System users

Wholesalers

What are my FMD obligations as a wholesaler?

Pharmaceutical wholesalers across Europe are required to verify medicines bearing safety features that pass through their warehouses in specific circumstances as set out in the Commission Delegated Regulation (EU) 2016/161. This is done by scanning the 2D barcode on the pack and verifying the pack via an Internet connection to the Irish Medicines Verification System. Wholesalers are also required to decommission packs in certain circumstances, including when they are being supplied to specific customers as per Article 23 of the Delegated Regulation. 

Getting connected as a wholesaler to the IMVS

There are a number of steps to be completed in order to be able to scan barcodes and check them against the data held in the IMVS:

1. Identify what SKUs are in-scope and all locations within your warehouse(s) where scanning will need to take place;
2. Put in place procedures to flag when stock must be verified and/or decommissioned and to deal with any alerts from the IMVS;
3. Identify what customers you will have to decommission products for under Article 23;
4. Identify what software solution you will use to connect to the IMVS. A list of the IT software providers, whose FMD solutions have been certified by IMVO, is available on the FMD Software Providers section of our website;
5. Source scanner(s) to read barcodes. If you are using externally sourced software, your IT software provider will be able to advise you on models that will work correctly with their solution;
6. Consider what changes are needed to work practices, SOPs, facilities and personnel to support scanning operations and management of alerts;
7. Inform your team about what’s happening and training relevant staff;
8. Get connected to the IMVS – click here for more details.

Alert investigation

When you scan the 2D barcode, an alert will be generated if the data in the barcode or the pack status (‘active’/’decommissioned’) doesn’t match what’s in the IMVS. All Level 5 alerts generated when packs are scanned must be investigated by wholesalers to rule out falsification and IMVO must be informed of the outcome of this investigation.

IMVO may contact you from time to time for additional information about alerts. If you have any queries, please email alert.support@imvo.ie or phone us on +353-1-5715320.

Article 23

Article 23 of the Commission Delegated Regulation (EU) 2016/161 gives Member States flexibility to mandate wholesalers to verify and decommission the unique identifier of all medicines bearing the safety features for certain categories of customers. For Ireland, Medicinal Products (Safety Features on Packaging) Regulations 2019 (S.I. No. 36 of 2019) have defined the relevant customer groups as follows:

1. persons authorised to supply medicinal products to the public who do not operate within a healthcare institution or within a pharmacy;
2. a veterinary practitioner, as defined in section 2(1) of the Veterinary Practice Act 2005 (No. 22 of 2005);
3. retailers of veterinary medicinal products;
4. a registered dentist, as defined in section 2 of the Dentists Act 1985 (No. 9 of 1985);
5. persons registered with the Optical Registration Board under the Health and Social Care Professionals Act 2005 (No. 27 of 2005);
6. paramedics and emergency medical practitioners;
7. the Defence Forces, An Garda Síochána and other governmental institutions maintaining stocks of medicinal products for the purposes of civil protection and disaster control;
8. universities and other higher education establishments using medicinal products for the purposes of research and education, with the exception of healthcare institutions;
9. prisons;
10. schools;
11. hospices;
12. nursing homes.

The Delegated Regulation defines a healthcare institution as ‘a hospital, in- or outpatient clinic or health centre.’ S.I. 36 of 2019 further defines ‘in- or outpatient clinics’ and ‘health centres’ as follows:

• ‘In or out-patient clinic’ means an in or out-patient/day patient clinic under the management or control of a hospital;
• ‘health centre’ means a health centre under the management or control of a hospital.

Designated wholesalers

As per Article 20(b) of the Commission Delegated Regulation (EU) 2016/161, wholesalers are not required to verify packs received from the relevant manufacturer or MAH or a wholesaler designated by the MAH, by means of a written contract, to store and distribute products covered by his MA on his behalf (i.e. ‘Designated Wholesaler’). MAHs (including parallel importers / parallel distributors) are obliged to upload to the EU Hub a list of ‘Designated Wholesalers’ for each product placed on the market. For detailed guidance on Designated Wholesalers, please see Appendix 5 to the EMVO Master Data Guide which is available from EMVO.

Wholesalers who wish to know if they have been assigned ‘designated wholesaler’ status for a given product, can use their FMD software to pull this information from the IMVS in one of two ways, depending on how the software has been programmed:

1. By way of a request for a report relating to that product, specifically, the ‘Contracted Wholesalers Stakeholder Report’ – this will return a report with the relevant details.
2. By way of a query for Product Data for a particular pack (technically a ‘call to ProductDataDownload()’  or a ‘JSON query’) – this generates a response that includes all the information about the product, including the designated wholesaler.

If the wholesaler’s FMD software does not have either type of functionality, then the wholesaler will need to ask the MAH for details of the designated wholesaler for the product in question. If the wholesaler is seeking information about designated wholesalers for a pack that has not been released for Ireland, e.g. an unlicensed pack from the UK, the IMVS cannot return any information on designated wholesalers as this data will not exist in the Irish system.

IMVO webinars for wholesalers

For information on upcoming webinars visit the News and Events page.