What the regulation means in practical terms
To comply, most companies need three things working together:
- Unique identification per saleable pack
- On-pack marking that can be scanned reliably
- Digital reporting of product and movement events (often in an EPCIS-like model)
If you only “print a code” but cannot reliably link that code to events (commissioning, packing, shipping, receiving, etc.), you will still face compliance and release risk.
Core requirements
1) A unique ID for each saleable pack
Each pack needs a unique identifier so it can be verified and traced through the supply chain. In practice, this means you need a controlled process to request/allocate IDs, apply them to packs, and reconcile what was used versus what was issued.
2) Standardized data on the pack (scan-ready)
Most implementations use a GS1 DataMatrix on the secondary package, carrying key data elements such as:
- Product identifier (commonly GTIN)
- Unique ID / serial (or UID)
- Batch/lot
- Expiry date
Your packaging line must be able to print, verify, and scan these marks at speed—without quality drift.
3) Aggregation (pack → case → pallet)
Aggregation links child items (packs) to parent containers (cases, pallets). It is what makes warehouse operations fast and what makes reporting coherent.
If your aggregation is weak, you will spend time fixing “orphan packs,” broken hierarchies, and shipment mismatches.
4) Event reporting to the national system
Companies are expected to report supply-chain events so the national system can understand product status and movement. Common event types include:
- Commissioning (creating active serialized packs)
- Packing/aggregation
- Shipping and receiving
- Returns, recall handling, and decommissioning (e.g., expiry/destruction), as applicable
Exact submission methods and validations can vary by implementation and portal rules, so treat your EDA onboarding/portal guidance as the operational source of truth.