Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Notable

Add facility codes to drug packaging and build a searchable database

Attempted

Printed page 457 14. Department of Health and Human Services

“The FDA should also add facility codes to drug packaging and construct a searchable database that cross-references product codes and facility codes.”

What has happened

  1. Attempted

    FDA has formally scheduled the labeling half of this ask. The 2026 Unified Agenda, published 2026-08-14, carries HHS/FDA RIN 0910-AJ32, "Amendments to 21 CFR Parts 201, 314, and 601 to Promote Supply Chain Transparency in Human Drug Labeling; Identifying API and FDF Manufacturing Sites", at Proposed Rule Stage, first published in this agenda, with an NPRM listed for 07/2026 and none published: FDA "is proposing to require brand and generic pharmaceutical manufacturers to improve transparency of pharmaceutical manufacturing information", amending part 201, the drug labeling part. Identifying the API and finished-dosage-form manufacturing site on the label is the Quote's first limb - which facility made the drug, stated on the package - under the agency's own words for it. The second limb is untouched: no searchable database cross-referencing product codes to facility codes is proposed here or anywhere else. Nothing has been published, and the package identifier itself still carries no facility segment - the final rule of 2026-03-05 fixes the National Drug Code at twelve digits in three segments (labeler, product, package), effective 2033-03-07. A dated agenda entry naming the ask's object is `attempted` and never more (playbook §3b, settled 2026-09-01).

Research log

What was searched, and what didn’t count as evidence

Research notes

  • FDA’s existing Drug Establishments Current Registration Site lists registered establishments but is not cross-referenced to product codes and pre-dates the window.
  • One search, run 2026-08-28, covered the p. 456–457 asks on generics, laboratory tests and inspections: this one, #1224, #1226, #1228, #1229, #1231 and #1232.
  • Correction of an earlier finding, made 2026-09-01 on a reading of the full HHS regulatory agenda. The search of 2026-08-28 recorded not started on a Federal Register negative — “facility codes” returns 0 documents since 2025-01-20, which is still true, because the Quote’s own phrase is not the instrument’s phrase: a document’s title is not a keyword list. FDA’s word for the thing is “identifying API and FDF manufacturing sites”, and it appears only in the full HHS agenda on reginfo.gov (183 active RINs), not in the abbreviated Unified Agenda the Federal Register prints. The agenda was published 2026-08-14, before the stale not started event of 2026-08-28, so the later finding replaces the stale event rather than following it, and the earlier negative is restated inside the new event’s note. The NDC final rule stays as Evidence because it is what shows the package identifier still has no facility segment.
  • No proposed rule for RIN 0910-AJ32 appears among the Federal Register proposed rules we keep and search (checked 2026-09-01), so the Status comes from the agenda entry alone. A boundary call: the entry names the labeling limb in FDA’s words rather than the Mandate’s (“manufacturing sites”, not “facility codes”) and says nothing about the searchable database, so a reviewer who reads the ask as one indivisible two-part object would leave this at not started.
Action
create
Object
searchable drug facility code database
ID
1230