There is no grace period.
When US Customs and Border Protection (CBP) redefined the “ultimate purchaser” of imported medications in 2024, it set in motion new labeling requirements that affect pharmacies and pharmacy benefit managers (PBMs) with mail-order services across the healthcare industry.
Despite pushback and requests for changes from stakeholders, throughout 2025, rulings affirmed the CBP’s position that compliance with country-of-origin (CoO) labeling is required, and there is no grace period or leeway.
Pharmacies, PBMs with mail-order pharmacies, and other stakeholders in the healthcare supply chain face operational and compliance challenges necessitating new workflows and technology. To help them efficiently meet regulations, Wolters Kluwer’s cloud-hosted Medi-Span® Country of Origin solution automates CoO labeling at the point of dispensing, helping reduce manual processes for healthcare businesses while enhancing transparency for patients.
What is the purpose of country-of-origin labeling?
Until the CBP ruling, the pharmacy was considered the “ultimate purchaser” of many imported pharmaceuticals. Due to concerns over pharmacies repackaging and relabeling bulk drug orders for sale to consumers in smaller amounts, CBP redefined the “ultimate purchaser” as the individual customer and declared that the patient or consumer be properly informed of any drug’s country of origin.
The reasons CBP cites for the necessity of CoO labeling include:
- The consumer’s right to know if their prescriptions are imported from outside the US.
- It allows the consumer to be selective about purchasing products based on CoO.
- It helps CBP maintain commodity statistics of import volumes.
- It enables US manufacturers to analyze competition.
- It helps track counterfeit goods.