There is no question about the increasing risk of counterfeiting incidents occurring in the global pharmaceutical supply chain.
The manufacture, distribution, and dispensation of medicines are strictly and efficiently controlled in regions such as Europe
and the United States, which may explain the low number of counterfeiting incidents that occur in these regions compared with
other areas of the world. The high confidence of the public in the pharmaceutical supply chain, however, needs to be maintained
and reinforced to keep discouraging patients from purchasing medicines from illegal websites.
Complex supply chains
Awareness campaigns, such as those promoted by the Council of Europe, can assist in this regard. These programs, among other
things, direct consumers seeking online pharmaceuticals to the legitimate supply chain. New complex channels of distribution
and dispensation, however, are developing. These changes, coupled with economic constraints in public healthcare systems are
opening the door to fraud committed by rogue players.
Anticounterfeiting efforts among regulators and business stakeholders have increased in the US and Europe since 2007. During
these past few years, several serious incidents of counterfeiting, contamination, and adulteration have occurred, affecting,
among others, Plavix, Casodex, and Zyprexa in the UK, and heparin worldwide.
A European mass-serialization strategy
The Council of Europe and its European Directorate for the Quality of Medicines & HealthCare (EDQM) have developed a comprehensive
anticounterfeiting strategy that includes several activities, including the training of customs, police and health officers
and the adoption of the Medicrime Convention on counterfeiting of medical products and similar crimes involving threats to
public health. The Medicrime Convention will be opened for signatures this month (October 2011), and will constitute, for
the first time, a binding international legal instrument to combat counterfeiting by criminalizing these activities (1).
As part of this anticounterfeiting strategy, a new EDQM project called eTACT aims to develop a traceability and mass-serialization
system that authorities and stakeholders (i.e., manufacturers, suppliers, distributors, healthcare professionals, patients)
across the global pharmaceutical supply chain can use.
At its current stage of development, eTACT consists of a live demonstration IT system, developed using nonproprietary standards,
with inherent flexibility. The system's repositories will contain data on the pharmaceutical products and items traced (e.g.,
transaction data, such as the commissioning and registration of new items, packing, shipping, and dispensing).
The main standards followed will be those from GS1, the international nonprofit association dedicated to improving the efficiency
and visibility of supply chains. Product identifiers will thus be the GS1 Global Trade Item Numbers (GTINs) and also national
product numbers, such as VNRs in the Nordic countries. Master data (i.e., the product name, marketing authorization holder,
dose strength) will be registered together with these product number(s).
The item data will be formed by combining the product number(s), a nonsequential and unpredictable serial number, the batch
number, and the expiry date of the item. The resulting unique number, a Unique Medicine Identifier (UMI), compliant with GS1
standards, will be placed on the secondary packaging of medicinal products in the form of a 2D Datamatrix barcode. A switch
to RFID tags is possible at a later stage when the technology for this data carrier is sufficiently mature.
Transaction data will be registered by system administrators. What data is recorded, who has access to those data and under
what circumstances (e.g., alerts, or recalls) will be decided upfront by the stakeholders depending on the market destination
of the products, the panEuropean architecture of the system, and the data-sharing option chosen by the manufacturer.
The IT system will be usable along the entire pharmaceutical supply chain to the patient level to prevent entry of the counterfeit
products into the marketplace. The system will allow verification of any individual item or package of a medicinal product
by querying the directory of the repositories.