When you buy from or sell to another pharmacy to restock, DSCSA applies. Four things matter on every trade:
Transaction information (TI): product, strength, dosage form, NDC, container size and count, lot, dates, and both parties’ names and addresses.
Transaction statement (TS): the seller’s attestation that it is authorized, received the product from an authorized source, and is not knowingly shipping suspect or illegitimate product.
Authorized trading partners: your trading partner must hold a valid state pharmacy license.
Records: keep product tracing records for at least six years.
You may hear “T3.” It’s legacy shorthand for TI, transaction history and TS. The transaction history requirement ended on November 27, 2023 under § 582(k) of the FD&C Act, the sunset provision, on the same date the enhanced drug distribution security requirements in § 582(g) took effect. TI and TS still apply.
There is one exemption, and it is narrower than it sounds. DSCSA defines a specific patient need precisely: the transfer of a product from one pharmacy to another to fill a prescription for an identified patient (§ 581(19)). Where that applies, the selling pharmacy does not have to pass transaction information and a transaction statement with the product (§ 582(d)(1)(A)(ii)).
The same definition then closes the door the phrase appears to open. It says the term “does not include the transfer of a product from one pharmacy to another for the purpose of increasing or replenishing stock in anticipation of a potential need.” It covers the prescription in front of you, and nothing else.
That matters because pharmacies buy and sell for far more reasons than one patient’s prescription — overstock tying up cash, deadstock and near-expiry stock, a formulary change, a discontinued line, covering a shortage, or building up ahead of a known seasonal run. None of those is a specific patient need, so for all of them the full requirements apply.
InStockRx does not rely on that exemption. Every trade carries transaction information and a transaction statement, between verified authorized trading partners, whatever the reason for the trade. So you are never working out whether a particular purchase qualifies as a specific patient need — the records are there either way, and you can buy and sell for any legitimate reason your pharmacy has.
Verified partners only. Every pharmacy’s state license and DEA registration are verified before its first trade. No one lists, browses or trades until that’s done.
TI and TS on every trade. Transaction information and a transaction statement are recorded and stored with the trade for both sides.
Your records, in your account. Find your purchases under Buying Activity and your sales under Selling Activity. We keep records for seven years, a year longer than DSCSA’s six.
Transfers between your own pharmacies carry no fee, with the DSCSA transfer information attached to the trade.
A real person to call. Every member has a dedicated Account Manager, with a response within one business day.
DSCSA now calls for secure, interoperable electronic exchange of TI and TS. FDA recommends GS1’s EPCIS standard for it. Many wholesalers still send EDI 856 advance ship notices, and a PDF or ASN alone doesn’t show package-level interoperability.
We can sit in the middle of that exchange in three ways, and you choose which. Upstream, we can receive EPCIS data directly from your wholesaler, so what they send about your purchases reaches us in the standard format rather than as paperwork you re-key. Downstream, when a purchase on InStockRx completes we can send its EPCIS file straight on to the DSCSA compliance provider or chain system you already use, so you are not downloading files here and re-filing them there. Or we hold it, which is the default: your records stay in your account for the full six years, and you export them whenever you need them. Tell us which wholesaler or provider to connect and we will set it up. Questions about data exchange go to dscsa.support@instockrx.com.
DSCSA does not require a seller to prove where a package came from. TI and TS are the standard, and every trade on InStockRx carries them. Certification is something extra we built on top: a certified listing has evidence of the medication’s supply chain attached to it — either the original wholesaler invoice or a DSCSA EPCIS transaction history file — so a buyer can see where the package came from before making an offer, rather than taking its origin on trust.
This is where connecting your wholesaler’s EPCIS feed, described above, earns its keep a second time. With that feed connected and your GLN on your pharmacy profile, scanning the 2D barcode when you list captures the GTIN and serial number — and if our tracing data shows that exact package was most recently transferred to you, the listing certifies itself. There is no file to find and nothing to upload. Without the feed, certifying a listing means going back for the invoice.
Buyers notice. A cash offer carries a tick box asking the seller to attach an invoice or EPCIS file, some medications require certification outright, and a certified listing can typically be priced higher than one without, because the buyer is more confident in what they are buying. To set it up, ask us to connect your wholesaler’s EPCIS feed at dscsa.support@instockrx.com.
If a product looks wrong, quarantine it and investigate. If it’s determined to be illegitimate, notify FDA and your immediate trading partners within 24 hours. Keep written procedures (SOPs) for record review, discrepancies, investigations, notifications and who does what. On InStockRx, contact info@instockrx.com and your Account Manager; your trade records are ready to pull for the investigation.
GS1 standards are how the drug supply chain identifies products and shares tracing data: the GTIN in every DataMatrix barcode, location numbers for trading partners, and EPCIS for data exchange. InStockRx has been a GS1 US Standard Solution Partner since November 2024 and uses the GS1 US Data Hub, so the product identifiers on InStockRx follow the same standards your wholesaler uses.
FDA extended exemptions from certain enhanced tracing and verification requirements for small dispensers to November 27, 2027. Eligibility is based on the owning company having 25 or fewer full-time licensed pharmacists or qualified pharmacy technicians as of November 27, 2026. It is not an exemption from all DSCSA duties. Read more in our DSCSA deadlines guide.
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