The FDA is encouraging small dispensers to complete the DSCSA Small Dispensers Assessment Survey by September 22, 2026. This assessment will help FDA better understand whether small dispensers have access to the technology, software, and resources needed to meet DSCSA enhanced drug distribution security requirements.
Need more clarity on what these updates mean for your pharmacy?
Visit our DSCSA FAQs for detailed information.
What does this mean
The Drug Supply Chain Security Act, or DSCSA, continues to move the industry toward interoperable, electronic tracing of prescription drugs at the package level. For small dispensers, the FDA is gathering information through an assessment survey to better understand real-world readiness, including whether required software and hardware are accessible, affordable, and able to fit into pharmacy operations.
Small dispensers may complete the survey themselves or designate another entity, such as a consultant, to complete it on their behalf.
How does this impact you
If your pharmacy qualifies as a small dispenser, the September 22, 2026 survey deadline is an important opportunity to share feedback directly with FDA about your pharmacy’s ability to meet DSCSA requirements. For the purposes of FDA’s current exemptions, a small dispenser is defined as a company that owns the dispenser and has 25 or fewer full-time employees licensed as pharmacists or qualified as pharmacy technicians as of November 27, 2026.
The FDA has also issued exemptions from certain DSCSA requirements for small dispensers, and where applicable their trading partners, until November 27, 2027. This exemption gives FDA time to complete the small dispensers assessment, publish the final assessment report for public comment, and host a public meeting on the assessment.
Why this matters
Completing the FDA survey helps ensure the pharmacy owner perspective is represented as FDA evaluates the feasibility of DSCSA requirements for small dispensers. The assessment looks at whether the necessary software and hardware are readily accessible, whether they are prohibitively expensive to obtain, install, and maintain, and whether they can be integrated into day-to-day business practices, including interoperability with wholesale distributors.
Staying engaged now can also help your pharmacy remain audit ready, reduce operational disruptions, and better prepare for future DSCSA expectations.
DSCSA Frequently Asked Questions
Need more clarity on what these updates mean for your pharmacy? Visit our DSCSA FAQs for detailed information.
For the most comprehensive and up-to-date information, review the FDA’s Drug Supply Chain Security Act resources, including the FDA’s Small Dispensers Assessment page and Exemptions under the Drug Supply Chain Security Act page. The FDA outlines small dispenser assessment details, exemption timelines, waiver and exemption options, and ongoing DSCSA compliance expectations.
