Note that industry reports a high degree of uncertainty, with the compliance deadlines in some instances not being enforced. The advice from Excellis to our customers is to ensure that:

1. Any compliance requirement issued is adhered to (for example item-level coding/serialization)
2. Data are retained in the customer’s L4 Repository / EPCIS to allow responding to any queries by authorities or retrospective data upload
3. Where there is some uncertainty around the details of the compliance requirements, follow the Emerging Global Standard on the basis of GS1 coding

In May 2020, the Ministry of Public Health issued a tender to establish a comprehensive National system for tracking and tracing of pharmaceuticals throughout the entire pathway from manufacturer(s) / port of entry to the dispensing of the product to the patient; supporting the sector’s strategic, regulatory, and patient safety objectives. This will presumably align with the published compliance dates, but no further details are known at this time.

• 2025: Primary Pack (batch id)
• 2023: Primary Pack (product code)
• 2021: SSCC on shipments
• September 2019: Roadmap of Product Identification requirements announced, following GS1 standard; suppliers to enter dialogue with HMC and provide information about their compliance readiness preparations.
• 2018: Barcoding requested for certain imports (HMC)