NCPA and NACDS have submitted joint comments to U.S. Customs and Border Protection on its interpretive ruling on marking prescriptions with their country of origin. Under the ruling, medication bottles that pharmacies dispense to patients must be marked with the COO on the packaging that the patient receives. NCPA and NACDS also requested a joint meeting with CBP to discuss the ruling, and sent our joint comments to the White House, Department of Health and Human Services, Food and Drug Administration, Department of Labor, and Department of Commerce leadership.
Together, we expressed that CBP’s interpretative ruling is a stark departure from more than a century of standard pharmacy practice. Requiring pharmacies to now include the COO on prescription bottles would impose undue burdens on pharmacy practice.
Since pharmacists presently do not provide this information on prescription bottles, pharmacy workflow would need to be reconfigured to allow pharmacists to view the COO and somehow mark that information on the prescription bottle. This would cause widespread disruption of pharmacy practice nationwide as pharmacy computer systems software would need to be redesigned and reconfigured to capture this information and mark it on the prescription bottle. This would cost millions of dollars in technology upgrades and could take years to accomplish.
Additionally, we expressed concern that this requirement would exacerbate existing prescription drug shortages because pharmacies would be forced to dispense medications in manufacturer-provided stock bottles that are already marked with the COO. Pharmacies would not be able to utilize larger stock bottles that are broken down into smaller quantities for dispensing, impacting patients’ ability to obtain life-saving prescriptions.
