In short: checking an injectable supplier is a sequence of document checks, each made against an independent source and not against copies the supplier sends. The layers are the supplier's License to Operate (LTO), the product's Certificate of Product Registration (CPR), the authorization that links the supplier to the registrant, the papers for the delivered batch, and the record of storage and transport. A gap in any layer is a reason to stop and ask before the product is received.
This article is for procurement officers, pharmacists in charge and licensing staff at hospitals and licensed healthcare facilities. It describes checks that follow from the structure of Philippine drug regulation, as set out in our companion article on the License to Operate and the Certificate of Product Registration. We write both terms, and the Food and Drug Administration (FDA) Philippines, in full where they first appear.
Most of the checks below are good purchasing practice. Where a check rests on a legal text or an FDA document we say which one, and where we rely on a consultancy guide we say that too. Several FDA web pages could not be retrieved by our tools, so the description of the FDA's online verification portal comes from secondary sources. Nothing here assesses any supplier or product.
The two numbers on every set of papers
A supplier's papers carry two different kinds of number, and each answers a different question. The License to Operate belongs to an establishment and names the activities it may carry out. The Certificate of Product Registration belongs to one product and names the registrant. Republic Act 9711 prohibits manufacturing, importing, exporting, selling, distributing or retailing a drug without the license the Act requires, and it separately prohibits offering a health product that needs registration and is not registered. The buyer's job is to check both, and then to check that they belong together.
| Document | What it identifies | What to read | Stop and ask if |
|---|---|---|---|
| License to Operate | An establishment and its licensed activity | Company name, address, activity category, validity dates | The name on the invoice or delivery note differs, or the activity does not match what the supplier does |
| Certificate of Product Registration | One product and its registrant | Generic name, brand name, strength, dosage form, presentation, registrant, validity dates | The product in the box differs from the entry in any field, or the registrant is not the supplier and no authorization is shown |
A product registration does not make every company holding stock a licensed supplier. The FDA's licensing sheets list separate establishment categories, among them drug trader, drug distributor (importer, exporter, wholesaler), drugstore and retail outlet for non-prescription drugs. A buyer should confirm that the category on the supplier's license matches what the supplier is doing in the transaction.
Checking the registration
The FDA runs an online verification portal for registered products. Consultancy guides describe a search by product name or by registration number, and one reports that an FDA circular of 2023 required the approved package insert of registered drug products to be published there. We could not confirm the current interface from an FDA page, and for that reason we give no link. Open the portal from the FDA's own website, and never from an address that a supplier sends you.
A useful routine has four steps. Search by the generic name as well as the brand name. Compare every field of the entry with the label of the product offered: generic name, brand name, strength, dosage form and presentation. Read the validity dates, since a registration that has expired is not a current registration. Save a dated printout or screenshot of the entry for the procurement file.
If the product does not appear, that is not by itself proof that it is unregistered, because naming and spelling differ. It is a reason to hold the purchase until the supplier explains the gap and the FDA confirms the status. A copy of a certificate supplied by a seller is a claim. The portal entry and the FDA's own confirmation are the evidence.
Checking the establishment
Ask for a copy of the supplier's License to Operate and compare it with the name and address on the invoice, the delivery note and the registration. The FDA's service sheet for the initial license asks for proof of business registration, a location plan with GPS coordinates and a named qualified person, so each of these facts exists on file at the FDA. Where the FDA offers a lookup for establishments, use it. Where it does not, confirm the details with the FDA directly and keep the reply.
The buyer's own side has its own license. Republic Act 4226, the Hospital Licensure Act, provides that a hospital may not operate or be opened to the public unless it has been registered and has obtained a license from the licensing agency, and later Department of Health orders set the classification and licensing details. That license is separate from the supplier's, and one does not replace the other.
The link between supplier and registrant
The product registration names a registrant. The supplier in front of you may be that registrant or may be another licensed company that handles the product. The authorization chain ties the two together, and it is the layer most often left unchecked.
| Situation | Ask for | Confirm |
|---|---|---|
| The supplier is the registrant | The registration and the supplier's License to Operate | That the registrant's name on the registration matches the licensed establishment |
| The supplier handles the product for the registrant | The registrant's written authorization, with its License to Operate | That the letter names the product, the supplier and the period it covers, and that it is signed and dated |
| A foreign manufacturer has appointed a local company | The letter of authorization from the manufacturer that the FDA's dossier checklist lists where applicable | The manufacturer's identity through a contact you found independently, not one printed on the letter |
Read the letter for the same things in every case: who signs, on whose letterhead, which products it names, which period it covers and what activity it permits. An authorization that names no products, carries no date or cannot be confirmed by the signing company should be treated as missing.
The papers for each batch
Registration and licensing describe the product and the company in general. Each delivery then needs its own evidence that the units in the box are the registered product and that they were kept in the right conditions. The checks below apply to every batch received.
| Document | What to check |
|---|---|
| Certificate of analysis | Batch number and expiry date match the carton and the vial label; the manufacturer and site are named; results are stated against a specification. |
| Label and package insert | The text matches the registered product. The FDA's dossier checklist includes labeling and the package insert, so the approved text is on file. |
| Manufacturer's GMP evidence | For an imported product the FDA's checklist lists a foreign GMP clearance and a Certificate of Pharmaceutical Product in the WHO format; the manufacturing site on them matches the site on the label. |
| Invoice and delivery note | The issuing company is the licensed establishment you verified, and the product description matches the registration. |
| Storage and transport record | For temperature-sensitive products, a temperature record for the whole route and evidence of the stated storage conditions. An FDA circular of 2014 ties the license inspection to good distribution and storage practices, including cold-chain management. |
At receiving, check that seals are intact, that the lot number and expiry date on every carton match the certificate, and that the quantity matches the delivery note. Keep the certificate with the batch record, so that a later question about a vial can be traced to the delivery.
Warning signs
Some patterns justify stopping a purchase until the supplier has answered in writing:
- No License to Operate number, or a license for a different activity than the one being carried out.
- A registration whose registrant is a different company, with no authorization letter.
- A product name, strength or presentation on the box that differs from the registration entry.
- Documents offered only as images that cannot be traced to an issuing body.
- A request to skip a check because a delivery is urgent.
- A promise to complete registration or authorization after delivery.
The FDA has repeatedly issued public advisories about unregistered health products. We could not retrieve those pages in full, so we do not summarize their content, but they are a reason to regard any gap in the layers above as serious.
Keeping a verification file
A verification file turns a one-off check into something an auditor or a licensing officer can follow. For each supplier keep the dated copy of the license, the dated portal record for each product, the authorization letters and the correspondence that confirmed them. For each batch keep the certificate, the delivery note and the storage record. Assign one named owner for the file and set a date to repeat the checks before any registration or license reaches its stated expiry. Because registrants may ask for validity of two years or five years, the expiry dates differ between products from the same supplier.
Scope of this article
This article describes document checks that follow from the structure of the licensing and registration rules. It does not assess any supplier or product, does not replace the Department of Health rules on a facility's own licensing, and does not replace advice from the FDA or from counsel. The legal texts we read were Republic Act 9711 (from the Lawphil project), Republic Act 4226 and the implementing rules of RA 9711 (from the WIPO copy), together with FDA service sheets uploaded in 2023.
Frequently asked questions
What is the difference between an LTO and a CPR?
The License to Operate covers an establishment and its licensed activities. The Certificate of Product Registration covers one product and names the registrant. A buyer needs to check both and check that they belong together.
Where can a buyer check a product registration?
The FDA runs an online verification portal. Consultancy guides describe searching by product name or registration number. Open it from the FDA's own website, and compare every field of the entry with the product label.
Does a registration mean every supplier of the product is licensed?
No. The registration names a registrant. Any company that imports, distributes or sells the product needs a license for its own activity, and a company that is not the registrant should show the registrant's authorization.
Is a copy of a certificate sent by the supplier enough?
No. A copy is a claim. Confirm the entry against the portal and the license against the FDA, and keep a dated record of what you saw.
What should a hospital do if a product is not found on the portal?
Hold the purchase. Ask the supplier for the registration details in writing, check for naming or spelling differences, and confirm the status with the FDA before the product is received.
Does this article replace a facility's own licensing requirements?
No. A hospital's own license is issued under Republic Act 4226 and Department of Health orders. This article only describes how to check a supplier.
Registration partnership
Licensed importers and distributors considering a registration partnership can start the conversation through our enquiry form.
Selected references
- Republic Act No. 9711, the Food and Drug Administration Act of 2009 (amending RA 3720), Section 10. Lawphil
- Republic Act No. 4226, the Hospital Licensure Act, Sections 4 and 5. Lawphil
- Department of Health, Department Circular No. 2011-0101, implementing rules and regulations of RA 9711, Book II, Article I, Section 3. WIPO Lex
- Food and Drug Administration (Philippines), citizen's charter service sheet: License to Operate, initial application for drug traders, drug distributors, drugstores and others. FDA service sheet (PDF)
- Food and Drug Administration (Philippines), citizen's charter service sheet: Certificate of Product Registration of pharmaceutical products, initial, prescription generic drugs. FDA service sheet (PDF)
- FDA Circular No. 2014-026, November 21, 2014, guidelines on licensing of drug distributors. Lawyerly (legal database)
- Secondary source for the portal and its search fields: Triple i Consulting, a consultancy guide (not an FDA text). Triple i Consulting