated Regulation allows for aggregation but does not stipulate the need for pack aggregation. The EMVS / NMVS system does not support aggregation.

Is it possible for Software Suppliers to register their clients without an agreement for the FMD service?

It is not recommended. It is necessary for the person registering to accept the terms and conditions of the EULA, which could not be justified without an agreement in place.

List of IT Software Suppliers

For those organisations who do not have an IT software provider, or who seek to find companies providing solutions, SecurMed has published the following list of providers.

Useful FMD Links

Please find below links to public sites which provide useful information for the implementation of the Falsified Medicines Directive. MHRA have provided guidance for the implementation and compliance of the Safety Features Regulation: Implementing the Falsified Medicines Directive: Safety Features.

Will manufacturers and wholesalers be able to see data on products I have dispensed?

No. The Delegated Regulation asserts that all parties that are connected to the repositories system, including manufacturers, wholesalers and pharmacies, have sole responsibility, ownership and access to any data that they generate.