Inventory

Pedigree required for Rx drugs sold, purchased, traded by non-ADR as of December 1, 2006

• 6 months notice

BUT: Enforcement discretion – until April 1, 2007

• If ADR when Rx drugs were purchased, but non-ADR when sold

  • Documentation that drugs purchased prior to Dec. 1, 2006

  • Documentation that purchased same type of drugs from same mfg on at least 2 occasions in previous 24 months

Inventory acquired via merger, buyout, acquisition