DSCSA Trading Partner Verification — How to Confirm Your Suppliers Are Authorized

What Is a DSCSA Authorized Trading Partner?

DSCSA Section 581(2) defines an "Authorized Trading Partner" (ATP) as a trading partner that is:

• A manufacturer, wholesale distributor, repackager, or dispenser licensed or registered with the FDA
• A wholesale distributor with a valid license in the states where it operates
• A dispenser (pharmacy) with a valid pharmacy license in its state(s) of operation

The ATP concept is central to DSCSA compliance: you can only buy from and sell to other ATPs. Purchasing from an unauthorized source is a federal violation regardless of whether the product itself is authentic.

Why Trading Partner Verification Matters

Before DSCSA, some pharmacies unknowingly purchased product from unlicensed or fraudulent distributors operating as "gray market" sellers. These sellers sometimes offered deep discounts on product that was counterfeit, diverted, or improperly stored.

DSCSA's ATP requirement is designed to close this loophole. By requiring pharmacies and distributors to verify licensure before each transaction, it becomes much harder for illegitimate product to enter the supply chain under the guise of a legitimate transaction.

How to Verify a Supplier's ATP Status

To verify that a wholesale distributor is an authorized trading partner, you should:

1. Request their state wholesale distributor license numbers for all states where they ship product
2. Verify the license through your state board of pharmacy or through the NABP Wholesale Distributor Database
3. Request their FDA registration number under DSCSA (required for all wholesale distributors after 2014)
4. Check for NABP VAWD accreditation — a voluntary credential that demonstrates higher compliance standards

Premier Pharma provides our license numbers and FDA registration on request and maintains current NABP VAWD accreditation.

Common Red Flags for Unauthorized Distributors

Be cautious of any supplier that:

• Cannot provide a valid wholesale distributor license for your state
• Offers prices significantly below market rates with no explanation
• Cannot provide T2 documentation (TI + TS) with shipments
• Offers product that has been repackaged or relabeled without explanation
• Does not provide compliant product identifiers (NDC + serial + lot + expiration)
• Solicits transactions through personal email or phone without a business address

If a deal seems too good to be true, it may involve diverted, counterfeit, or improperly stored product.

Consequences of Buying From Unauthorized Sources

Purchasing prescription drugs from an unauthorized source is a violation of both DSCSA and state pharmacy law, regardless of whether the product itself is ultimately found to be authentic. Consequences can include:

• FDA Warning Letter and enforcement action
• State board of pharmacy disciplinary action, including license suspension or revocation
• Criminal referral if controlled substances are involved
• Civil liability if a patient is harmed by compromised product

How Premier Pharma Maintains ATP Compliance

Premier Pharma holds wholesale distributor licenses in all states where we operate, is registered with FDA under DSCSA, and maintains NABP VAWD accreditation. We verify the license and registration of every customer before shipping product and refuse to sell to unlicensed buyers. Our compliance team can provide documentation of our licensure and accreditation on request.