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序列化不是一刀切的。由于美国、欧盟、亚洲和中东的规定各不相同,公司必须应对复杂的要求网络。您为全球合规做好准备了吗?
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如果你热衷于有所作为并在协作环境中茁壮成长,LspEdia 就是你的不二之选。

Last updated: October 1, 2026
The DSCSA was built around a ten-year phase-in: enacted in 2013 (3), lot-level tracing from 2015, package-level serialization in 2017 and 2018, verification requirements layered on through 2020, and enhanced electronic tracing from 2023. That final phase has run past the original window — the last group comes fully into scope in November 2027.
Date | Milestone |
Nov 27, 2013 | DSCSA signed into law as Title II of the Drug Quality and Security Act |
Jan 1, 2015 | Manufacturers, wholesale distributors, and repackagers must provide transaction information, history, and statements at the lot level |
Jul 1, 2015 | Dispensers must begin receiving and retaining transaction information, history, and statements |
Nov 27, 2017 | Statutory deadline for manufacturers to affix package-level product identifiers — FDA delayed enforcement one year (4) |
Nov 27, 2018 | Manufacturers (under the delayed enforcement policy) and repackagers must affix product identifiers to each package and homogeneous case (4) |
Nov 27, 2019 | Wholesale distributors may only accept serialized product, and must verify product identifiers on saleable returns before redistribution — FDA declined to enforce the saleable-returns piece under a compliance policy later extended to Nov 27, 2024 |
Nov 27, 2020 | Dispensers may only accept product bearing a product identifier, and must verify identifiers when investigating suspect product — also covered by the compliance policy extended to Nov 27, 2024 |
Nov 27, 2023 | Enhanced drug distribution security requirements (electronic, interoperable, package-level tracing) take legal effect (3) |
Nov 27, 2023 – Nov 27, 2024 | FDA stabilization period: enforcement of the enhanced requirements paused industry-wide |
Jun–Oct 2024 | FDA issues the small dispenser exemption (June 12, reissued July 12) and conditional exemptions for other connected trading partners (October 9) (1) |
2025 | Conditional exemptions end: manufacturers and repackagers (May 27), wholesale distributors (Aug 27), dispensers with 26 or more licensed staff (Nov 27) (1) |
Aug 6, 2026 | FDA extends the small dispenser exemption from Nov 27, 2026 to Nov 27, 2027 (2) |
Nov 27, 2027 | Small dispenser exemption ends — every trading partner type fully in scope (2) |
“Licensed staff” means full-time employees licensed as pharmacists or qualified as pharmacy technicians, counted across the corporate entity that owns the dispenser, as of November 27, 2026. (2)
Manufacturers, repackagers, wholesale distributors, and dispensers with 26 or more licensed staff are fully in scope for the enhanced requirements. Qualifying small dispensers are the last group with time remaining, through November 27, 2027. (2) For the specific date that applies to your organization, see the DSCSA deadline breakdown by trading partner type.
After that date, the phased category-wide exemptions are done and DSCSA becomes the ongoing standard of operation rather than an implementation project. Individual trading partners can still request a waiver, exception, or exemption from FDA through the Waivers, Exceptions, and Exemptions (WEER) process, but those are case-by-case and granted on request, not automatic relief by category. (1)
Manufacturers were required to affix package-level product identifiers by November 27, 2017, delayed by FDA enforcement policy to November 27, 2018; repackagers by November 27, 2018. Wholesale distributors could only accept serialized product from November 27, 2019, and dispensers from November 27, 2020. (4)
Nearly. The remaining milestone is the small dispenser exemption ending November 27, 2027, after which every trading partner category is fully in scope for the enhanced requirements. (2)
The enhanced requirements took legal effect in November 2023 and haven’t moved. What changed is FDA’s enforcement posture: a one-year stabilization period, then conditional exemptions staggered by partner type through 2025, then a separate and twice-extended exemption for small dispensers. (1)(2)