Department of Regulatory Affairs, K.B. Institute of Pharmaceutical Education and Research, Gandhinagar.
The pharmaceutical supply chain plays a critical role in ensuring the safe and efficient distribution of medications. However, challenges such as demand variability, logistical complexities, regulatory compliance, and counterfeit drugs threaten its stability. This study explores regulatory frameworks, distribution channels, emerging challenges, and the transformative role of technology in enhancing supply chain resilience. Regulations like DSCSA, EU FMD, GDP, and WHO guidelines safeguard product integrity through strict documentation, serialization, and tracking. Despite these measures, disruptions from supply shortages, pandemics, geopolitical tensions, and cold chain vulnerabilities persist. To address these issues, pharmaceutical firms adopt multisourcing strategies, flexible logistics, and digital monitoring. Distribution networks range from direct manufacturer-to-pharmacy models to complex multi-tier systems, including e-commerce and direct-to-patient delivery, which improve access but introduce regulatory challenges.
A supply chain is a collection of enterprises that collaborate to procure raw materials, process them into semifinished and finished products, and then deliver them to the end users. Effective process management, from the design of a product or service to its sale, use, and eventual disposal by the consumer, is referred to as "supply chain management." This process includes product design, purchasing, planning and forecasting, production, filling, distribution, and post-purchase assistance (Fig. 1). Supply chain management (SCM) problems can be generally classified into coordination-level and configuration-level problems. Coordination-level problems are concerned with tactical choices and day-to-day operations, whereas configuration-level problems are concerned with the overall structure and infrastructure of the supply chain. With businesses experiencing high competition, decreasing product life cycles, changing consumer tastes, and rising production and distribution expenses, the significance of effective SCM has increased tremendously. Businesses depend on SCM to maximize customer value, speed up innovation, optimize the use of resources, minimize costs, and maximize profitability. Supply chain networks have revolutionized classical linear models into fluid systems of high interdependence and cooperation. Supply chain networks enable the movement of materials, information, and finances between entities, consisting of five primary elements: demand segments, ship assets, internal logistics (production), outbound logistics (distributors), and inbound logistics (suppliers). In the drugs sector, supply chain is exceptionally complex owing to regulatory limitations as well as the essential nature of healthcare products. A normal medicines supply chain ranges from raw material production, pharmaceutical manufacturing, storage warehouses, pharmacy or hospital distribution, and terminal patients. There has been a shift in economy that has motivated drug manufacturers to alter their supply chains in terms of making it efficient, complying, and responsive. The complexity of supply chains is due to interconnected components with non-linear behaviors, which are difficult to model through conventional static methods. Static models do not consider actual phenomena like demand variations, delays, and oscillations. To overcome these issues, System Dynamics (SD) has been a successful modeling technique that helps to better understand interdependencies and enhance forecasting and decision-making in supply chain management.
Figure 1. Supply Chain Process
Customer orientation in supply chain management emphasizes three competencies: supply chain (SC) dependability, responsiveness, and flexibility. SC dependability guarantees that the correct product, in the correct amount, with the correct packaging and documentation, is received by the correct customer at the correct time and place. SC responsiveness is the rate at which the supply chain can respond to consumer needs, whereas SC flexibility enables companies to change from one product to another or increase or decrease production in a smooth manner due to changes in demand. This lessens the chances of stockouts and reduces the necessity for storage of excess inventory. Time-based competition has emerged as a leading strategy for retaining competitiveness. In order to accommodate consumer needs in a timely manner, the supply chain needs to reduce the time spent on product development, production, promotion, and distribution. Responsiveness, or agility, is important for dependability as it allows the supply chain to respond to market changes and consumer demands quickly and efficiently. In the pharmaceutical sector, agility is especially important because of reasons like declining product life cycles, increasing mergers and acquisitions, changing consumer behavior, and competitive forces that require quick reactions. The internal view of supply chain management emphasizes cost-effectiveness and asset management. Effective SC management minimizes production, transportation, and inventory expenses and enhances customer service. Operating costs, such as planning, sourcing, manufacturing, delivery, returns, labor, and overhead, affect overall productivity and profitability. Cost-reduction measures enhance partnerships, reduce product costs, minimize lead times and inventories, enhance forecasting, and facilitate just-in-time delivery, drastically minimizing indirect costs. The most critical metrics for SC asset management are cash-to-cash cycle time, return on SC fixed assets, and return on working capital. Cash-to-cash cycle time is the time it takes from purchasing materials until cash is realized from sales, which allocates the financials required for operations.
1.2 History of Supply Chain Management (Implementation of Good Distribution Practice Guideline)
Figure 2: Flowchart of History of Supply Chain Management
What Makes Pharmaceuticals Supply Chain Management unique?
Wang states that "the main goal of SCM in pharmaceutical is to supply the right product, to the right customer, in the right quantity, at the right time." The pharmaceutical supply chain involves planning, execution, and oversight of material and information flow from raw material procurement to final product delivery. Key players, including manufacturers, suppliers, warehouses, carriers, distribution hubs, and retailers, work together to ensure timely and accurate delivery of medical supplies. Over the past decade, evolving business models and increasing expectations for comprehensive diagnosis and treatment have added complexity to pharmaceutical supply chains. The shift toward outcome-based models highlights the importance of efficient supply chain management in delivering products precisely when and where needed. Effective SCM enables healthcare organizations to adapt to changing demands while maintaining quality and reliability.
Table 1: Differences Between Normal Supply chain and Pharmaceutical Supply chain
Aspects
|
Normal Supply chain management |
Pharmaceutical Supply chain management |
Core Objective
|
Focuses on efficiency, cost reduction, and timely delivery of goods.
|
Ensures product safety, efficacy, timely availability, and compliance with health regulations |
Product Sensitivity
|
Products are generally less sensitive to environmental conditions.
|
Pharmaceuticals are highly sensitive to temperature, humidity, and light, requiring strict handling and storage (e.g., cold chain for vaccines). |
Regulatory Compliance
|
Operates under fewer regulatory restrictions. |
Strictly regulated by agencies like FDA, EMA, and WHO to ensure product safety and quality.
|
Product Lifespan
|
Products typically have longer lifespans and fewer constraints.
|
Many pharmaceuticals have short shelf lives and require stringent expiration date management. |
Product Recall
|
Less critical; recalls often involve replacement of goods.
|
Recalls can have severe consequences, including patient harm, legal penalties, and reputational damage. |
Inventory Management
|
Can tolerate overstock or slight shortages without major issues.
|
Overstock leads to waste due to expiration; shortages can have life-threatening consequences. |
Storage and Handling
|
Standard storage conditions for most products.
|
Requires specialized storage facilities, including temperature and humidity-controlled environments |
Transportation Needs
|
Standard logistics suffice; basic packaging and handling are adequate.
|
Specialized transportation, including cold-chain logistics, is essential for temperature-sensitive products. |
Counterfeit Risk
|
Counterfeiting is less critical in most industries.
|
High risk of counterfeit drugs, requiring serialization, tamper-proof packaging, and tracking systems.
|
Supply chain Complexity
|
Often linear and less complex.
|
Involves multi-layered global networks due to manufacturing, regulations, and distribution challenges. |
Demand Variability
|
Demand is more predictable for consumer goods.
|
Demand is unpredictable, influenced by disease outbreaks, pandemics, and health emergencies. |
Stakeholder Involvement
|
Typically involves standard suppliers, manufacturers, and distributors. |
Includes manufacturers, wholesalers, regulators, hospitals, pharmacies, and healthcare providers. |
Technology Use
|
Technology adoption varies; often focused on basic operational tools.
|
Advanced technologies like blockchain, IoT, and AI are critical for traceability, quality, and optimization. |
Risk Management
|
Risks are usually financial or logistical.
|
Risks include patient safety, compliance failures, and ethical concerns with serious consequences. |
Sustainability Focus
|
Varies by industry; often focused on cost-effective green initiatives.
|
Increasing focus on sustainable practices like eco-friendly packaging and reducing waste. |
1.4 Role of Every Stockholder in The Pharmaceutical Supply Chain Management
The pharmaceutical Supply chain, while not without its imperfections, is a complex and intriguing network. It all begins with researchers and manufacturers who source the necessary materials, then design and test the medications. Once ready, these products are picked up by distributors and sent to pharmacies, where we can purchase them, whether with a prescription or not. This description, however, merely scratches the surface. The entire chain involves even more detailed steps, best understood by examining the roles of the key players involved in the process.
Critical participants in a manufacturing process are also sometimes termed "stakeholders," a term which you may have encountered by now. Critical players in the pharmaceutical Supply chain are:
• Raw material suppliers
• Drug makers
• Regulatory agencies
• Wholesale distributors
• Pharmacy benefit managers
• Pharmacies
• Dispensed to Consumers
1.5 Benefits of Supply Chain Management in Pharmaceutical Industry
The pharmaceutical industry heavily relies on effective Supply chain management to ensure the timely availability of drugs and medical supplies. The key benefits of efficient Supply chain management in this sector include:
1. Increased Efficiency and Cost Savings
2. Improved Product Safety and Quality
3. Efficient Inventory Control
4. Improved Patient Safety and Health
5. Improved Regulatory Adherence
6. Collaborative Partnerships and Alliances
7. Analytics-Driven Decision Making
1.6 Challenges of The Pharmaceutical Supply Chain Management
The pharmaceutical Supply chain is a complicated and rigorously regulated framework that enables the distribution of medications and healthcare products. However, it faces challenges stemming from its complex, global nature and the unique characteristics of its products. A comprehensive examination of these challenges follows:
1. Regulatory Compliance and Complex Documentation
2. Biopharmaceutical Cold Chain Management
3. Traceability and Counterfeiting Concerns
4. Demand Forecasting and Inventory Management
5. Adapting to Market Dynamics
6. Ensuring Timely Delivery
02. Registration Requirement for Finished Formulation
1. Planning
Planning the supply of materials resulting from client demand is known as supply chain planning. It's not as simple as it seems. The supply chain needs to be meticulously organised at every point. Demand planning must come first, followed by sourcing, manufacture, storage, and delivery. One must examine each of these in depth because they are all of utmost importance. We must begin at the customer's end, where the demand originates, just like with everything else in a business.
2. Demand Planning
The foundation of all business activities is market demand. Because it helps businesses to efficiently plan production, acquire raw materials, and store stockpiles, demand prediction is essential. Thus, demand planning serves as the foundation for all other planning tasks. Demand may be accurately predicted by using past company data. Furthermore, advanced technologies like predictive analytics enable businesses to accurately forecast product needs so they can serve the market at different times of the year.
3. Supply Planning
The amount of goods that must be produced can be ascertained when the demand has been established. The next step is to create a supply plan, which is a plan for acquiring raw materials. To ensure a seamless product delivery process, however, more than just raw materials need to be accounted for; packaging, labelling, and other essential components must also be available. Before manufacturing starts, the purchasing team is in charge of making sure that all required supplies and materials are available.
4. Production Planning
Production management is responsible for coordinating the necessary manufacturing of the items and ensuring that they are delivered to clients on time. To meet these dates, they must guarantee that sufficient production capacity is available. Businesses should strictly create goods in accordance with orders received in order to ensure minimal waste. This is made simple by supply chain management, which improves the visibility of all supply chain activities and makes them more effective and customer-responsive.
5. Sales & Operations Planning
The goal of this process is to bring everyone involved in delivering goods to customers into sync. The manufacturing team schedules production based on the sales team's projections of the expected market demand for a specific time period. Businesses can cut waste and overproduction by merging the work of both teams, guaranteeing that consumers receive their orders on schedule and exactly as requested.
Registration Process
List Of Documents
03.Import Process of Pharmaceutical Raw Material
Despite a doubt, sourcing is a crucial supply chain procedure. It involves a lot more than just buying basic ingredients. According to supply chain management, there are many aspects of sourcing that the sourcing manager must carefully consider. The quality of the final product and its level of market acceptance are significantly influenced by the cost and quality of the raw materials. As a result, it's important to understand how specific sourcing is. Additionally, there are a number of external parties and considerations involved in this function. Let's talk about the most crucial sourcing processes.
Figure 5: Sourcing Of Raw Material- Different Methods for The Finding a Supplier
3.1 Pharmaceutical Raw Material Import Process
List Of Documents
1. Form 40- Application for Issue of Registration Certificate for Import of Drugs inti India under the Drugs and Cosmetics Rules 1945
2. TR6 Challan
3. Form-41- Registration Certificate- Registration Certificate to be issued for Import of Drugs into India under Drugs and Cosmetics Rules, 1945
4. Form-10-License to Import Drugs (Excluding those specified in Schedule X) to the Drugs and Cosmetic Rules, 1945
5. Form 10A- License to Import drugs specified in Schedule X to the Drugs and Cosmetic Rules,1945
6. Form-8-Application for License to import drugs (Excluding those specified in Schedule X) to the Drugs and Cosmetic Rules,1945
7. Form 8A-Application for License to Import Drugs specified in Schedule X to the Drugs and Cosmetics Rules,1945
8. Form-9- Form of Undertaking to accompany an application for an Import License
Additional documents required for the import of raw materials, as per CDSCO guidelines, include:
11. Re-registration undertaking
12. Plant Master File
13. Module-03
14. Import-Export Code
15. DMF
16. Vendor qualification Document
17. Drug approval Certificate
Table 2: Fees Structure import procedure of pharmaceutical raw material
04. Import Process of Narcotic & Phychotropic Raw Material
One of India's most significant pieces of legislation pertaining to the guideline of narcotic drugs and psychotropic substances is the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act). The Act's primary goal is to prevent the unlawful trafficking, abuse, and trade of narcotics and psychotropic medications while allowing for their use in research, medicine, and science. The Act divides pharmaceuticals into schedules based on their potential for abuse and therapeutic value, with varying degrees of regulation applied to each group.
Narcotic Drugs:
According to the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), narcotic drugs are defined as substances derived from opium, coca leaf, or other synthetic compounds with properties that induce stupor, insensibility, or altered states of consciousness. These drugs are often used for medicinal purposes, such as pain relief, but their misuse can lead to addiction.
Psychotropic Substances:
Any natural or chemical substance, or its salt, as listed in the Schedule of the NDPS Act, that modifies the central nervous system and brain function and results in changes in perception, mood, consciousness, cognition, or behaviour is considered a psychotropic substance under the Act. Examples include drugs like LSD, benzodiazepines, and amphetamines. As per the Narcotic Drugs And Psychotropic Substances Act, 1985 (NDPS ACT) Every application for a license or for renewal thereof under the proviso to rule 35 or rule 35 or rule 37 shall be in such form and manner as may be specified by the Narcotics Commissioner.
Figure 6: Registration Process for Narcotic and Psychotropic Substances of Raw Material
List Of Documents
1. Form-04-Certificate of Official Approval of Import as per NDPS act, 1985
2. Form-4A- Certificate of Official Approval of Import under the Proviso to Rule 54
3. Form-05- Authorisation for Official Approval of Export- NDPS Act, 1985
Table 3: Fees Structure for the Narcotic drugs and Psychotropic Substances Forms
05. Import Process of Dual Use Substance Raw Material
Dual-use drugs are chemical substances used in medicine but have other uses besides medical use in industries like textile, chemicals, and food industry. Although the drugs are technically pharmaceuticals under the definition, their uses in industry require specific regulatory approvals for compliance with drug control policies in the country.
Regulatory Control by CDSCO
The Central Drugs Standard Control Organization (CDSCO) is India's national drug regulator, functioning under the Drugs and Cosmetics Act, 1940, and its Rules. CDSCO performs drug distribution, importation, and enforcement of compliance on the central government's behalf.
Import Authorization and Approval Process
Importation of dual-use drugs is subject to prior approval, differentiating between their pharmaceutical production and non-medical uses. New drug clearances and licensing are assessed by the Drugs Technical Advisory Board (DTAB) and the Consultative Committee, ensuring compliance with regulations under the Central License Approving Authority. Manufacturers apply for a No Objection Certificate (NOC) for dual-use drugs by submitting the following documents:
The supply chain starts with the supplier of ingredients before moving on to the next actor. The ingredient supplier must provide the NOC for verification. A partnership is formed upon verification of the NOC. Drugs are imprinted with QR codes that are generated specifically for them. Regulators are the next actor in the transformation of the supply chain for these medications. To register with the DAPP, the regulators must scan the QR code. When the QR code is scanned, a new timestamp is added to the blockchain. The medications are validated by scanning the QR code once they arrive at the logistics provider. When the medication is delivered to the patient, it is confirmed with the patient by authenticating the unique code which the end user has inserted. The entire Supply chain is truncated and transaction history is noted in a blockchain if the QR code inserted by the end user is found equal to the QR code provided to the ingredient provider.
1. Ketamine (Primary use for Anaesthetic for surgery or pain management. And dual use for Treatment for severe depression and as a recreational drug (illicit use).
2. Epinephrine (Primary use for Emergency treatment for anaphylaxis and Dual use in cardiac arrest and some asthma attacks).
3. Gabapentin (Primary use for treatment of epilepsy and dual use in neuropathic pain and off-label as an anxiety treatment).
Registration Process
06. Custom Clerance Procedure of Imported Raw Material
The process by which products entering or leaving a nation are inspected and approved by customs officers is known as customs clearance. It guarantees that import and export operations comply with the relevant laws, rules, and tariffs of the country of origin or destination. It comprises examining paperwork, figuring out taxes and duties, and confirming that goods are safe and in accordance with laws. The customs clearance process involves several key individuals and entities, each playing specific roles to ensure smooth operations. Below is a breakdown of the personnel involved and their roles:
1. Importer/Exporter
2. Customs Broker
3. Customs Officer/Inspector
4. Freight Forwarder
5. Logistics Coordinator
6. Warehouse Operator/Port Authority
7. Government Officials from Regulatory Bodies
8. Transporter/Carrier
9. Financial Institution Representative
10. Auditor (post-Clearance)
Figure 7: Steps Involved in Import and Export Procedure
07. Inventory Management
It is a process of purchasing goods and services for an individual, society, organization or group in a systematic and planned way which includes exchange of information, plan and purpose. The procurement has a detailed SOP which is mandatory to be followed and using this technique, one can save cost and time without any dispute between the parties making the transaction. The process of procurement is more transparent and creates healthy competition among all the vendors.
Figure 8: Step by Step procedure for manufacturing of pharmaceutical product
ERP and It’s role in Pharmaceutical Companies
Software called enterprise resource planning (ERP) connects and aggregates data from different pharmaceutical departments, increasing decision visibility and streamlining information integration across all departments. ERP systems combine many components to provide an end-to-end view of production processes, quality control, administrative procedures, and financial administration in pharmaceutical and healthcare organisations, such as medical device and medicine corporations. The majority of pharmaceutical organisations have a fragmented information system made up of specialised, incompatible subsystems. More complexity, inefficiency, and expense result from this fragmented approach. Pharma ERP software solves these problems by providing an integrated platform that includes all relevant data and procedures. ERP software enables pharmaceutical companies to streamline business processes, improve cooperation, and improve patient outcomes by integrating various systems.
Implementing pharma ERP software can bring significant benefits to the pharmaceutical industry. Some of the key advantages brought to pharmaceutical businesses by ERP systems:
1. Efficient Inventory Management
A wide range of commodities are handled by pharmaceutical companies, many of which require careful stock management. ERP software helps maintain optimal inventory levels, reduce waste, and avoid stock-outs or bottlenecks by providing real-time inventory tracking and organisation. It guarantees seamless supply chain operations, makes warehouse administration easier, and permits accurate forecasting.
2. Regulatory Compliance
To ensure the safety and efficacy of its products, the pharmaceutical industry is subject to strict regulations. Pharma manufacturers must follow these rules in order to maintain the reputation of their brands, gain the trust of consumers, and avoid fines and legal problems.
3. Streamlined Manufacturing Processes
Complex procedures including formulation, manufacture, planning, and quality control are involved in the manufacturing of pharmaceuticals. These procedures are made simpler by ERP software, which automates manual tasks and offers precise data collection and analysis. It decreases production delays, minimises errors, and increases operational efficiency for pharmaceutical manufacturing organisations.
4. Enhanced Quality Control
To provide consistent, safe, and effective medications, the pharmaceutical production industry must maintain stringent quality control. Pharma ERP software plays a key role in quality control by collecting and evaluating data at every stage of production. It makes it easier to track expiration dates, manage non-conformances, monitor compliance, and maintain comprehensive records for auditing.
5. Improved Financial Management
Accounting and financial management are crucial for any company that manufactures pharmaceuticals. Pharma ERP software provides accurate and timely financial reports, automates accounting tasks, and aggregates financial data. It eliminates errors and saves time by doing away with the need for human data entry and reconciliation.
6. Optimal Supply chain management
Pharmaceutical companies must manage their supply chains well in order to maintain customer happiness, cut expenses, and deliver goods on time. According to pharmanewsintel.com, "managing all issues effectively requires effective communication, cooperation, and careful inventory and resource management across the Supply chain." ERP software for the pharmaceutical sector provides complete supply chain visibility and control, enabling efficient order fulfilment, inventory control, and procurement.Pharmaceutical manufacturers can improve coordination with suppliers and distributors, expedite procurement processes, and trace and track goods along the supply chain with the use of an ERP system. The technology enhances supply chain performance overall, reduces lead times, and enables better demand forecasting.
There are several types of ERP systems available for pharma manufacturers, each offering unique features and functionalities. The choice of ERP system depends on your organization’s size, complexity and specific requirements.
The three main types of ERP systems in the pharma industry are:
1. On-Premise ERP Systems
The internal IT staff of the company hosts and maintains an on-premise ERP system. Pharma corporations have total control over data and infrastructure with such a system. Large pharmaceutical firms with in-house IT teams and high customisation needs would find it suitable.
2. Cloud-Based ERP Systems
A cloud-based ERP system is hosted and maintained by a third-party vendor. The solution is cost-effective, scalable, and flexible because it eliminates the need for your company to make investments in IT infrastructure or hardware. For small to mid-sized pharmaceutical enterprises that require rapid implementation and easy data access, cloud-based ERP systems are perfect.
3. Hybrid ERP Systems
Both on-premises and cloud-based components are present in a hybrid ERP system. Your pharmaceutical company can gain from both approaches with a hybrid system, which offers flexibility and customisation together with the benefits of cloud-based scalability and cost reductions. Businesses that require both on-premise and cloud-based capability can benefit from hybrid ERP solutions.
Figure 26: Information Flow from Inventory Management to End User
08. Regulations For Warehouse of Pharmaceutical Industry
For pharmaceutical businesses, an effective warehouse plan is essential. Error risk is decreased and operations are streamlined in well-organised warehouses. Product placement, picking routes, and the utilisation of storage devices like shelving and racking systems are all taken into account.
Pharmaceutical warehouses are usually designed with distinct storage sections according to the needs of each product at the time of construction. A typical warehouse will have the following sections, though the precise locations may change based on inventory and its needs:
Additionally, some warehouses may include:
Compliance with regulatory standards is an important pharmaceutical warehouse requirement. Here are some key regulations and guidelines:
09. Regulations For Dispatch of Finished Pharmaceutical Product
To establish a standardized procedure for the safe and efficient dispatch of finished pharmaceutical products, ensuring compliance with Good Distribution Practices (GDP) and maintaining product quality. For the purpose of dispatch of finished pharmaceutical product some documents like Purchase Order (PO), Sales Order, Packing List, Bill of Lading (BOL), Commercial Invoice, Shipping Label, Certificate of Origin, Customs Declaration, Freight Bill, Delivery Receipt, Proof of Delivery (POD), Quality Control Certificate, Hazardous Materials Declaration, Export License, Waybill are required.
Transportation Requirements
Ship pharmaceutical products according to storage conditions on labels to ensure quality. Operators are required to comply with all transport and storage laws. Provide product identification, contamination prevention, and security during transportation. Cold chain is required for temperature-sensitive products. Written agreements are necessary between manufacturers, agents, and shipping companies. Employ suitable transport means (air, road, sea, rail) without sacrificing quality. Track, record, and report deviations during transport. Dangerous, narcotic, and controlled drugs re subject to national and international regulations. Segregate rejected, expired, recalled, or returned products with proper labeling. Vehicles and containers should be clean, dry, pest-free, and hecked for temperature and humidity. Drivers should be certified, and transit documents are required. Put in place cleaning, maintenance, and security measures for vehicles and equipment. Keep records of monitoring information or inspection by the regulators. Prevent tampering and unauthorized access in transit.
10. Export Process of Finished Pharmaceutical Product
Exporting pharmaceutical products from India involves compliance with CDSCO regulations to ensure product quality and safety in international markets. Key export guidelines for Pharmaceuticals include:
Step 1: Understand Regulatory Requirements
Step 2: Market Research & Identifying Export Markets
Step 3: Documentation
Step 4: Manufacturing & Quality Control
Step 5: Packaging & Labeling: Protecting Products and Ensuring Compliance
Step 6: Logistics & Shipping: Getting Products to Market Efficiently
Step 7: Customs Clearance: Navigating Import Regulations
Step 8: Regulatory Compliance & Renewal: Maintaining Market Access
The production of pharmaceuticals for export is authorised by the special code, often known as the neutral code. The code is alphanumeric. Only authorised producers are given the unique code for medications. The manufacturer's name and address are covered by the specific code on the product label and package. As a result, the neutral code enables the drug's maker to distribute their products without disclosing their name and address on the labels. This can be a requirement of an external law. Second, the foreign buyer might not want the target buyers to know the manufacturer's name. As a result, the buyer may give the manufacturer instructions to conceal their information on the medication.
Export NOC
According to the Drug and Cosmetics Act, the Central Authorities handle the approval of new drugs, clinical trials conducted within the nation, the creation of drug standards, the regulation of the quality of imported drugs, the coordination of the activities of State Drug Control Organisations, and the provision of expert advice with the goal of establishing uniformity in the enforcement of the Drugs and Cosmetics Act. The State authorities are primarily responsible for controlling the manufacture, sale, and distribution of drugs. A manufacturer may obtain a No Objection Certificate from the Central Drugs Standard Control Organisation (CDSCO) Zonal/Sub Zonal offices if they have a valid copy of their licence in accordance with Forms 25 and 28. This certificate may only be used for exporting approved or unapproved new drugs or drugs that are prohibited in India. The guidelines are issued by Ministry of Health and Family Welfare for Export purpose and Rule 94 of the Drugs and Cosmetic Act, 1940. The application for Export NOC is filled as per checklist issued by the CDSCO.
The Following documents are required to be submitted in the following manner and order for issue of the No Objection Certificate for export of drugs from India
Special Code/Neutral Code For NOC
When a manufacturer does not want their name and address to appear on the label, they can use either the special code or the neutral code, which are both permitted by the CDSCO. The manufacturer must submit an application and provide the necessary paperwork in order to receive a unique number for the finished formulation or bulk pharmaceuticals for export.
In the application to CDSCO, the regulatory authority's authorised manufacturer assigns a unique code.
Following documents required for the application for grant of permission to the use of Special Code for Export of Finished Formulation/Bulk Drug.
• A properly signed application for an export NOC on business letterhead.
• A legitimate export order that explicitly states the quantity and name of the medication to be shipped on the letterhead of the foreign customer.
• A letter on the foreign buyer's letterhead outlining the precise need for a unique code number.
• A copy of the State Licensing Authority's current manufacturing licence a copy of the product permission for a particular product or the export-related No Objection Certificate that this office has granted for the product prototype packaging materials, such as labels, cartons, leaflets, blister foil, etc., with the code mentioned.
• A valid registration certificate from the importing nation's Ministry of Health must be presented in the event that prohibited pharmaceuticals are exported.
Why should you export drugs with neutral code?
Labelling requirements for medicinal products may vary by country. Therefore, a standardised label design is provided by the neutral code for medicine export. The manufacturers can export to various countries without having to change the product label to meet the labelling requirements of each importing country. Exporting drugs with a neutral code helps to avoid the need for frequent label changes depending on the country of destination. The producer can lower labelling costs by using a uniform and standard label format, which eliminates the need to modify the label to meet the labelling requirements of different nations. For brand strategies or competitive reasons, manufacturers may be reluctant to disclose their identities in specific areas. Manufacturers can safeguard their brand by using the neutral code to conceal their name and address. Incoterms, also known as "International Commercial Terms," are rules and guidelines established by the ICC that specify the obligations of both the buyer and the seller under different logistics agreements in international trade. This not only helps buyers and sellers get rid of their misunderstandings regarding international trade agreements, but it also makes commercial dealings easier. While some of these Incoterms apply to all forms of transportation, some are limited to transportation via internal waterways and the sea. Incoterms outline the conditions of the transfer of ownership and the risk associated with the products being exchanged. As a result, the buyer is responsible for paying for all carriage in the case of EX Works EXW. The buyer is responsible for setting up the main carriage in FCA, FAS, and FOB. The seller is responsible for setting up the main carriage in DAT, DDP, and DAP, and the risk transfer takes place after the main carriage. Lastly, the seller arranges the major carriage in CFR, CIF, CPT, and CIP; nonetheless, the risk transfers before the main carriage.
When inputs are physically incorporated into a product that is meant for export, they can be imported duty-free under the Advance Authorisation Scheme (after usual waste is allowed). Usually, an export promise is the only requirement for granting advance authorisation. With few exceptions, the import of inputs is exempt from Basic Customs Duty, Additional Customs Duty, Education Cess, Anti-dumping Duty, Safeguard Duty, Transition Product-Specific Safeguard Duty, Integrated Tax, and Compensation Cess.
The validity of Advance Authorization
Advance Authorization is valid for 12 months from the date of issue of such Authorization However, the export obligation may be fulfilled within 18 months from the date of issue of Authorization or as notified by the DGFT.
As per the Foreign Trade Policy, "deemed exports" are transactions wherein the supplied goods do not cross the borders of the country and are paid in free foreign exchange or Indian rupees. Deemed Export Scheme includes all types of supply by the manufacturer as well as supply by prime and subcontractor. Certain supplies included are commodities to United Nations or any other international organizations for their official use, supply to EOU, advance approval-based supply of goods, etc. The scheme provides a level platform in certain specified circumstances to local manufacturers. The beneficiary will be entitled to the following advantages with respect to manufacturing and supply of goods under Deemed Exports:
• Advance Authorisation / Advance Authorisation for annual requirement/DFIA
• Deemed Export Drawback for BCD.
• Refund of terminal excise duty for excisable
After examining the average incidence of customs, central excise duties, service tax, and transaction costs borne by the export products, the government has notified the duty drawback plan for the vast majority of export products. Customs and excise taxes paid on inputs or raw materials, as well as service taxes paid on input services utilised in the production of export goods, are to be reimbursed or recovered under the Duty Drawback Scheme. The article describes how to take advantage of India's export duty deduction.
Customs Act, 1962
The Duty Drawback provisions are explained under Section 74 and Section 75 of the Customs Act, 1962. The Act laid down the various restrictions and conditions for claiming drawback of duties in certain cases.Customs Act, 1962
The Duty Drawback provisions are explained under Section 74 and Section 75 of the Customs Act, 1962. This Act prescribed the different restrictions and conditions for availing drawback of duties in specific circumstances.
• The Duty Drawback Scheme's benefit
Table 04: Percentage of Duty Drawback
6. Refund of Duties and Taxes on Exported Products (RoDTEP)
• This scheme has been established with the specific aim of counterbalancing taxes and duties being charged on the export of commodities that are not otherwise credited, remitted or refunded in nature and form, and become adjusted as part of the export items.
• Central, State and local duties/taxes/levies incurred on an export product, including cumulative indirect duty/taxes paid at earlier stage on goods and services used in the manufacture of export goods and other indirect duty/taxes/levies on distribution of exported goods is refunded under the scheme.
• Department of Commerce informs the Scheme and Department of Revenue administers it.
• The Scheme is operative from exports of 1st January 2021. The rate schedule of RoDTEP has been notified and according to the same transferable e-scrips are issued and will be utilized solely for payment of Basic Customs Duty.
REFERENCES
Nishi Patel*, Hitesh Dani, Dr. Maitreyi Zaveri, Zuki Patel, Advancing Pharmaceutical Supply Chain: Rules & Regulations, Strategies for Overcoming Challenges, Int. J. of Pharm. Sci., 2025, Vol 3, Issue 4, 01-25 https://doi.org/10.5281/zenodo.15117523