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Shardul Nautiyal, Mumbai May 19 , 2023
The Federation of Pharmaceutical and Allied Products Merchant Exporters (FPME) has urged the Pharmaceuticals Export Promotion Council of India (Pharmexcil) to do a comprehensive trial run as a confidence building measure with stakeholders before implementing track and trace. 

The main purpose of the track and trace barcode is to provide quality assurance by means of traceability and ensuring patient safety.

“Implementation of track and trace requires adherence to proper guidelines and a comprehensive trial run needs to be given to the manufacturers, merchant exporters, customs officers and the Custom House Agents (CHA) for successful implementation of this mechanism and also for maintenance of data,” informed Sandeep Modi, joint secretary, FPME.

The FPME members are today providing all required information already for traceability and hence would like to elaborate that currently for all export shipments merchant exporters are providing in their export invoices and packing lists details such as name of product, (with composition), quantity, HS code, manufacturing license number, all purchase bills of manufacturers/traders/distributors (with statutory details), batch numbers, manufacturing date, expiry date, exporters FDA license, IEC number, all details of exporter and importer with bank details.

According to a letter from the FPME to the Pharmexcil, “Single export shipment could have over 8 to 9 documents duly certified by exporter. The details of the invoices and packing lists are also uploaded by the exporters /forwarders on ICEGATE along with the digital signature certificate. They also upload supporting documents in electronic format. The shipments with physical samples and documents are duly physically inspected by customs and ADC department. Details are also uploaded on eSanchit for the purpose of GST/ROTDEP/banking FIRC etc.”

An FPME official further informed that all required details are available online to the relevant authorities. The same is also authenticated by the merchant exporter. To the best of our knowledge, maintenance of track and trace by scanning the barcode and uploading the data in the DAVA/iVEDA portal is not being done by the recipient country. They are relying on the details provided by us in human visible format. If for any complaint or feedback there is complete traceability of the shipment readily available at the destination. Track and trace is to be implemented only if mandated by the importing country else it is also a financial burden.

It has also been urged that a dedicated window be linked to the ICEGATE portal where shipment details of products exported by merchant exporters are already uploaded, including products manufactured as well as goods procured from the trade. This will lead to implementation uniformly and maintain data with secrecy and reliability.

“As merchant exporters, the FPME sources its products (allied multiple products) from manufacturers, traders and distributors locally. Many products do not carry barcodes at all levels (tertiary, secondary or primary). It cannot put additional stickers for goods procured locally as it will contravene Drug & Cosmetic (D&C) Act. In view of this, it has been requested to advise a mechanism whereby the track and trace system by way of bar coding is implemented until it is implemented universally,” an official said.

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