Required is a Product Identifier, uniquely identifying packages and homogenous cases with 4 data elements in both machine and human readable format.

Trading partners have different requirements as related to their respective roles in the supply chain.

• November 27, 2023: Fully interoperable, electronic system for tracing including Product Identifiers
• 1-Year Enforcement delay, bring the new enforcement date to November 27th, 2024.
• November 27, 2020: Dispensers cannot accept product without Product Identifiers affixed; Dispensers must verify PI of suspect and illegitimate product.
• 3-Year enforcement delay bringing new enforcement date to November 27th, 2023.Enforcement delay is ONLY for verifying suspect and illegitimate products, not including the requirement for ensuring a product is encoded with a product identifier.
• Additional 1-Year Enforcement delay, bring the new enforcement date to November 27th , 2024.
• November 27, 2019: (saleable returns verification enforcement discretion to 2020) Wholesale distributors cannot accept product without Product Identifiers affixed; wholesale distributors cannot resell returns with verification of Product Identifiers.
• Addition 3-year Enforcement Delay to the Sept 2019 1-Year delay bringing the new enforcement date to November 27th, 2023.
• Additional 1-Year Enforcement delay, bring the new enforcement date to November 27th , 2024.
• November 27, 2018: Repackagers – 4 element Product Identifier required on product entering the supply chain
• November 27, 2017: (enforcement discretion to 2018) Manufacturers – 4 element Product Identifier required on product entering the supply chain
• July 1, 2015: (adding dispensers to January 1 requirement)
• January 1, 2015: (all trading partners except dispensers) Authorized trading partners only; T3 required to be passed with each transaction