US Pharma · DSCSA §582 · enforcement is live

FDA can ask for your tracing records. You have 48 hours.

Most companies find out whether they can answer during the recall, not before it. This audit tells you in 14 days — in writing, on your real products.

$5,000 fixed — credited if you proceedWritten report in 14 daysNo commitment to proceed

Wholesale distributors: 1 business day, not to exceed 48 hours — 21 U.S.C. §360eee-1(c)(1)(C). Dispensers: 2 business days — §360eee-1(d)(1)(D).

The problem

One phone call starts a clock you cannot pause.

A drug gets recalled. Or FDA opens an investigation into a suspect product and one of your lot numbers is on the list. Someone calls you and asks a simple question: where did this unit come from, and where did it go?

The law gives you two days to answer. Not two days to start looking — two days to have the answer.

What people assume

“Our serialization system has it.”

It has the numbers. Whether it can assemble one unit's full history, across every partner who touched it, inside 48 hours is a different question — and almost nobody has tested it.

What usually happens

People start opening spreadsheets.

The record exists, but in pieces: your system, your supplier's portal, an emailed file, a PDF someone saved. Assembling it is a research project. The clock does not care.

What it costs

You recall wider than you need to.

When you cannot say exactly which units are affected, you pull everything that might be. Good product goes in the bin because the record could not be trusted to be precise.

Why now

The grace period is over.

DSCSA is not coming. It arrived. The stabilization period ended in November 2024 and FDA's exemptions have expired for every category except the smallest pharmacies. If you are a wholesale distributor or a larger dispenser, you are already inside enforcement.

There is one clock left, and it is not yours unless you are small: 27 November 2027.

Manufacturersexpired 27 May 2025
Wholesale distributorsexpired 27 Aug 2025
Larger dispensersexpired 27 Nov 2025
Small dispensers27 Nov 2027
What we do

We run the fire drill before the fire.

We pick one of your real products. We ask the question a regulator would ask. Then we time you.

01 · Step

We pick a unit and trace it

A real product from your real inventory. We follow it back through every hand it passed through, using only the records you actually hold today.

02 · Step

We put a stopwatch on it

You get a number: how many hours it takes you, today, to answer the question the law gives you 48 hours to answer. Most people have never measured this.

03 · Step

We write down what is missing

Every gap, what it would cost to close, and how long it takes. Ranked, so you can fix the dangerous ones first and argue about the rest later.

That is the whole product. There is no platform you have to buy to get value from it, and no rip-and-replace. If your existing systems come out clean, the report says so.

Book it

$5,000. Fourteen days. Credited if you proceed.

Pay online and we start. If you go on to implement with us, the full $5,000 comes off your first invoice — so the audit costs you nothing but time. If you don't, you keep the report and owe us nothing further.

Fee
$5,000 fixed
If you proceed
Fully credited
Turnaround
14 days
Your team's time
Under 4 hours
$5,000 fixed — credited if you proceedWritten report in 14 daysNo commitment to proceed

What lands on your desk

  • A written gap analysis against §582 and the systems you run today.
  • Your traceback time measured on a real unit, so you have a number.
  • A ranked fix list with cost and timeline against each item.
  • A readiness check of TraceLink, Antares or MediLedger as you have them configured.
  • A pilot scope for one product line, if and only if you want one.
The audits

Six regulations. One at a time.

DSCSA is where US pharma starts. If you sell into Europe, the same method applies to the rules that reach you there.

Auditor verifying a pallet with a handheld RFID reader in a dark warehouse In the field · pallet-level verification
FAQ

The questions people ask before they book.

How much does an Aeroz compliance audit cost?

$5,000, fixed, paid online. If you go on to implement with us, the full $5,000 comes off your first invoice — so the audit costs you nothing if you proceed. Larger multi-regulation scopes are quoted after a short call.

What do I actually get for $5,000?

A written report in 14 days: where you are exposed under the regulation, a timed test of how fast you can trace one unit today, a fix list with costs and dates, and a scoped pilot for one product line. It is written to be handed to a regulator or a board, not to a salesperson.

How fast do I have to answer FDA?

If you are a wholesale distributor: 1 business day, not to exceed 48 hours (21 U.S.C. §360eee-1(c)(1)(C)). If you are a dispenser: 2 business days (§360eee-1(d)(1)(D)). The clock starts when the request arrives, not when you find the records.

Is DSCSA actually being enforced yet?

Yes. The stabilization period ended 27 November 2024. Manufacturer exemptions expired May 2025, wholesale distributors August 2025, larger dispensers November 2025. Only small dispensers have time left, until 27 November 2027.

Do I have to replace TraceLink, Antares or MediLedger?

No, and we would tell you if you did. Those systems do serialization and they do it well. We test whether the data they hold can actually answer a regulator's question in the time the law allows, and we sit on top of them rather than replacing them.

Do I have to buy anything after the audit?

No. It is a standalone engagement with a written deliverable and no obligation. Plenty of people buy it purely to size their exposure and stop there. That is a legitimate outcome and we will not chase you.

What if the audit says we are fine?

Then you have a dated written record saying so, which is worth having the next time your board or a customer asks. We will not invent a gap to justify the fee, and the report says plainly what it found.

Who runs the audit and how much of my team's time does it take?

Our audit team, working from your existing records and systems. Expect two calls and a data pull — usually under four hours of your people's time across the fortnight.