Over the past year, PHSL has kept you up to date on the U.S. Customs and Border Protection’s (CBP) Country of Origin requirements for prescription medications. You can check out our original article and October 2025 update at the links provided.

Despite pushback from several pharmacy organizations, CBP affirmed their position in July 2025, resulting in the need for pharmacies to quickly implement strategies for compliance. In our initial article, PHSL addressed the concern of where country of origin would be sourced from, as this information had not been widely captured in leading drug databases. Once it became clear that pharmacies would need additional resources to comply with CBP’s requirement, pricing compendia providers Medi-Span, First Databank, and Gold Standard began to collect and publish the country of origin in their compendia in late 2025. This allowed pharmacy systems using these compendia as part of their pharmacy dispensing software systems to have access to country of origin by NDC. Pharmacies can then use the information to publish country of origin on prescription labels in compliance with the CBP’s requirements. Pharmacies should contact their systems vendor if country of origin is not automatically included from a compendia source.

Manufacturers should be prepared to submit their product’s country of origin when submitting NDCs to drug compendia providers. PHSL can assist with your questions regarding country of origin requirements and/or compendia submission form guidance. Contact us today!