
Digital Product Passport for pharmaceuticals
The Digital Product Passport for pharmaceuticals is voluntary, serialisation has been mandatory since 2019. The electronic package leaflet comes next.
Where Transpareo supports you
Medicines need no product passport, because the Ecodesign Regulation excludes them. Their duties come from medicines law, from serialisation to the electronic package leaflet. Transpareo is the DPP platform on which you keep the data around a medicine in one place, behind a code of its own. Each card names the section where the topic continues. To tick things off, use the pharma checklist.
The European verification system checks the unique identifier of every pack. Transpareo leaves that check untouched and places the passport beside it as a code of its own.
The passport needs an identifier that leads to the authorised information. Transpareo builds it from your GTIN as a GS1 Digital Link or issues one of its own.
The summary of product characteristics, the package leaflet and the labelling are authorised word for word. In Transpareo they are fields you take over unchanged from the authorisation.
The new pharmaceutical legislation requires the package leaflet in electronic form too. Keep the text structured in Transpareo today, and you will not capture it again later.
Active substances often come from several countries, each with evidence of its own. In Transpareo every active substance is a component with its manufacturing site and documents.
Manufacturing sites, distribution and temperature records belong to the product. With Transpareo Upstream, contract manufacturers fill in their details themselves, and you review every value.
Patients read the leaflet, professionals the summary of product characteristics, authorities the batch records. In Transpareo you set for every field who may see it.
After a variation you have to show what applied before. Transpareo signs every publication and keeps earlier versions retrievable.
Advertising prescription medicines to the general public is prohibited. Transpareo shows no advertising behind the passport and does not track readers in the browser.
No passport duty for medicines, yet every pack is already unique
No law requires a digital product passport for pharmaceuticals. Yet the industry has marked every single pack for longer than any other. Transpareo is the DPP platform that keeps the data around a medicine in one place and shows it behind a code of its own.
Where the law stands
The Ecodesign Regulation excludes human and veterinary medicines. So for medicines there is no delegated act and no passport deadline. Medicines law governs their duties, today the Union code on medicinal products for human use.
What already applies today
Prescription medicines bear safety features. They consist of a unique identifier and an anti-tampering device. Since 9 February 2019 the Delegated Regulation on safety features has set out the details.
The manufacturer encodes the identifier in a Data Matrix. The marketing authorisation holder makes sure the data sits in the repositories system before release. Pharmacies verify the identifier on supply and decommission it.
Belgium, Greece and Italy had verification systems of their own. They joined on 9 February 2025, when their transitional period ended. Since then the system has covered the whole Union.
The Data Matrix makes every pack unique. A passport gives it a page.
What is still moving
Electronic product information puts the summary of product characteristics, the package leaflet and the labelling into a structured form. Its standard rests on Fast Healthcare Interoperability Resources (FHIR). The EU network adopted it after a pilot from July 2023 to August 2024. Companies submit it voluntarily today.
On 11 December 2025 Parliament and Council agreed on new pharmaceutical legislation. On 28 September 2026 the Council adopted its position. Parliament’s second reading is provisionally planned for 23 November 2026. Then a new Directive and a new Regulation appear in the Official Journal.
The new legislation applies 24 months after its entry into force. The package leaflet then comes on paper and in electronic form. For new applications that applies at once, for existing medicines after five years. Both need implementing acts the Commission still has to adopt. Member states may drop the printed leaflet, provided patients get one free of charge on request.
For access to the electronic leaflet the agreed text draws a clear line. It allows no identification, profiling or tracking of individuals. Advertising is ruled out there as well. Transpareo already shows no advertising behind the passport and does not track readers in the browser. Which platforms may provide the leaflet is for the implementing acts to set.
Until publication in the Official Journal, every date stays an expectation.
What you find on this page
The sections below show the timeline, the roles in the supply chain and the data around a medicine. Then come the pharma checklist as a PDF, the official sources and the questions pharmaceutical companies ask us most often. A click on a term underlined with dots shows what the law says.
From the rules to the passport
The picture shows the rules that concern a medicine in grey. Teal is the data you keep for them anyway. Blue is the Transpareo product passport with its reading tiers for patients, professionals and authorities.
The three biggest hurdles in practice
- Two identifiers with different jobs: the serial number proves a pack is genuine. A passport identifier leads to information about the product. Treating one as the other opens a gap in verification that an audit will find. In Transpareo the passport sits as a code of its own beside the Data Matrix.
- Every text here is authorised: the patient text is authorised word by word, and the text for professionals differs from it. Neither may be rewritten to read better. In Transpareo you take the wording over as a field, and every publication becomes a new, signed version.
- Retention outlives everything: batch documentation, temperature evidence and superseded product information stay in demand long after the last pack expired. That requirement falls on the provider. With Transpareo every earlier version stays retrievable at a permanent address.
More on this: Signatures and certificates in the DPP and Disclosure does not cost you the signature.
Regulatory timeline for pharmaceuticals
The key dates of the rules that apply to pharmaceuticals or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 2 January 2013Falsified Medicines Directive to be transposed
Directive 2011/62/EU amends the Community code on medicinal products for human use. It introduces safety features on the outer packaging, a unique identifier and an anti-tampering device. Tighter rules for wholesale distribution and active substances come with it.
- 9 February 2019Safety features become mandatory
Commission Delegated Regulation (EU) 2016/161 applies. Every prescription pack carries a unique identifier in a Data Matrix code. Pharmacies verify it against the repositories system and decommission it at the moment of supply.
- August 2024EU ePI pilot completed
The pilot run by EMA and national authorities ends after a year, with Denmark, the Netherlands, Spain and Sweden. The report follows in December 2024. The network settles on a common standard based on Fast Healthcare Interoperability Resources (FHIR).
- 9 February 2025Belgium, Greece and Italy join
The additional transitional period for three member states with verification systems of their own ends. Since then the harmonised safety features have applied across the whole Union.
- 11 December 2025Political agreement on the pharmaceutical package
Parliament and Council agree on a new Directive and a new Regulation. They replace Directive 2001/83/EC and Regulation (EC) No 726/2004. Electronic product information is part of the reform.
- 6 March 2026Agreed texts published
The Council publishes the agreed texts of the Directive and the Regulation. Until adoption the wording can still change in legal-linguistic revision.
- September 2026EMA guidance for ePI submission
EMA publishes guidance on submitting electronic product information in the centralised procedure. A draft roadmap has been out since March 2026. Submission stays voluntary, and EMA strongly encourages it.
- 28 September 2026The Council adopts its position
The Council adopts its position at first reading. It matches the political agreement of December 2025. The Commission supports it.
- Expected late 2026Second reading in Parliament
Parliament votes at second reading, provisionally planned for 23 November 2026. Both acts are then published in the Official Journal. They enter into force twenty days later.
- 24 months after entry into forceThe new pharmaceutical legislation applies
The member states apply the new Directive. For new marketing authorisation applications the package leaflet then comes in electronic form too. That requires implementing acts the Commission still has to adopt.
- Five years after entry into forceElectronic leaflet for all
Medicines authorised or applied for before then also get an electronic package leaflet. The marketing authorisation holder may switch earlier. Packs from the time before may be sold until stocks run out.
- No act plannedMedicines stay outside the ESPR
The Ecodesign Regulation excludes human and veterinary medicines. So no ESPR product passport is added for medicines.
Who is affected?
Duties for pharmaceuticals: what falls on each economic operator on the way to the market.
The manufacturer places the unique identifier on the pack. The marketing authorisation holder makes sure the data is uploaded before release. It owns the product information and answers for every change to it. Under the agreed new legislation it also provides the package leaflet electronically.
A manufacturing importer brings the medicine into the EU and carries the same safety-feature duties as a manufacturer in the EU. That includes batch release. Supply contracts with third countries have to deliver the identifier data and the product information in a usable form. With a supplier request in Transpareo, the contract manufacturer fills in its details itself.
It verifies the authenticity of packs in defined risk situations. Where the rules require it, it decommissions identifiers. Its distribution records follow good distribution practice. It keeps no product data of its own, but it has to show where a pack came from and where it went.
They verify the identifier and decommission it at the moment of supply. Hospitals may do so earlier, while the pack is in their possession. Pharmacies are also the first to read electronic product information. So it has to work at the counter, on a phone too.
What belongs in a DPP for pharmaceuticals?
Data fields of a voluntary passport for pharmaceuticals, including data current EU law already asks for.
Every pack carries a unique identifier. It consists of product code, serial number, batch number and expiry date, and a national reimbursement number where one is required. The manufacturer encodes it in a Data Matrix. That code belongs to the verification system, and the passport sits beside it.
This covers active substances with their manufacturing site, origin and specification. Imported active substances need a written confirmation from the authority of the exporting country. So the paperwork behind a single ingredient often spans several jurisdictions.
This covers manufacturing and packaging sites and the distribution records under good distribution practice. Products with a cold chain add temperature records. They belong on the product with a date and a source.
This covers the marketing authorisation number, the summary of product characteristics, the package leaflet and the labelling. This content becomes electronic product information. So it needs a structured form that keeps the authorised wording unchanged.
Downloads
The checklist for pharmaceuticals as a PDF to print and tick off - no account needed.
The checklist for pharmaceuticals lists duties that apply today under existing law. The EU has excluded the industry from the product passport, so no passport act will follow; we update the list when the underlying law changes.
Transpareo for pharmaceuticals
Transpareo is the DPP software for pharmaceutical companies that want the data around a medicine in one place. You create the authorisation number, authorised texts, storage conditions and disposal information as fields of their own. Active substances are components with their own manufacturing site and documents. Certificates, test reports and cold-chain records sit on the product as documents.
Data comes in through the web interface, by Excel import or through the API. Contract manufacturers and suppliers of active substances fill in their details through a supplier request. You review every value before you take it over.
You set for every field who may see it, such as everyone, professionals only or authorities only. Every publication is signed, and earlier versions stay retrievable. Readers check the signature with the Transpareo Time Machine, right in their own browser. Information outside the authorisation, such as disposal, Transpareo translates into 40 languages, and you review the result. You export your data at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for pharmaceuticals
Is a digital product passport mandatory for medicines?
No. The Ecodesign Regulation excludes human and veterinary medicines. No delegated act will cover a medicine. What is mandatory is serialisation, since 9 February 2019. The new pharmaceutical legislation adds the electronic package leaflet. A passport in Transpareo holds both, and everything around them, together. It shows the authorised information behind every pack at a readable size. Every superseded version stays retrievable for the audit.
Is the unique identifier the same thing as a passport identifier?
No. The two have different jobs. The unique identifier is a serial number per pack in a Data Matrix code. Pharmacies verify it against the repositories system and decommission it on supply. It proves that a pack is genuine. A passport identifier leads to information about the product. Both can sit on the same pack. Verification against the repositories system stays mandatory in every case, and Transpareo leaves it untouched.
Does this apply to importers?
Yes. A manufacturing importer that brings a medicine into the EU carries the same safety-feature duties as a manufacturer in the EU. It applies the identifier and makes sure the data is uploaded before release. The hard part is usually the contract. Third-country suppliers have to deliver the identifier data and the product information in structured form. A scanned document does not do that. With a supplier request in Transpareo, the supplier enters its details straight into the fields.
What is ePI, and when does it become mandatory?
Electronic product information is the authorised summary of product characteristics, package leaflet and labelling in structured form. Its common standard rests on Fast Healthcare Interoperability Resources (FHIR). Submission is voluntary today, and EMA encourages it. The new pharmaceutical legislation requires the package leaflet in electronic form too. For new applications that applies 24 months after entry into force, for existing medicines after five years. Both need implementing acts that are still missing. The Council adopted its position on 28 September 2026, and Parliament’s second reading is outstanding. Until the text is in the Official Journal, every date is an expectation.
Do I need a GTIN?
Not as such. The product code in the unique identifier has to identify the medicine. In most member states it rests on a GS1 GTIN or a national equivalent. If your product code rests on a GTIN, Transpareo turns it into a GS1 Digital Link. Without one, Transpareo issues a unique identifier of its own. The QR code leads to the same passport either way.
Who sees which data?
Medicines information is strongly tiered. The patient text is authorised word by word, and the text for professionals differs from it. Manufacturing and audit records are not public at all. In Transpareo you set for every field who may see it. The authorised product information can be public. Batch records, temperature logs and audit reports are seen only by the readers you admit. The same code shows every reader their part.
May a passport carry patient-facing information?
Yes, the authorised text, and only in its authorised form. Product information may not be rewritten, shortened or supplemented with promotional claims. For prescription medicines advertising to the general public is prohibited. So a passport serves as a container for authorised content. Data without a promotional message joins it, such as manufacturing origin, cold-chain evidence and disposal information. A machine translation does not replace an authorised language version. Transpareo shows no advertising behind the passport and does not track readers in the browser.
Do I need one passport per pack?
That depends on what it should answer. Serialisation already works per pack, in the repositories system. A passport is usually more useful per product or batch. That is where the authorised information, the manufacturing sites and the batch evidence sit. Transpareo keeps passports per product, batch or item. So you go down to the single pack where there is a reason to.
How long does the information have to stay available?
Longer than the shelf life. Batch documentation has to be retrievable years after the last pack expired. A pharmacovigilance question often reaches back further. So a link printed on a carton has to outlive the carton by a wide margin. Settle before you sign what happens to your passports after a cancellation. With Transpareo, published passports stay reachable at a permanent address. Our provider checklist names more questions.
What does non-compliance cost?
For the safety features the member states set the penalties, and their authorities enforce them. In practice the consequence weighs more. A pack that cannot be verified may not be supplied. A batch whose data is missing from the system stands still. An unauthorised or outdated text in the product information is an infringement that reaches the marketing authorisation itself. Either way the damage shows as stopped supply.
Official documents
Legal sources for pharmaceuticals to read for yourself: what each document is and when you need it.
- Directive 2011/62/EU (Falsified Medicines Directive)The directive of 8 June 2011 that inserted the safety features into Directive 2001/83/EC. To be transposed by 2 January 2013. Start here if you want the reasoning behind serialisation.
- Commission Delegated Regulation (EU) 2016/161The mechanics. It sets what the unique identifier contains and how it is encoded, and governs how the repositories system is set up. It applies from 9 February 2019, in some Member States from 9 February 2025 at the latest.
- Directive 2001/83/EC on medicinal products for human useThe Union code the Falsified Medicines Directive amended and the pharmaceutical package will replace. Until the reform applies it stays the reference for the summary of product characteristics, the package leaflet and the labelling. It requires a ban on advertising prescription medicines to the public.
- Council position on the new pharmaceutical DirectiveThe text the Council adopted at first reading on 28 September 2026. Art. 66 governs the electronic package leaflet and bars tracking and advertising with it. Art. 221(9) sets the dates. Until Parliament’s second reading it is a draft.
- Commission page on falsified medicinesThe official overview of the safety features, the verification system and the dates behind them. A short and correct account of what the unique identifier is for.
- EMA page on electronic product informationWhat ePI is and the common standard the network adopted. Then the pilot and its report, the roadmap and the submission guidance. The ePI timeline changes here first.
- EMA page on the reform of the EU pharmaceutical legislationThe status of the new Directive and Regulation, with the political agreement of 11 December 2025 and the transition to application. Check it before you trust any date on a slide.
- Regulation (EU) 2024/1781 (ESPR)The framework regulation behind the digital product passport in other industries. Relevant here because it takes human and veterinary medicines out of its scope.
Further reading on our blog
Trust in a product passport rests on the signed record of the product itself. Transpareo Proofchain keeps it verifiable that way for ten years, longer than a platform usually lasts.
Transpareo signs each field of a product passport on its own, so a disclosed protected field keeps its proof. Its reader need not trust the platform.
GS1 Digital Link is an international standard for the QR code on a product passport. What it means for interoperability.
One page behind every pack
Start free and put the authorised information behind a code of its own, next to the Data Matrix you already print.