A medicine rarely vanishes overnight. A batch fails inspection, a supplier emails about a late delivery, a hospital tender adds demand, and months later a pharmacy has none. Early warning means joining those events up while there is still time to act, then telling the regulator when the law asks you to.
This guide is for anyone who keeps a medicine on the shelf or answers for it: supply continuity leads, supply planners, market supply leads, QA release, regulatory affairs and heads of supply risk. No background needed.
Imagine you are the supply continuity lead at a mid-size drug company, Northwind Bio, and you look after a biologic pen in Germany. It is Wednesday, October 7. You have 19,800 pens on hand and sell about 3,100 a week. One lot is on hold in quality, one shipment is quarantined after a warm truck, and a regional supply contract won in a tender adds 560 pens a week from November 2. Your projection dips below safety stock, the two-week buffer you keep for surprises, on November 16, and it never reaches zero.
At 9:18 am the contract manufacturer writes that a sub-supplier's furnace repair has cut its glass syringe barrels. Lot 2614, 6,000 pens, will ship late. The email is one of 23 reaching a shared mailbox that day.
Before the email
Lot 2614 ships
Nov 20
Stock-out
None projected
After the email
Lot 2614 ships
Dec 14
Stock-out
Nov 30, in 54 days
Seen 54 days aheadThree moves close the gap:4,200 pens from two nearby markets, a faster QA release and air freight.
Early warning catches this because someone read that email the morning it came and took 6,000 pens out of the forecast at once. It also puts the next question on the table while there is time to answer it: do we owe a regulator a report?
Drug shortages from inside the manufacturer: the warnings, the rules, the arithmetic and the people who sign
Why three trackers count US shortages three ways, what section 506C and the EU rules ask and when, which supply indicators move first, how weeks of cover is worked out, who decides, and how teams run all of it today. If you are new to the work, start here.
01 · In plain words
What drug shortage early warning is: seeing a supply gap while there is time to close it
A drug company makes a medicine in batches, often months before anyone takes it. A contract plant fills it, a packer labels it for each country, a quality team releases it, and a truck delivers it. A planner keeps a forecast of how much stock each country will hold in each coming week. When everything arrives on time, nobody thinks about that forecast.
Then something slips. A quality inspector finds particles in one tray of a batch, so the batch waits. A data logger on a truck reads warm, so a shipment waits. A health insurer in one country awards a tender, so demand rises. A supplier's supplier has a broken furnace, so the contract plant writes that a batch will ship three weeks late. Each of these reaches a different person, in a different system or a shared mailbox. Each looks manageable alone.
Together they can empty a country's shelves. The planner's forecast still shows the old dates until someone changes them, and the monthly or weekly planning meeting may be the first time anyone adds it all up. By then, the choices have shrunk. There is less time to move stock from a neighboring country, ask quality to prioritize a release, or book a flight.
A second job sits on top of the first. In the United States, a company that makes an important medicine must tell FDA about an interruption likely to disrupt its supply, ideally six months ahead and in the worst case within five business days. In the European Union, a company tells the national regulator, and for centrally authorized medicines also the European Medicines Agency, as early as possible. Doing that well depends on having seen the gap early, so the two jobs are one piece of work.
One German pen, from a supplier's email to a decision about the regulator
An event happensA hold, a late batch, a warm truck, a tender. In the example, a sub-supplier's furnace repair cuts the glass barrels for lot 2614.
Someone reads it and moves the datesThe event is matched to a lot, a pack and a market, and the forecast is rebuilt with that stock taken out. This step, and the next, are what this guide is about.
The risk gets a date and an ownerA projected date when stock falls below the safety level, and a date when it runs out. In the example, November 30, 54 days away.
People choose what to doMove stock, speed a release, fly a batch, phase deliveries. One person signs, and a second signs off on a large move.
The regulator hears, if the law says soRegulatory affairs decides and files. The decision and its reason stay on the record, whichever way it goes.
The companies, people and figures in this example are fictional.
Why five business days is the fallback, and three more shortage surprises
Six months is the rule
FDA's duty starts at six months before an interruption. Five business days applies only when the event could not reasonably be foreseen six months ahead.1
A competitor's stock does not help you
FDA's draft guidance says to judge the interruption "solely" on your own capacity and supply, leaving out what others could make.2
Your supplier owes FDA nothing
A third-party ingredient maker or contract plant has no duty to notify. The applicant answers alone, whoever made the product, so the applicant needs its suppliers to tell it.2
The EU platform covers fewer products than people think
Outside a crisis, the EU's monitoring platform takes reports on centrally authorized medicines only. National reporting always stays in place.3
Four terms shortage teams use every day
Weeks of cover
Stock divided by forecast demand per week. It says how long supply would last if nothing else arrived.
Safety stock
A buffer a company chooses to keep for surprises, often stated in weeks. In the example, two weeks, or 6,200 pens.
Meaningful disruption
US legal phrase: a production change reasonably likely to cut a firm's own supply by more than a negligible amount and affect its ability to fill orders or meet expected demand.1
Marketing authorization holder (MAH)
The company that holds a medicine's license in the EU. A centrally authorized product holds one license for the whole Union, granted through the European Medicines Agency.
You will also see CMO (contract manufacturing organization, a firm that makes product for you), API (active pharmaceutical ingredient, the substance that does the medical work), S&OP (sales and operations planning, the regular meeting where supply and demand are reconciled) QA (quality assurance, the team that releases batches) and Tier (the priority a company gives a product on its critical list, with Tier 1 the most critical).
02 · Three shortage counts
Why FDA reports 93 ongoing drug shortages while pharmacists report 227
In shortBoth numbers are correct for what they count. Each tracker uses its own inclusion rules, and FDA's follows a legal definition. For a manufacturer the useful figures sit lower down: FDA received 1,424 notifications in 2025 and says it helped prevent 330 shortages. Early notice is the mechanism FDA credits.
"How many drugs are in shortage?" has at least three published answers. FDA had 93 ongoing shortages at December 31, 2025.4 United States Pharmacopeia (USP), working from FDA's list, reported 75 at the same date.5
The American Society of Health-System Pharmacists (ASHP) and the University of Utah counted 227 active shortages at the end of the second quarter of 2026, the third quarterly rise in a row, against an all-time high of 323 in the first quarter of 2024.6 We read these pharmacist figures in trade press accounts, not in ASHP's or USP's own reports.
The legal definition explains part of the gap. Under FDA's rules a shortage is a period when demand or projected demand for a drug in the United States exceeds its supply.1 A hospital pharmacist who cannot buy one presentation from a usual wholesaler has a real problem that may not meet that test nationally. Read each count as an answer to its own question.
93
ongoing shortages tracked by FDA's drug and biologics centers at December 31, 2025.4
FDA, report to Congress for 2025
227
active shortages on the ASHP and University of Utah count at the end of the second quarter of 2026.6
As reported by AJMC, July 20, 2026
5.3 yrs
USP's average duration of an active shortage at the end of 2025, up from 4.3 years a year before and about two years in 2019.5
As reported by RAPS, June 10, 2026
New FDA-tracked shortages fell from 251 in 2011 to 4 in 2025
New drug and biologic shortages per calendar year, as drawn in FDA's Figure 1
New shortages falling so far says less than it seems to. Old ones are staying. FDA's ongoing count sat at 41 in 2017 and at 93 in 2025, and FDA puts that down to market conditions, including weak incentives to make older, less profitable products and limited manufacturing capacity.4 USP's rising average duration tells the same story.5
Ongoing shortages have more than doubled since 2017 even as new ones fell
Ongoing FDA-tracked shortages at each year end, as drawn in FDA's Figure 3
What FDA's 2025 shortage numbers say about early notice
In 2025, 167 manufacturers told FDA about 1,424 potential shortage situations under section 506C. FDA says it helped prevent 330 shortages that year, using tools such as regulatory flexibility, and it expedited review of 224 submissions and prioritized 10 inspections.4 FDA's stated reading is that early notification requirements are helping to reduce the threat and impact of shortages.4 That is the agency's own assessment of its own program, and a prevented shortage cannot be counted as cleanly as one that happened.
FDA credits itself with 330 prevented shortages in 2025, the highest count in this six-year window
Shortages FDA says it helped prevent, drugs and biologics combined
What the public lists show on a given day, in November 2026
FDA and the European Medicines Agency each publish a list that anyone can read. FDA's data, through openFDA, held 1,153 rows marked Current on November 2, 2026. Each row is one package, so one shortage can fill many rows, and openFDA warns that it has not validated its data.
By our count of every Current row, they cover 69 generic product names, and 820 of them, or 71%, are injections; the count leaves out rows marked resolved or to be discontinued.7 EMA's catalog, generated on November 3, 2026, lists 27 ongoing shortages, 53 resolved and 5 discontinued medicines (our count of its export). It holds only shortages EMA has assessed, and EMA says it is not a full overview of EU shortages.8,3
Medicine, by generic name
Where listed, and the date read
What the list says
Lisdexamfetamine capsules
FDA data, November 2, 2026
90 package rows, first posted from 2023; 26 rows give the reason as shortage of an active ingredient.7
Lidocaine injection
FDA data, November 2, 2026
65 package rows, first posted from 2012; 15 rows give the reason as increased demand.7
These lines repeat public lists on the dates shown and say nothing about any firm's conduct. A listing can change on any day.
Almost all current package rows on FDA's list were first posted in 2023 or earlier
1,153 current rows on November 2, 2026, by the year each was first posted. Rows count packages, and a row first posted long ago may have been updated since.
FDA section 506C: who must notify, about which medicines, and by when
In shortThe manufacturer or applicant of a prescription drug or biologic that is life-supporting, life-sustaining, or for a debilitating disease must tell FDA about a permanent discontinuance, or an interruption likely to cause a meaningful disruption in US supply. Notice is due six months ahead. If that could not be foreseen, it is due as soon as practicable and, for a finished product, no later than five business days after the event.
Section 506C of the Federal Food, Drug, and Cosmetic Act, codified at 21 U.S.C. 356c, is the statute. FDA's 2015 final rule put it into 21 CFR 314.81(b)(3)(iii) for drugs, 21 CFR 600.82 for biologics and 21 CFR 310.306 for drugs marketed without an approved application.9,1,10,2 The law reached its present shape in two steps: the FDA Safety and Innovation Act (July 9, 2012) and the CARES Act (March 27, 2020, in effect September 23, 2020), which added active ingredients, associated devices and redundancy plans.2,4
Section 506C grew in steps, and FDA's newest guidance is still a draft
Oct 31, 2011Executive Order 13588
Directs FDA to seek early notice from manufacturers.
Jul 9, 2012FDASIA
Notice extended to most covered prescription drugs, and non-compliance letters required.
Jul 8, 2015Final rule
21 CFR 310.306, 314.81(b)(3)(iii) and 600.82, including biologics.
Sep 23, 2020CARES Act takes effect
Adds API notices, redundancy plans and yearly volume reports.
Feb 2024Draft guidance, Revision 1
Recommends more content and updates about every two weeks.
Nov 3, 2026Status today
The 2024 revision is still labeled draft on FDA's page.
The clocks for a finished product and for an active ingredient differ
Finished product
Active ingredient for a finished product
Who notifies
Applicant holding the approved application (an NDA for a new drug, an ANDA for a generic or a BLA for a biologic), or the maker of an unapproved covered drug.2
The same applicant or maker. Third-party API makers and suppliers are not required to.2
What triggers it
Permanent discontinuance, or an interruption in manufacturing likely to lead to a meaningful disruption in US supply.1
Permanent discontinuance, or an interruption likely to lead to a meaningful disruption in supply of the API.9,2
As soon as practicable, and in no case later than 5 business days after it occurs.1,10
As soon as practicable. FDA's draft attaches the five-day cap to the finished product, and says the 2015 rules do not contain the API duty.9,2
Minimum contents
Name with its National Drug Code (NDC), applicant, discontinuance or interruption, reason, estimated duration. Also whether an API or an associated device is a reason or risk factor, with the API source and known alternatives.1,2
Reason, source and known alternative sources, expected duration.2
Where it goes
For products of CDER, FDA's drug center, email to its drug shortage staff or the CDER Direct NextGen Portal. For products of CBER, its biologics center, email. Updates go by email.2
Counting five business days on a real calendar
Say a supplier's reactor shuts down on Friday, October 2, 2026. The first business day after it is Monday, October 5, so the fifth is Friday, October 9. Saturday and Sunday do not count.
The company may hear of it a day later, as a force majeure email on October 3. The text of the rule counts from when the event "occurs", with no allowance for how long the news takes to travel, which is why FDA's draft tells applicants to set up a process with suppliers so they get timely information.1,2 Build your internal date from the event, and treat any business day you lose to an unread mailbox as a day gone.
Four questions decide whether a firm owes FDA a notice
Our reading of the statute, the rule and the 2024 draft. Regulatory affairs and counsel apply it to the facts.
1Is the medicine covered?
Prescription drug or biologic, life-supporting, life-sustaining, or for a debilitating disease, and not a radiopharmaceutical.
Regulatory affairs
2Is it a discontinuance or an interruption?
A permanent stop is always reportable. Routine maintenance or an insignificant change with a quick restart is outside.
Supply and quality
3Would your own supply fall by more than a negligible amount?
Only your own capacity and stock count. Leave out competitors. If unsure, FDA urges you to notify anyway.
Supply, quality, regulatory
4Could you have known six months ahead?
If yes, six months. If no, as soon as practicable, and for a finished product within five business days.
Prescription drug or biologic, life-supporting, life-sustaining, or for a debilitating disease, and not a radiopharmaceutical.
Regulatory affairs
Is it a discontinuance or an interruption?
A permanent stop is always reportable. Routine maintenance or an insignificant change with a quick restart is outside.
Supply and quality
Would your own supply fall by more than a negligible amount?
Only your own capacity and stock count. Leave out competitors. If unsure, FDA urges you to notify anyway.
Supply, quality, regulatory
Could you have known six months ahead?
If yes, six months. If no, as soon as practicable, and for a finished product within five business days.
Regulatory affairs
The clock
Failing to notify means a public letter, and FDA has sent few of them
If a firm misses the duty, FDA must send it a letter. The firm has 30 calendar days to explain and supply the information, and within 45 calendar days FDA posts the letter and any response, unless FDA finds the letter was issued in error or the firm had a reasonable basis.9,1
FDA has issued 11 such letters since 2014, and none in 2024 or 2025, and its page lists the letters with the firms' replies.4,11 The section's force lies in that public record and in losing FDA's help: a late notice leaves the agency less time to expedite a supplement or an inspection under section 506C(g).9,4
FDA has sent 11 non-compliance letters since 2014, and none in the last two years
Section 506C(j) also asks for a plan you keep ready
Since the CARES Act, each maker of a covered drug, its API or an associated device must develop, maintain and, as appropriate, implement a redundancy plan that identifies and evaluates risks to supply for each establishment where the drug or its API is made. FDA may inspect and copy it.9 FDA's guidance on these plans has been a draft since May 2022.12 The redundancy plan is your forward-looking view of where supply could fail, and an early warning system is what tells you it has started to.
04 · Meaningful disruption
The meaningful disruption test sits well below a stock-out
In shortA meaningful disruption is a change in production reasonably likely to reduce a firm's own supply by more than a negligible amount and affect its ability to fill orders or meet expected demand. Waiting for a projected zero sets the bar too high. FDA wants to hear before you miss an order, and if you are unsure it urges you to file.
The definition has one carve-out: interruptions due to matters such as routine maintenance or insignificant changes in manufacturing, as long as the manufacturer expects to resume in a short period.1 Everything else that meets the test counts, whatever your market share, however many competitors could fill the gap, and however much product remains in distribution.2 The 2015 final rule says an applicant need not predict the market-wide effect of its interruption, and FDA's draft repeats it.2
Three lines in the draft change how a warning process should be set up. FDA should not first learn of a disruption when a firm cannot fill an order. If you are considering an action that may lead to a disruption, such as holding production to investigate a quality issue, FDA asks you to notify it immediately. And although a sudden demand spike with no manufacturing interruption falls outside the requirement, FDA asks you to report it anyway.2 These are recommendations in a draft, with no force of law, and they tell you how the people reading your notice think.
Most supply events FDA describes call for notice or a request to notify, well before stock runs out
Our reading of the rule and the February 2024 draft for a covered finished product. Your counsel decides the facts.
NoPossiblyYes
Required by ruleFDA asks for itOutside the dutyPermanent decision to stop making itYesNoNoInterruption likely to cut your own supply by more than a negligible amountYesNoNoProduction hold to investigate a quality issue, disruption possiblePossiblyYesNoUnsure whether a disruption is likelyPossiblyYesNoSudden demand spike with no manufacturing interruptionNoYesYesRoutine maintenance, quick restart expectedNoNoYes
Interruption likely to cut your own supply by more than a negligible amount
Yes
No
No
Production hold to investigate a quality issue, disruption possible
Possibly
Yes
No
Unsure whether a disruption is likely
Possibly
Yes
No
Sudden demand spike with no manufacturing interruption
No
Yes
Yes
Routine maintenance, quick restart expected
No
No
Yes
A late notice, step by step, at a fictional drug maker
Picture Cobbleford Pharma, a fictional maker of a sterile injectable that treats a debilitating condition. On March 2, its QA team holds three batches for a particle investigation. Its supply planner sees six weeks of stock and nobody speaks to regulatory affairs, because six weeks feels like plenty. On April 6 the investigation widens. On April 14 a wholesaler's order goes unfilled, and only then does regulatory affairs write to FDA.
Read against the text, the firm had a production change likely to affect its ability to fill orders by early March at the latest. FDA's draft had asked it to notify immediately when considering such a hold, and in any case before missing an order.2 The six weeks of stock was a reason to feel calm, and it had no bearing on the test. A process built around a weekly cover number alone will repeat that mistake, because cover stays high well after the legal question has been raised.
What FDA recommends on top of the minimum notice
The minimum is five or six facts. FDA's draft lists more that it finds useful, and you may send them later: they include whether the disruption is avoidable, the underlying root cause, the estimated start date, market share, historic monthly sales, whether the product is made on several lines or sites, current inventory, the date the last batch was or will be released, how long supply will last, any reserve and whether allocation is possible, whether a redundancy plan exists, and what you have told customers.
"Manufacturing delay" alone is called out as too thin.2 FDA also recommends updates about every two weeks until the situation is resolved, even if nothing has changed.2 Other reports do not count: a field alert report or a marketing status report is no substitute.2
6 mo
before the interruption or discontinuance, where it could reasonably be foreseen.1
21 CFR 314.81(b)(3)(iii)(b)
5 days
business days after it occurs, the outer limit for a finished product when six months was not possible.1
Also 21 CFR 600.82(b) for biologics
2 wks
between updates, FDA's recommendation until the situation is resolved, even with no change.2
February 2024 draft, not binding
05 · The EU rules
EU shortage reporting: Article 23a, national rules and the European Shortages Monitoring Platform
In shortEvery EU holder tells the national regulator, under national rules that vary. Holders of centrally authorized medicines also report to EMA through the ESMP, as soon as they become aware of a potential or actual shortage, and have had to since February 2, 2025. Nationally authorized medicines enter the ESMP only in a crisis or a preparedness action. Two months' notice is the expected minimum, and most notices to EMA come on or after the start date.
Three layers apply at once. The Directive on medicinal products, 2001/83/EC, says in Article 81 that holders should ensure appropriate and continued supply, within the limits of their responsibilities, and in Article 23a that a holder must notify a member state if a product ceases to be placed on its market, temporarily or permanently, other than in exceptional circumstances no less than two months before.13 National laws add to that. Regulation (EU) 2022/123 adds the European platform.14
The Directive's wording leaves room for argument. The European Commission reads Article 23a as covering shortages, while some member states say it does not refer specifically to them, and 21 of 31 national regulators reported a separate national requirement in a 2022 survey.15 Almost all member states use their own definitions.15
The shared definition, in Regulation 2022/123 and quoted by EMA, is a situation in which supply of an authorized medicine does not meet demand at a national level, whatever the cause.3 The 2019 guidance from EMA and the Heads of Medicines Agencies (HMA), the network of national regulators, asks holders to report every current and anticipated shortage, regardless of the medicine's clinical importance or available alternatives.13
Mode
Which medicines
Who reports to EMA
When
Normal circumstances
Centrally authorized medicines, in any EU/EEA country except Northern Ireland, whether or not on the Union list.3
Holders, through their single point of contact.
As soon as they become aware of a potential or actual shortage. Keep updating until resolved.3
MSSG-led preparedness
A subset chosen by EMA's executive steering group on shortages (MSSG), including nationally authorized medicines.16
Holders and national regulators.
The MSSG sets scope and frequency, and EMA emails the contacts first.16,3
Crisis
The critical list for a public health emergency or major event, including nationally authorized medicines.16,14
Holders and national regulators.
When the Commission recognizes a crisis, at the frequency the MSSG sets.16
EMA's first functions for routine reporting went live on November 28, 2024, the full set on January 29, 2025, and the transition ended on February 2, 2025.16,3 Reporting works through a template or machine-to-machine.17 Each holder had to name an industry single point of contact, or i-SPOC, by September 2, 2022.18 Your own national duties carry on beside all this: EMA says so twice in one FAQ.3
"Potential shortage" has no harmonized EU definition yet. EMA's working description is plain: if a holder foresees the possibility of a shortage of a centrally authorized medicine in a particular market, it should report it. A working party is still discussing a definition.3 So the question to put to regulatory affairs is whether you foresee the possibility, which is a lower bar than whether a stock-out remains after your plan.
What national shortage rules ask, in six EU countries
Country
Notice
Medicines and condition
Italy
4 months before any supply interruption
All medicines
Netherlands
Immediately, at least 2 months in advance
All medicines, if not all orders can be delivered within 14 days
Belgium
As soon as possible, at the latest on the day of unavailability
All medicines
Germany
Immediately
If a shortage could disrupt patient care
France
On becoming aware of a risk of stock disruption
Medicines of major therapeutic interest
Austria
Immediately
Prescription-only medicines, unavailable for over 2 weeks
The European Court of Auditors' examples, Figure 5, based on the CHESSMEN joint action.15 Check each country's current text before relying on it.
How late the EU's notices actually arrive
The European Court of Auditors looked at timeliness and found that most shortages were not notified two months ahead. For notifications to EMA, 55.9% came on or after the start date.15 It also noted shortages never notified at all, and that this leaves EMA without timely, complete and comparable information.15 EMA has no penalty to apply: its FAQ says there are currently no penalties for late reporting.3 National regulators can have them, and 18 of 30 EEA countries provide for sanctions, of which 8 have applied them.15
More than half of the shortage notices EMA received came on or after the start date
56 in 100
notifications to EMA arrived on or after the shortage's start date: 55.9%, centrally authorized medicines, May 2023 to October 2024
Shortage plans on the way: the EU pharma package, the Critical Medicines Act and rules elsewhere
In shortNeither EU law has passed. The Council's text of the pharmaceutical regulation sets six months' notice of a temporary disruption of more than two weeks and requires a shortage prevention plan for every prescription medicine, handed over within two days of a request. It would apply six months after entry into force, much sooner than the rest of the package. EMA is already telling companies to prepare.
The Council adopted its first-reading position on the pharmaceutical package on September 28, 2026, and Parliament's file reads "Awaiting Parliament's second reading", with no final act.19,20 The text can still change. Readers should note one detail that most summaries miss: while the regulation generally applies 24 months after entry into force, the Council text applies Articles 120 to 132, the shortage chapter, six months after entry into force.19 EMA's guidance page tells holders to be ready before a legal deadline "expected from mid-2027".18
Council text, Article
What a holder would have to do
Today's position
120(1)(a), (b)
Notify a permanent cessation or a withdrawal request at least 12 months before the last supply.19
Notify a temporary suspension, or a temporary disruption expected to last over two weeks, as soon as possible and at least six months ahead. In exceptional circumstances, as soon as you become aware.19
As early as possible, and two months under the Directive and guidance.13
121
Keep an up-to-date shortage prevention plan for prescription medicines and others the Commission identifies. Submit it within two days of a request.19
Good practice; the new guidance anticipates the duty.21,22
122, 123
Prepare a shortage mitigation plan when a regulator asks, and a documented risk assessment for products without a prevention plan.19
Guidance only, revision planned for the fourth quarter of 2026.18,23
EMA and the national regulators have already published the means. The prevention plan guidance, EMA/160238/2026, dated July 17, 2026, says plans will not be routinely filed, may be grouped by common supply chain, and may form part of the annual product quality review.21 The mitigation plan guidance, from September 2024, says companies should keep a record of root causes and measures after each shortage ends.23
ICH's revised quality risk management guideline, Q9(R1), added a section in January 2023 tying risk work to product availability, on the view that quality and manufacturing issues are a significant cause of shortages.24
The Critical Medicines Act is a separate file, aimed more at where medicines are made and how they are bought. Negotiators reached a provisional agreement on May 12, 2026, member states' ambassadors in Coreper endorsed it on June 30, and Parliament's public health committee approved it on July 14. As of November 3, 2026 it has no final act.25,26 Treat it as coming, and check for publication.
The Union list of critical medicines, version 2.1 revision 1, was last updated on January 19, 2026, and EMA says holders' further duties for listed products will come through the new legislation.27
The EU's shortage duties are tightening in stages, with the largest step still unapproved
Feb 2, 2025ESMP mandatory for centrally authorized medicines
Transition ends.
May 12, 2026Critical Medicines Act provisional deal
Formal adoption still to come.
Jul 17, 2026New prevention plan guidance
EMA/160238/2026, published in August.
Sep 28, 2026Council position on the package
Articles 120 to 132: six months after entry into force.
Nov 3, 2026Status today
Awaiting Parliament's second reading, with no final act.
Mid-2027EMA's expected deadline for prevention plans
Six months; else as soon as practicable, and five business days for a finished product.1
Statute and rule, draft guidance
EU member states
National regulator; EMA for centrally authorized medicines
Two months and as early as possible; national rules vary.13,15
Directive, regulation, guidance
United Kingdom
Department of Health and Social Care
At least six months, or as soon as reasonably practicable.28
2018 regulations, published data
Canada
Public shortage website
At least six months before an anticipated shortage; else within 5 calendar days of becoming aware. Actual, unanticipated shortages: within 5 calendar days.29
Regulations, with a draft guide for consultation
Volume gives a sense of the workload. UK companies filed 989 notifications in 2021, 1,608 in 2022 and 1,629 in 2023, and 1,013 in the first half of 2024, counting both potential and confirmed issues.28
UK medicine supply notifications passed 1,600 a year, and more than 1,000 in the first half of 2024
Notifications to the UK health department, potential and confirmed. Monthly data summed by us. 2024 covers January to June.
Which supply indicators warn of a shortage first: holds, delay notices, shipment exceptions and demand
In shortManufacturing and quality problems lead every published cause list: 62% of FDA's 163 sampled drugs, 50.6% of 83,266 EU notifications. A shortage rarely announces itself in one place. Its warnings sit in the planning export, the quality system, a shared mailbox and a shipment feed, and the most useful one is often an email.
FDA's task force looked at 163 drugs that went into shortage between 2013 and 2017, and 62% did so after supply disruptions tied to manufacturing or product quality problems.30 National regulators analyzed 83,266 EU notifications from 24 countries for 2022 and 2023 and put manufacturing issues at 50.6%, with quality issues counted separately at 2.6%.15 The two studies sort causes into different categories, so their percentages cannot be compared or subtracted.
Many US shortages come with no stated reason. In the ASHP and University of Utah data for 2025, 59% of shortages had a cause that was unknown or not given.6 A buyer of your medicine often cannot tell why, and neither can a regulator unless you say so.
Manufacturing issues lead the causes EU regulators recorded, at just over half
Root causes of 83,266 shortage notifications, 24 EEA countries, 2022 to 2023
One common source of trouble spreads beyond a single product. EMA's guidance gives the example of a single manufacturer contracted to make products or active substances for several holders, where one manufacturing issue reaches well past one product, and of a general issue such as a temperature excursion at a wholesaler touching more than one medicine.13 A warning process has to ask "what else came from there?" every time.
08 · Weeks of cover
Weeks of cover and stock-out dates, worked through on 16 weeks of a German pen
In shortStart with stock on hand. For each coming week add receipts you can rely on and subtract demand. The first week below your safety stock is the warning, the first below zero is the stock-out, and stock divided by that week's demand is cover. The arithmetic takes minutes. The work is deciding which receipts you can still rely on.
Here is the fictional case with every figure, so you can follow the steps. The pen sells 3,100 units a week in Germany. Safety stock is two weeks of forward demand: 2 × 3,100 = 6,200 pens. A regional tender adds 18% from November 2: 3,100 × 18% is about 560, so demand becomes 3,660 a week. On hand on October 7 are 19,800 pens.
The first step takes out what you cannot count. Lot VLT-P-2611, 6,000 pens, is on QA hold, and its receipt moves to December 7 as 5,400 pens after the investigation. Shipment SH-77421, 3,800 pens, is quarantined after its logger read 9.4 °C for 47 minutes, so it counts as zero until QA decides. The tender adds 560 a week.
Then the delay notice moves lot 2614, 6,000 pens, from a November 20 ship date to December 14. Add the four: 6,000 + 6,000 + 3,800 + 2,800 (the tender's first five weeks at 560) = 18,600 pens short against plan.
One delay notice turns a dip below safety stock into a stock-out on November 30
Projected stock in Germany at each week's end, in thousands of pens. Safety stock is 6.2 thousand. The chart shows the fictional case, using the receipts and demand on its screens.
Original planIf nothing is doneWith the approved plan
-100102030
Oct 12Oct 26Nov 9Nov 23Dec 7Dec 21Jan 4Jan 18
Fictional example from this guide
Show the numbers
Original plan
If nothing is done
With the approved plan
Oct 12
16.7
16.7
16.7
Oct 19
17.4
13.6
13.6
Oct 26
20.3
10.5
10.5
Nov 2
17.2
6.84
11
Nov 9
20.1
9.18
13.4
Nov 16
17
5.52
15.1
Nov 23
19.9
1.86
11.5
Nov 30
16.8
-1.8
7.8
Dec 7
19.7
-0.06
10.1
Dec 14
16.6
2.28
6.48
Dec 21
20.9
6.02
10.2
Dec 28
17.8
2.36
6.56
Jan 4
22.1
6.1
10.3
Jan 11
19
2.44
6.64
Jan 18
23.3
6.18
10.4
Jan 25
20.2
2.52
6.72
Now read the line. Stock first drops under 6,200 in the week of November 16 (5,520). It first goes below zero in the week of November 30 (−1,800). Cover at that low point is −1,800 ÷ 3,660, or −0.5 weeks. From October 7, November 30 is 54 days, or 7.7 weeks.
The plan is the same arithmetic again with different receipts. Moving 4,200 pens from two other countries adds them in the week of November 2. A faster QA release brings 5,400 pens to November 16 from December 7. Air freight brings lot 2614 to the week of December 7. Stock now stays above zero and above safety stock, with its lowest point 6,480 pens on December 14, or 6,480 ÷ 3,660 = 1.8 weeks of cover.
Decisions the projection cannot make for you
Whether held stock countsA cautious projection counts held and quarantined stock as zero until QA decides, then adds it back at QA's date. Counting it early makes the projection look safer than it is.
What cover meansCover at today's demand and cover at next month's demand can differ by weeks, so state which you used. Most companies use forward demand.
Where stock is countedA national number can hide regional gaps, and EMA's definition looks at the national level and sets short, regional logistics problems aside.13 Your market team will care about both.
What happens to a donor marketMoving pens to Germany lowers cover in the Netherlands and Austria. Rerun their projections before you sign, and keep each above its own floor.
09 · The decision and who signs
Who decides on a shortage plan, and who signs the FDA or EU notification
In shortTwo decisions, two owners. Supply decides what to do about the gap. Regulatory affairs decides whether the law requires a notice, and it files. Neither FDA nor the EU names a job title: FDA holds the applicant solely responsible, and the EU holds the marketing authorization holder responsible through its single point of contact. Write down who signs what before the first alert.
FDA's draft says the applicant alone is responsible, whether it makes the product or a contractor does.2 The rule asks for electronic notice in a format FDA can process and sets no signatory.1 In the EU the marketing authorization holder is the responsible party, and its registered i-SPOC is the person EMA deals with.3,18 Inside a company that usually splits as shown below. No law sets this split. It is a common pattern, and your own procedures decide.
Supply signs the plan, and regulatory affairs signs the notice
A common way to divide the work. Titles differ by company.
1Confirm the risk
Is this warning real? Name the drivers, cite the records, and dismiss with a reason if it is not.
Supply continuity leadHours
2Approve the plan
Choose moves, owners and costs. A large move from a donor market gets a second signature.
Continuity lead; head of supply riskSame day
3Set release dates
Say what can be released, and when. Nobody else promises these.
QA release leadPer batch
4Decide on the notice
Does the medicine fall in scope? Is a disruption likely, or a shortage foreseen? Record the reasoning, including a no.
Regulatory affairs, counsel if in doubtAs soon as practicable
5File and update
FDA notice or email; ESMP through the i-SPOC; each national regulator. FDA asks for updates about every two weeks.
Is this warning real? Name the drivers, cite the records, and dismiss with a reason if it is not.
Supply continuity lead
Hours
Approve the plan
Choose moves, owners and costs. A large move from a donor market gets a second signature.
Continuity lead; head of supply risk
Same day
Set release dates
Say what can be released, and when. Nobody else promises these.
QA release lead
Per batch
Decide on the notice
Does the medicine fall in scope? Is a disruption likely, or a shortage foreseen? Record the reasoning, including a no.
Regulatory affairs, counsel if in doubt
As soon as practicable
File and update
FDA notice or email; ESMP through the i-SPOC; each national regulator. FDA asks for updates about every two weeks.
Regulatory affairs
Until resolved
Mitigation moves a supply team can choose, and what each one costs
FDA's list of its own tools hints at what companies can do, including reviewing expiration date extensions and expediting review of a new source.4 In a company's own hands, the usual options are below. EMA's good practice paper adds a warning: stockpiling disrupts the supply chain, so use fair distribution and avoid quiet hoarding.22 FDA defines allocation as limiting the quantity distributed to customers to extend the life of supply.2
Move
What it buys
What to check before signing
Reallocate stock between markets
Quick weeks of cover in the short market
The pack and its label must be legal in the receiving country. Donor markets keep their floor.
Prioritize a QA release
Weeks at no direct cost
Quality decides. Priority changes the order, and the criteria stay where they are.
Faster freight
Days to weeks
Cost and cold chain. For a temperature-controlled product, the shipping qualification must cover it.
Registered alternate site
A new batch
The site must be in your license for that market, and changeover takes time.
Phase deliveries or allocate
Demand moved later
Customer agreements, tender terms and fair treatment across customers.22
Ask the regulator for help
Expedited review or inspection
FDA's duty to expedite is tied to shortages under section 506C(g), which is another reason to notify early.9
The duty to notify can stand even with a mitigation plan in place. FDA's test looks at the likely effect of a production change on your own supply, and the EU's looks at what you foresee. A solid plan is useful content for the notice. If regulatory affairs concludes no notice is owed, write down why, because that reasoning is what an inspector will ask about.
10 · What goes wrong
Seven ways drug makers find a shortage too late or file the notice late
In shortThe failures are mostly ordinary: a supplier's email nobody connected, held stock still in the forecast, a reason written as "manufacturing delay". The regulators have written about several of them, and each can be tested with a look through last quarter's records.
Failure
Why it happens
How to see it in your records
The notice sits in a mailbox
Supply notices share an inbox with price lists and capacity letters. Lot numbers mean little to the person reading.
Date received against the date the plan changed, for your last 20 supplier notices.
Held stock stays in the forecast
Planning and quality are separate systems, and a hold does not move a receipt.
Every open hold: is its receipt still on its old date?
Each event looks manageable alone
Different owners see one event each. Nobody adds them up until the planning meeting.
Your last three near misses: when did the first event occur, and when did someone add them?
Waiting for a zero
Teams test for a stock-out. FDA's test is more than a negligible reduction affecting orders, and the EU's turns on what you foresee.1,3
Notices you did not file: what was the reason on record?
Nobody asked the API supplier
Third-party suppliers have no FDA duty, and contracts may say nothing.2
Do your quality or supply agreements require prompt notice of an interruption?
A thin reason
The first line of an email becomes the reason. FDA asks for more than "manufacturing delay".2
Read your last three notices as a reviewer would.
One rule set for every country
Italy, Belgium and Germany ask different things.15 A global process may meet none of them.
Who owns each national rule, and when was it last read?
Why US drug shortages so often have no stated cause
Six in ten US shortages in 2025 had no stated cause
Causes given for 2025 shortages in the ASHP and University of Utah data, as reported in AJMC
Public detail is thin, so customers and competitors plan blind, and most of the facts sit in manufacturers' own records. By our count, FDA's data fills in a reason on only 406 of the 1,153 current rows.7 A company that knows why it is short can tell a regulator what is happening, and FDA's draft asks it to go beyond a recital of broad categories.2
What the shape of the market makes worse
The medicines most exposed to this are often old and cheap. Of FDA's 163 sampled drugs, 63% were sterile injectables and 67% had a generic version, with a median of almost 35 years since first approval and a median price of $8.73 per unit in the year before the shortage.30
USP reports that 71% of drugs in shortage at the end of 2025 were sterile injectables.5 In the ASHP data, 48% of new shortages in 2026 involve sole-source products.6 For a single-source product, "your own supply" and "the market's supply" are the same thing, so a late warning leaves customers nowhere to turn.
11 · AI and its limits
What AI can do for drug shortage prediction, and what regulators expect of it
In shortReading an email and rebuilding a projection are jobs software does well, because a person can check each result against its source. Predicting market shortages from outside data is much less proven. Regulators have no shortage-specific AI rule. The draft EU GMP Annex 22 would bar large language models from critical GMP uses, so keep the batch release decision away from them, and a person signs what goes to a regulator.
"Drug shortage prediction" covers two different problems. One is forecasting whether a medicine will be short nationally, from public or pharmacy data. The published work here is modest. A Canadian study on sales from 22 pharmacies reached 69% accuracy across four shortage classes one month ahead, with a kappa, a measure of agreement beyond chance, of 0.44, and correctly predicted 59% of the most impactful shortages, with no manufacturer inventory data.31
An informal single-author analysis of about 3,000 drugs in October 2026 found machine learning did not clearly beat a simple score based on dosage form and similar features, and it warned against reading those associations as forecasts.32 We found no peer-reviewed lead-time result for a system that reads a manufacturer's own records.
The other problem is what this guide describes: a manufacturer using its own records. Here most of the answer is arithmetic on known receipts and known demand. Software adds speed and reach: reading a delay notice the minute it lands, matching a lot to the markets that depend on it, and rebuilding every projection touched. A person can verify each step. Measure it by replaying your own past events through the tool.
Text
Status, November 3, 2026
What it means for this work
FDA draft guidance on AI for regulatory decision-making
It does not address AI used for operational efficiencies, such as internal workflows or drafting a submission, that do not affect drug quality. Internal planning support sits near that line. Your use may differ, so have regulatory affairs assess it.
Says generative AI and LLMs should not be used in critical GMP applications. Reading a delay email for planning is outside batch release; check your own classification. A quality decision stays with people.
EU GMP Annex 11
January 2011 revision in force; revision still a draft.35
Applies if the system is used in a GMP-regulated activity.
EU AI Act
Omnibus in force July 27, 2026. Annex III rules from December 2, 2027; Annex I from August 2, 2028.36
Our reading: supply planning support is unlikely to be high-risk on its face. Ask counsel about your use.
21 CFR Part 11 and data integrity guidance
In force. The MHRA's guidance reads ALCOA and ALCOA+ as one expectation.37,38
Where a decision record falls under a predicate rule (an FDA rule that requires the record in the first place), it needs controls such as audit trails and authority checks. Records should stay attributable, legible, contemporaneous, original and accurate.
What stays with people when supply warnings are automated
Releasing stock
QA alone decides whether a held batch or a warm shipment can be used, and when.
Choosing the plan
Moving stock between countries is a commercial and ethical choice that needs a named signer.
Deciding on the notice
Whether a medicine is covered and a disruption likely is a legal judgment. A draft is only a draft.
Talking to regulators and customers
No software should write to an authority, a supplier or a hospital on its own.
12 · How teams do it today
How supply teams run shortage monitoring today, and where an estimated 54 hours go
In shortMost teams use a weekly planning meeting, a spreadsheet and a shared mailbox, with planning and quality systems each holding part of the picture. We found no published benchmark for how long this takes. Our own working estimate is about 54 hours from notice to signed plan, about 24 of them waiting. Time your own last three cases and replace our estimate.
Continuity lead, planner, market lead, QA, risk head and regulatory affairs: who touches a shortage
CL
Supply continuity lead
Keeps the critical list, confirms or dismisses warnings and signs plans.
Cares about: which market runs out first, and the record that says so.
SP
Global supply planner
Rebuilds the plan when a batch moves, and books alternatives.
Cares about: the date the plan breaks.
MS
Market supply lead
Handles tenders, allocations and customers in one country or region.
Cares about: tender awards counted as the supply events they are.
QA
QA release lead
Owns holds, deviations and batch certification.
Cares about: one agreed release priority for each shortage.
RK
Head of supply-chain risk
Gives second approval on large moves, and reports the trend.
Cares about: why stock moves, before it moves.
RA
Regulatory affairs
Decides on and files FDA notices and EU reports, often as the i-SPOC.
Cares about: hearing early enough to meet a five-business-day clock.
From a CMO's email to a signed plan, by hand
A delay notice crosses five desks before anyone can sign, and the first wait is the longest
A typical path, with our estimated times. These are placeholders, and no source publishes a benchmark.
1Notice arrives
Lands in a shared mailbox, often read by procurement.
Procurement or supplyUp to a day
2Matched to a market
Which lot, pack and country? What else is open?
Planner, market lead4 hours
3Projection rebuilt
Receipts moved by hand, in a spreadsheet, for 16 weeks.
Planner6 hours
4Records gathered and options found
Quality, shipment and demand records, then donor markets and freight.
Lands in a shared mailbox, often read by procurement.
Procurement or supply
Up to a day
Matched to a market
Which lot, pack and country? What else is open?
Planner, market lead
4 hours
Projection rebuilt
Receipts moved by hand, in a spreadsheet, for 16 weeks.
Planner
6 hours
Records gathered and options found
Quality, shipment and demand records, then donor markets and freight.
Planner, QA, logistics
12 hours
Decided and filed if owed
Approvals, tasks and the notice question.
Continuity lead, risk head, regulatory affairs
8 hours
On our estimate, waiting for someone to read the notice is the largest single block
54 estimated hours from one notice on a critical product to a signed plan. Replace them with your own.
54hours
Notice waits in the mailbox24 hours
Finding donors, QA priorities, freight8 hours
Approvals, tasks, notice decision8 hours
Rebuilding the projection6 hours
Matching lot and pack4 hours
Pulling the records together4 hours
Illustrative · replace with your own numbers
Show the numbers
Part
Value
Notice waits in the mailbox
24 hours
Finding donors, QA priorities, freight
8 hours
Approvals, tasks, notice decision
8 hours
Rebuilding the projection
6 hours
Matching lot and pack
4 hours
Pulling the records together
4 hours
Four ways companies organize shortage monitoring
Way
What it gives you
What it leaves out
The planning meeting and a spreadsheet
Cheap and known to everyone. It suits a small portfolio.
Hears about events days late, and depends on who is in the room.
Alerts in the planning system
Good at cover below a threshold, based on the plan.
Blind to anything not yet in the plan: emails, holds, freight.
External availability subscriptions
Market and network views, useful for hospitals and for watching competitors.
Sees your supply from outside, rarely from your quality records and supplier mail.
Software that reads your own records
Joins quality, mail, shipments and plans, and keeps the source for each driver.
Needs access to those systems, and a person must still check and decide. It cannot see what suppliers never told you.
Part B · See it working
Botminds Drug Shortage Early Warning on one German pen and one US vial, from a delay email to a signed plan and an FDA notice draft
Part A described the work without naming a product. This part shows how Botminds does it for a fictional drug company, Northwind Bio, which watches seven critical medicines across 48 product-markets, each one product in one country. Every company, person, product, lot and shipment on these screens is sample data. Software agents, each with one job, read, match, project and draft. People confirm, approve, release stock and file.
13 · One notice, start to finish
October 7: a 9:18 am delay notice moves the German Veltrimab pen from no stock-out to a stock-out on November 30
In shortLena Ortiz, supply continuity lead for Europe and International, opens the shortage radar with one unread notice from the contract fill-finisher. One click reads it, matches lot 2614 to the German pack, and rebuilds 16 weeks of stock. The risk score goes from 61 to 86, and the drivers each cite the record behind them. Six minutes later Lena signs a three-move plan.
1
The shortage radar, with one supplier notice still unread
Each sector is a product and each dot a market. The closer a dot sits to the center, the fewer weeks remain before the projected stock-out, and the dotted outer ring holds alerts with no stock-out inside 16 weeks. The 5:42 am sweep has placed all 48 product-markets.
The German pen is already open as alert A-2611, risk 61: below safety stock on November 16, lowest cover 0.6 weeks on December 14, no stock-out. Three drivers, ranked by weeks of cover lost: the QA hold (−1.7), the quarantined shipment (−1.1) and the tender (−0.8). Above the radar, a notice from Halvorsen Fill-Finish about lot 2614 is marked as not read yet.
The shortage radar. The screen opens straight on the watch list of products and markets. The German dot sits on the outer ring because no stock-out is projected yet.
2
"Read it now": the notice is read on screen and the dot moves
The notice reader reads the email and quotes the passage it relies on: the fill of lot 2614 moves from October 26 to November 16 and the ship date from November 20 to December 14. That is 6,000 pens three weeks late. It matches lot 2614 to the German pack, and the risk scorer rebuilds the projection with the receipt moved.
The result appears in place: runs out November 30, in 54 days, 7.7 weeks if nothing is done. The score rises to 86, and the German dot moves inward to the 8-week ring and turns red. The delay becomes driver 1, marked new at 9:18.
The notice read in place. The strip above the radar keeps the notice's new dates and the change in risk, with a link to the passage the agents quoted.
3
The supplier's own words, highlighted
Every driver carries a citation. Opening the delay driver shows the email as a read-only copy, with the passage the agents cite highlighted. The second highlight matters too: lot 2614 can ship on December 4 if air freight is acceptable, so the way out is already in the source.
The cited email. A furnace repair at the sub-supplier of glass syringe barrels. The agents quote dates and never paraphrase them.
4
Four drivers on the same six weeks, each with weeks of cover lost
The alert opens on the projection. Projected stock-out November 30, lowest cover −0.5 weeks, first week under safety stock November 16. The four drivers each show what they take: the delay and the QA hold on lot VLT-P-2611 at −1.7 weeks each, the quarantined shipment SH-77421 at −1.1 weeks, and the tender at −0.8 weeks. That adds up to 18,600 pens short against plan, worked through in section 08.
On the right sit the six records behind it all: the planning export row, the deviation, the delay notice, the shipment exception, the demand update and the critical product list.
The alert. The gray dashed line is the plan before these events, and red is the path if nothing is done. Red markers show the receipts lost or delayed.
5
Six options drafted, three recommended, and the stock-out gone
The mitigation planner drafts options from the network, each with an owner, a cost and the weeks it buys. The three recommended: move 4,200 pens from the Netherlands and Austria (+1.2 weeks, €14,800 freight), QA priority on the deviation to release 5,400 pens on November 16 instead of December 7 (+1.5 weeks, no direct cost), and air-freight lot 2614 (+1.7 weeks, €22,500).
With all three, the stock-out goes from November 30 to none and lowest cover from −0.5 to 1.8 weeks on December 14. Austria would give 24% of its buffer, so the screen flags a second approval for Omar Haddad, head of supply-chain risk.
Mitigation options. Three more stay unchecked, including releasing the quarantined shipment, which is QA's call, and an alternate fill line at €61,000 changeover.
6
Lena confirms the risk and signs the plan
The confirmation shows the alert, the three moves with their owners and the result: no stock-out, lowest 1.8 weeks. Lena chooses the meaning of her signature, "I confirm this supply risk and approve the plan", and enters her password. The second approval request goes to Omar Haddad with her signature, at 9:24 am.
Confirm and sign. Name, time and meaning go into the decision log with the signature.
7
Tasks go to their owners, and the alert moves to Mitigating
The decision is recorded and three tasks go out: Priya Ranvelle for the reallocation, Dana Okafor for the QA priority, Sam Patel for the air freight. The second approval waits with Omar Haddad. The alert will stay in Mitigating until cover holds above safety stock for four weeks.
The last line says no stock-out is projected, so the authority notice is not needed, and the rationale is recorded. See the next section for what to make of that line.
Plan in motion. The green line in the chart above is the approved path. Every task carries its owner and the record it came from.
The delay notice and the QA hold each take 1.7 weeks of German cover
Weeks of cover each driver removes from the German pen's projection, on the sample case
CMO delay, lot 2614 three weeks late1.7 weeks
QA hold on lot VLT-P-26111.7 weeks
Shipment SH-77421 quarantined1.1 weeks
Regional tender, +18% demand0.8 weeks
Fictional example from this guide
Show the numbers
Item
Value
CMO delay, lot 2614 three weeks late
1.7 weeks
QA hold on lot VLT-P-2611
1.7 weeks
Shipment SH-77421 quarantined
1.1 weeks
Regional tender, +18% demand
0.8 weeks
The three recommended moves take the German pen from 11 weeks under safety stock to none
Weeks of the 16-week horizon on the sample case, before and after the approved plan. Counted from the projection in section 08.
If nothing is doneWith the approved plan
Weeks ending under safety stock (6,200 pens)11 weeks0 weeks
Weeks ending below zero2 weeks0 weeks
Fictional example from this guide
Show the numbers
If nothing is done
With the approved plan
Weeks ending under safety stock (6,200 pens)
11 weeks
0 weeks
Weeks ending below zero
2 weeks
0 weeks
14 · The authority notice
The FDA 506C notice and the EU shortage report, drafted from cited records and filed by regulatory affairs
In shortEach alert has an authority notice tab. For a US alert it counts business days and drafts the 506C fields. For an EU alert it drafts the national and ESMP report. The notice writer drafts, Hannah Weiss in regulatory affairs reviews and files, and no agent writes to a regulator. Two screens need a careful reading against the rules in Part A, and the captions say so.
1
Meanwhile in the US: the Talvoren vial with two business days left
Sam Patel's alert A-2609, risk 78. On October 3 at 8:02 am, Kestrel Fine Chemicals sent a force majeure notice: an unplanned shutdown of reactor R-4 on October 2 delays API lots K-77 to K-79 by about six weeks, and the supplier does not expect more than eight. US stock of Talvoren 100 mg/10 mL vials runs out on December 21 if nothing is done.
The tab counts five business days from October 2, so due October 9, and on October 7 that leaves two. The notice writer fills the fields from the cited records: drug, applicant, type, date, reason, expected duration, whether a meaningful disruption is likely, actions and contact.
FDA 506C notice draft. The screen treats five business days as the deadline for an API supplier's outage, a cautious internal date. The statute asks for API notice as soon as practicable, with the five-day cap set for the finished product.9,2 Before filing, regulatory affairs adds the NDC, the API source and any known alternative sources, and whether an associated device is a factor, which the rule and statute ask for.1,2
2
The EU report for the German pen, before the plan
Before Lena signs, the German alert's tab shows "Now: report as soon as a shortage is likely", and the draft says yes, a shortage is likely: start November 30 if nothing is done, supply back from December 14. Medicine, holder, member state and the four reasons each cite their record. The recipients line reads "European Shortages Monitoring Platform (ESMP) · national authority, Germany".
EU shortage report draft. The ESMP takes this report only if the product is centrally authorized, which the screen does not say. The German regulator hears either way, under national rules.3,15
3
After the plan: "No notice needed while the plan holds"
Once the approved plan removes the projected stock-out, the tab changes. It shows "No notice needed while the plan holds", Its "Shortage likely?" line now reads "Not with the approved actions", the report is kept as a draft with that rationale, and the mitigation lines fill in.
Read this screen as a recommendation that regulatory affairs then tests. EMA asks holders to report a potential shortage of a centrally authorized medicine when they foresee the possibility of one.3 Germany's rule, in the European Court of Auditors' summary, is immediate notification if a shortage could disrupt patient care.15 A plan that depends on a QA release and an air freight booking is a reason to file early, with the plan attached, and update. Our view is that most teams would file a potential shortage here.
EU report after the plan. The draft stays on file with its reasoning, and Hannah Weiss can send it at any time. The decision on filing belongs to regulatory affairs.
What the US screen's meaningful disruption question tests, and what the rule tests
The screen asks "Is a meaningful disruption likely?" and answers from the projected stock-out. FDA's test is lower: a change reasonably likely to reduce your own supply by more than a negligible amount and affect your ability to fill orders or meet expected demand.1 For Talvoren, a supplier outage that removes three API lots and 17,200 vials against plan meets that test whatever the stock-out date, and the guide's advice is to file. Ask any vendor, including us, to show you how its rule for the question can be set to your company's reading.
15 · Every screen
The risk register, the supply indicators feed, the continuity dashboard and the alert rules
In shortFour more screens carry the work between alerts. The register ranks open alerts and keeps the decision log. The supply indicators screen shows everything read, matched and linked. The dashboard tracks warning time and decisions. The settings hold your alert windows, sources and approvers.
The cover horizon. Below the radar, every open alert's next 16 weeks on one screen. The German pen and the US vial both show stock-outs if nothing is done, on November 30 and December 21.
The risk register. Ranked by risk, each with its break date and owner. Exported as one file for the continuity meeting.
The decision log. Dismissals keep their reasons, for example "goods receipt not yet posted; stock physically present". An inspector can read why a warning was set aside.
A run of the watch. Four watchers read in parallel. In this run a Rotterdam port delay has no supply impact, a deviation update links to A-2611, and a packaging schedule change raises a new alert for Dravenzo 15 mg in Spain, risk 47.
Every supply indicator. Twelve records with the alert each raised or joined. A stopper supplier's price list is marked "not a supply indicator", and a monthly capacity letter has no supply impact.
The continuity dashboard. Every figure on it is the sample company's. The 7.4-week median warning and 82% confirmed are the solution's design targets; "sales protected" is the sample's own estimate.
Risk heat map. Lowest weeks of cover for each product in each market. Talvoren in the US is the only cell below zero.
Alert rules and sources. Tier 1 alerts when cover will break safety stock within 16 weeks, Tier 2 within 10; minimum score 40; Tier 1 safety stock two weeks. A rule can also be written in plain words.
Approvers. A named person per region, a second approver for moves over 20% of a market's buffer, and the person who files FDA and EU notices.
16 · Roles and sign-offs
Six agents read and draft; the continuity lead, a second approver, QA and regulatory affairs decide
In shortEach agent has one job and stated limits. None of them edits the plan, releases stock, contacts a supplier or writes to a regulator. People confirm or dismiss every alert, approve every plan, give a second approval on any move over a fifth of a market's buffer, and file every notice.
Coverage monitor
Reads the daily planning export for 48 product-markets over 16 weeks, computes weeks of cover and flags any week under safety stock or any change of more than 5% in receipts or demand. Never edits the plan; every figure cites its export row.
Quality hold watcher
Reads holds, deviations, out-of-specification results and certification queues every hour and maps each batch to the market packs it blocks. Read-only on the quality system; release dates come from QA.
Supplier and CMO notice reader
Reads the supply mailbox and pulls supplier, lot, old and new dates and quantity, quoting the passage. Unclear notices go to a person; price lists and routine letters are marked as not a supply indicator.
Logistics exception watcher
Reads the shipment exception feed every 15 minutes: excursions with the logger reading and the product's stability budget, customs holds, missed pick-ups. Never releases quarantined stock.
Risk scorer
Rebuilds each projection with at-risk receipts moved and demand changes applied, reports lowest cover, first week under safety stock and the stock-out week, and scores 0 to 100 by depth, timing and tier. Raises alerts; never confirms or dismisses.
Mitigation planner and notice writer
Drafts options with their effect, cost and owner, recommends the smallest set that holds safety stock, and drafts the FDA 506C notice or EU report. Drafts only.
Who signs at each step of a shortage alert
Decision
Who, on the sample screens
What is recorded
Confirm or dismiss an alert
The regional continuity approver: Lena Ortiz for Europe and International, Sam Patel for the Americas
Name, time, meaning, and a reason for every dismissal
Approve the plan
The same approver
The moves, owners and costs, with the projection they produce
Move more than 20% of a market's buffer
Second approval: Omar Haddad, head of supply-chain risk
A second signature before stock moves
Release held or quarantined stock
QA: Dana Okafor
QA's own record; held stock counts as zero until then
File an FDA or EU notice
Regulatory affairs: Hannah Weiss
The draft, the decision to file or not, and its reason
Change a rule
An administrator
The audit trail, with the old and new value
The records support the controls an inspector expects of electronic records where a predicate rule applies: attributable entries, audit trails and authority checks.37,38 They are controls that support your compliance; your own validation and procedures decide whether you meet it. Botminds' own security is audited under SOC 2 Type II, and its information security is managed to ISO 27001.
17 · What goes in and out
What Drug Shortage Early Warning reads from your planning, quality and logistics systems, and what it gives back
In shortIt reads what your supply already runs on: the planning export, the quality system, the supply mailbox, the shipment exception feed and your critical product list. It gives back a ranked risk register with cited drivers, alerts with drafted plans and notices, a weekly dashboard and a decision log. Your systems stay the record.
From planning and quality
Projected inventory, receipts and demand by product and market, daily
Draft notices handed to regulatory affairs, who submit them
Agents never submit
18 · Design targets
The warning time and confirmation rate Drug Shortage Early Warning is designed to reach
In shortTwo design targets, each to be measured in your own live use: a median of 7.4 weeks of warning before a projected stock-out, against a goal of six or more, and 82% of alerts confirmed by planners, with the rest dismissed with a reason. Neither is a result from a customer. Measure them on a replay of your own last quarter before you rely on them.
7.4 wks
median warning before the projected stock-out, against a goal of six weeks or more.
Design target
82%
of alerts confirmed by planners; the rest dismissed with a reason in the log.
Design target
54 days
of warning on the sample case: a delay notice read at 9:24 am projects a stock-out on November 30.
Fictional example
On the product team's estimate, the hours from notice to signed plan drop from 54 to about 3.5
Hours for one supply notice on a Tier 1 product-market, by hand and with the solution. The solution team's estimate; replace with your own timings.
Matching lot to pack and open holds4 hours0.1 hours
Pulling records together4 hours0.2 hours
Illustrative · replace with your own numbers
Show the numbers
By hand
With the solution
Notice waiting in the mailbox
24 hours
0.1 hours
Finding donors, QA priorities, freight
8 hours
1 hour
Approvals, tasks, notice decision
8 hours
2 hours
Rebuilding the 16-week projection
6 hours
0.1 hours
Matching lot to pack and open holds
4 hours
0.1 hours
Pulling records together
4 hours
0.2 hours
The time a person still spends is the time that matters: deciding the plan, signing, and deciding on the notice. The waiting time is where the estimate moves most, and it is the easiest to measure: the gap between an email's arrival and the change in your plan.
Part C · Ready to automate?
Should you automate drug shortage early warning? The cost of a late warning, your return, your readiness and a pilot
This part speaks to you, the person deciding. It covers what a shortage found late costs a drug maker, how to size the return on your own numbers, a scored readiness check, what to ask any vendor, including us, and a pilot that replays a quarter you have already lived through.
19 · What a late warning costs
What a shortage found too late costs a drug maker, and how to count your own in a week
In shortNo public source puts a price on a manufacturer's stock-out, so that figure has to come from your own records. What is published shows the scale around you: most EU notices arrive late, FDA hears about well over a thousand potential shortages a year, and US hospitals spent $894 million in labor managing shortages in 2023. Your own cost lies in lost sales, tender terms, freight, and the regulator's patience.
55.9%
of shortage notifications to EMA arrived on or after the start date, May 2023 to October 2024.15
European Court of Auditors, 2025
1,424
potential shortage situations notified to FDA in 2025, by 167 manufacturers.4
FDA, report to Congress for 2025
$894M
in US hospital labor to manage shortages in 2023, with 20.2 million hours, in Vizient's survey of 132 hospitals.39,40
Vizient; year and sample as reported by Xtalks
Hospital pharmacy staff spend more than twice the hours on shortages they did in 2019
Hours a week per general hospital spent managing shortages, Vizient survey
That hospital time is your customers' cost, and it shapes how they judge suppliers in the next tender. Your own costs sit in different places, and most of them are already in your systems.
Counting the cost of late shortage warnings in your own records
Cost
Where it hides
How to find your number in a week
Warning time
The date an event occurred against the date your plan changed
Take your last 10 supply events on critical products. Event date, plan change date, decision date: the gaps are your number.
Lost sales
Orders cut, back orders, quotas
Units short in each stock-out over the past year, times net price.
Expediting
Freight and changeover lines in the general ledger
Air freight and premium freight booked under 14 days' notice on those products.
Tender terms
Contracts with penalties for failure to supply
Penalties invoiced or credited in the past two years.
Regulatory time
Regulatory affairs' calendar and email
Notices filed, and the hours from first warning to filing for each.
Team hours
The planning meeting, spreadsheets, escalations
Ask the people involved in your last three events to rebuild their hours.
Shortage costs no return calculator counts
A public letterA missed 506C notice leads to a letter FDA posts with your answer.9 FDA has sent 11 since 2014, each posted for anyone to read.4
Lost help from the regulatorFDA expedites reviews and inspections that could ease a shortage.9 The later it hears, the less time it has.
A customer's memoryHospitals spend hours on every shortage.40 A supplier that warned them early is remembered at the next tender.
A neighbor marketA rushed transfer can create the next shortage in the donor country.
The new EU dutiesIf the Council's text becomes law, six months' notice and a prevention plan on request become legal duties.19 The records you keep now decide how ready you are.
20 · Your return
Sizing the return on earlier shortage warnings: team hours, stock-outs avoided and freight not needed
In shortThree levers carry most of the value: fewer hours turning each supply event into a decision, fewer events that become stock-outs because they are seen weeks earlier, and less premium freight because options are chosen before only the fastest remains. A fourth, notices filed on time, protects you and is hard to price, so it stays out of the total. Every default below is a placeholder for your own number.
Hours
Hours from notice to decision
Reading, matching, rebuilding the projection and gathering records done in minutes. People keep the decision.
events × hours saved × hourly cost
Stock-outs
Events that no longer become stock-outs
A warning weeks earlier leaves more options open. Uses your own estimate of the share you would catch.
events × (share today − share with warning) × cost of a stock-out
Freight
Premium freight not booked
Earlier choices let ordinary freight or a release do the work.
events × share using premium freight × freight saved per event
Notice
Notices filed on time, with a full reason
Counted as the share of notices filed inside your target. Not priced here.
notices on time ÷ notices owed
No source publishes these inputs for drug makers. Each default is marked: illustrative means an assumption of ours.
Your volume and costHoursStock-outs and freight
Illustrative yearly value
Team hours freed0
Hours, valued$0
Stock-outs avoided0
Stock-outs avoided, valued$0
Premium freight saved$0
Total, before your costs$0
Formulas: hours freed = events × max(0, hours today − hours with automation); hours valued = that × hourly cost; stock-outs avoided = events × max(0, share today − share with warning) ÷ 100; valued = that × cost of one stock-out; freight = events × premium freight share ÷ 100 × freight saved. With the defaults: 2,880 hours, $259,200; 3.6 stock-outs avoided (the calculator rounds to 4), $1,440,000; freight $360,000; total $2,059,200 a year. The stock-out line carries most of the value and the most doubt, so replace it with your own history first.
21 · Readiness check
Is your supply team ready to automate shortage monitoring? Eight scored questions and one to reflect on
In shortScore each question 0 to 2. The questions test what software needs from you: a critical list, readable records, named owners, a written rule for notices and a way to measure. A low score is useful: it tells you what to fix first, and most of it needs no software.
1
Critical product list
Do you keep a list of critical products by market, with a tier, alternatives and a safety stock policy?
Why it mattersAlert windows and priorities hang off the tier. Without it, every product shouts at once.
A strong answer"One list, owned, reviewed twice a year, used in planning."
2
The planning export
Can you export projected stock, receipts and demand by product and market every day?
Why it mattersThe projection starts from it. A weekly export means warnings arrive up to a week late.
A strong answer"Daily, by SKU and market, 16 weeks or more."
3
Quality records
Can holds, deviations and the release queue be read, with lot numbers that map to packs?
Why it mattersMost published shortages start with manufacturing or quality problems.30,15
A strong answer"Read-only access, lot to pack mapping in place."
4
Supplier notices
Do supplier and CMO delay notices reach one mailbox or portal, and do your agreements require them?
Why it mattersThird-party suppliers owe FDA nothing, so you need them to tell you.2
A strong answer"One supply mailbox, and a notice clause in each quality agreement."
5
Notice rule
Is your rule for deciding on an FDA notice and EU or national reports written down, with an owner?
Why it mattersThe legal tests differ from a stock-out test. A written rule makes the decision repeatable.1,3
A strong answer"A procedure per region, owned by regulatory affairs, reasons recorded even for a no."
6
Who signs a shortage plan
Is it clear who confirms a risk, approves a plan, and gives a second approval on a large move?
Why it mattersSoftware can draft at once. Without named signers, the draft waits.
A strong answer"Named approvers by region, a written threshold for a second approval."
7
Measuring warning time
Do you know how many weeks of warning you had on your last few supply events?
Why it mattersWithout a baseline, no pilot can show a gain.
A strong answer"Event date, plan change date, decision date for each, last 12 months."
8
IT and quality acceptance
Will IT and quality accept a read-only connection to planning and quality systems, with a validated record of decisions?
Why it mattersA tool that cannot read the quality system sees half the picture.
A strong answer"Agreed in principle, with a risk-based assessment planned."
9
To reflect on, not scored
If you had seen your last stock-out eight weeks earlier, what would you have done differently, and who would have had to agree?
Why it mattersThe answer names the decisions and signers your process has to make room for.
A strong answerSpecific moves, specific people.
What a low, middle or high shortage readiness score means
0–6
Explore
Start without software. Write the critical list, put one mailbox and a notice clause in place, write the notice rule, and time your last three events.
7–11
Ready to pilot
Replay last quarter's events on your own records, compare the warnings with when your team found out, and check the drafted notices with regulatory affairs.
12–16
Ready to implement
Go live on Tier 1 products in one region with people deciding and filing, then widen as your measures hold.
22 · Questions for any vendor
What to ask a drug shortage early warning vendor about notices, projections, the 506C clock and who signs
In shortAsk for proof on your own records. Many products watch the market from outside, and some forecast from public lists. Find out whether a tool reads your own quality records and supplier mail, how it rebuilds a projection, how it treats held stock, and how it frames the notice question. Ask us the same.
A
Reading supplier notices and quality records
A1
Read this delay email from our supplier and show me the lot, the dates and the quantity, with the passage each came from.
Why it mattersA date a tool paraphrased is a date you cannot trust.
Strong answerQuoted passages, a link to the source, unclear notices routed to a person.
A2
How do you map a supplier's lot number to our packs and markets?
Why it mattersA notice about an API lot means nothing until it is matched to the finished packs that depend on it.
Strong answerUses your own bills of material and batch genealogy, and shows the chain.
A3
What do you do with a held batch or a quarantined shipment?
Why it mattersCounting held stock is how teams feel safe by mistake.
Strong answerCounted as zero until QA releases it, then at QA's date.
B
Projections and warning time
B1
Replay last quarter on our records: when would you have warned, and when did we find out?
Why it mattersWarning time measured on your own past events is the best guide to what you will see live.
Strong answerA table of events, both dates, and the cases it would have missed.
B2
Show me the weeks of cover each driver takes, and how they add up.
Why it mattersA risk score with no arithmetic behind it cannot be challenged in a meeting.
Strong answerPer driver, cited, adding to the shortfall against plan.
B3
How many alerts will we see a week, and how many will we dismiss?
Why it mattersA system that cries wolf is switched off.
Strong answerA measured confirmation rate on the replay, with dismissal reasons kept.
C
The FDA 506C notice and EU reports
C1
When does your notice clock start, and does it treat finished products and APIs differently?
Why it mattersThe five-day cap attaches to the finished product, and the clock runs from the event.1,2
Strong answerStarts at the event, with a cautious internal date you can set.
C2
Does your notice question test for a stock-out, or for a more than negligible reduction in our supply?
Why it mattersThe legal test is lower than a stock-out.1
Strong answerConfigurable to your procedure, with the reasoning recorded.
C3
Does the EU draft know which products are centrally authorized, and which national rules apply?
Why it mattersThe ESMP takes centrally authorized products outside a crisis, and national rules differ.3,15
Strong answerPer product and market, with your rule table.
D
Sign-offs, the decision log and messages to regulators
D1
Who can confirm, dismiss, approve and file, and how is that enforced?
Why it mattersA draft plan should never move stock on its own.
Strong answerNamed roles, a second approval over a threshold, signatures with meaning.
D2
Can an inspector read why an alert was dismissed a year ago?
Why it mattersA no is a decision too.
Strong answerA decision log with reasons and an audit trail.
D3
Do your agents ever write to a supplier, a customer or a regulator?
Why it mattersThose messages carry legal weight.
Strong answerNever. They draft, and people send.
23 · A pilot
A 10-week shortage warning pilot: replay last quarter on your own records, then run Tier 1 live
In shortStart with the past. Pick a quarter with real supply events, load its planning exports, quality records and supplier mail, and see when the warnings would have come compared with when your team found out. Then run your Tier 1 products live in one region, in parallel with your current process, with people deciding.
Ten weeks from a replayed quarter to a live decision on Tier 1 products
Your teamVendor
Pick the quarter, the events and the baseline dates
Connect planning, quality and mailbox read-only
Replay the quarter and compare warning dates
Review drafted notices with regulatory affairs
Run Tier 1 live in one region, in parallel
Measure and decide
Week 0246810
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Pick the quarter, the events and the baseline dates
0
2
Connect planning, quality and mailbox read-only
0
3
Replay the quarter and compare warning dates
3
5
Review drafted notices with regulatory affairs
4
6
Run Tier 1 live in one region, in parallel
5
9
Measure and decide
9
10
Five numbers that tell you whether shortage warnings arrive earlier
Measure
How to count it
What good looks like
Weeks of warning
Median weeks from the warning to the projected break, against your baseline
More weeks than today on the same events
Missed events
Replayed events the tool did not warn on
Each one explained, usually by a record it could not read
Confirmation rate
Alerts confirmed ÷ alerts decided
High enough that planners keep reading, with every dismissal reasoned
Hours to a signed plan
From notice arrival to signature
Hours, where today it is days
Notice quality
Regulatory affairs' review of each drafted notice
Accurate fields, a full reason, nothing invented
Deeper questions for the pilot
Which replayed events would have been caught only by reading an email, and how late did those emails reach planning?
Did any warning count a held batch before QA released it?
Did any donor market fall below its own floor after a reallocation?
For each event that meets FDA's test, when did the clock start, and when would you have filed?1
Which products are centrally authorized, and did every EU draft go to the right regulators?3
Who owns the critical list and the rules when the pilot team returns to its day job?
24 · Questions, answered
506C deadlines, meaningful disruption, the ESMP and shortage prediction: common questions
In shortCommon questions about drug shortage notification and early warning, each answered on its own.
What is a drug shortage early warning system?
It is software, or a process, that watches the events that can take a medicine off the shelf and warns the supply team before stock runs out. A manufacturer's version reads its own planning exports, quality holds, supplier notices and shipment exceptions, rebuilds projected stock and ranks the risks. People then decide what to do and whether to notify a regulator.
What is FDA section 506C?
Section 506C of the Federal Food, Drug, and Cosmetic Act requires manufacturers of certain important prescription drugs and biologics to tell FDA about a permanent discontinuance, or an interruption in manufacturing likely to lead to a meaningful disruption in US supply. It covers products that are life-supporting, life-sustaining, or for a debilitating disease, and since 2020 their active ingredients. FDA's rules are at 21 CFR 314.81(b)(3)(iii) and 600.82.
What is the FDA deadline for a drug shortage notification?
A manufacturer must notify FDA at least six months before an interruption or discontinuance happens. If six months' notice was not possible because the event could not reasonably be foreseen, as soon as practicable, and for a finished product no later than five business days after the interruption occurs. FDA's draft guidance also recommends updates about every two weeks until the situation is resolved.
What counts as a meaningful disruption in supply?
A change in production reasonably likely to reduce a manufacturer's own supply by more than a negligible amount and affect its ability to fill orders or meet expected demand. Routine maintenance or an insignificant change with a quick restart is excluded. Competitors' capacity does not count, and a stock-out is not required.
Do contract manufacturers have to report drug shortages to FDA?
No, and neither do third-party API makers. FDA's draft guidance says third-party API manufacturers and suppliers are not required to, and the applicant is solely responsible whoever makes the product. Applicants should set up a process with suppliers and contract manufacturers so they hear about interruptions in time.
What happens if a company fails to notify FDA?
FDA sends a non-compliance letter. The company has 30 calendar days to explain and give the missing information, and FDA posts the letter and the response within 45 days unless it finds a reasonable basis or an error. FDA has issued 11 such letters since 2014 and none in 2024 or 2025.
What is the European Shortages Monitoring Platform (ESMP)?
It is EMA's IT platform for information on shortages, supply and demand, set up under Regulation (EU) 2022/123. Since February 2, 2025, holders of centrally authorized medicines must use it to report potential and actual shortages to EMA in normal circumstances. Nationally authorized medicines enter it during a crisis or an MSSG-led preparedness action, and national reporting always continues.
How far in advance must a shortage be reported in the EU?
The Directive and EMA's guidance ask for notice no less than two months before the interruption, other than in exceptional circumstances, and as early as possible once a shortage is foreseen. National rules vary from immediate notice to four months ahead. The Council's text of the new pharmaceutical regulation would raise this to six months for a disruption expected to last more than two weeks, but it was not law on November 3, 2026.
What is a shortage prevention plan?
A document in which a holder identifies supply risks for a medicine and the measures that reduce them. EMA's guidance of July 2026 explains what to include, and the Council's text of the new EU regulation would require one for every prescription medicine, handed over within two days of a request. In the US, section 506C(j) asks for a comparable redundancy plan for covered drugs.
Can AI predict drug shortages?
Results for forecasting national shortages from outside data are still modest: one peer-reviewed study on Canadian pharmacy data reached 69% accuracy one month ahead across four classes. A manufacturer using its own records is solving an easier problem, projecting stock from known receipts and demand, and software speeds up reading notices and rebuilding projections. Measure any tool on a replay of your own past events.
How many drug shortages are there in the US?
It depends on the counter. FDA had 93 ongoing shortages at the end of 2025 and identified 4 new ones that year. The ASHP and University of Utah count stood at 227 active shortages at the end of the second quarter of 2026, against a record 323 in early 2024.
What is weeks of cover?
Stock divided by forecast weekly demand: how many weeks supply would last if nothing else arrived. Shortage teams project it week by week, take out receipts that are at risk, and compare it with safety stock. The first week below safety stock is the warning and the first below zero is the projected stock-out.
25 · Summary and glossary
Drug shortage early warning in brief: eight steps, the 506C and EU deadlines, and 13 terms
Print this page
In shortPrint this to keep the steps, the readiness bands, the rules as they stand on November 3, 2026, and the terms at hand.
The method
Keep one critical product list by market, with tiers, alternatives and safety stock.
Send every supplier and CMO notice to one mailbox, and require notice in each agreement.
Read each notice the day it arrives, and match it to lots, packs and markets.
Count held and quarantined stock as zero until QA releases it.
Rebuild the projection; name the first week under safety stock and the first below zero.
Cite the record behind every driver, and let named people confirm, dismiss and sign.
Test the notice question against the legal test, which sits below a stock-out, and record the reason either way.
File early, file fully, and update about every two weeks until resolved.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of November 3, 2026: FDA 506C six months, else as soon as practicable, five business days for a finished product · FDA's 2024 notification guidance and 2022 redundancy plan guidance still drafts · ESMP mandatory for centrally authorized medicines since February 2, 2025 · EU pharma package awaiting Parliament's second reading, shortage chapter six months after entry into force in the Council text · Critical Medicines Act provisionally agreed May 12, 2026, not adopted · EU GMP Annex 11 at January 2011, Annex 22 a draft · EU AI Act high-risk dates December 2, 2027 and August 2, 2028.
13 terms
Section 506C
The US law requiring early notice of discontinuances and interruptions of covered drugs.
Meaningful disruption
A production change likely to cut a firm's own supply by more than a negligible amount and affect orders.
Covered drug
Prescription drug or biologic that is life-supporting, life-sustaining, or for a debilitating disease.
Non-compliance letter
FDA's letter to a firm that failed to notify, posted with the reply.
Redundancy plan
A section 506C(j) plan identifying supply risks at each site.
ESMP
EMA's European Shortages Monitoring Platform.
Centrally authorized product
A medicine licensed for the whole EU through EMA.
i-SPOC
A holder's single point of contact registered with EMA for shortages.
Shortage prevention plan
A holder's plan of supply risks and measures for a medicine.
Weeks of cover
Stock divided by forecast weekly demand.
Safety stock
A buffer kept for surprises, often stated in weeks.
CMO
Contract manufacturing organization, a firm that makes product for another.
Supply indicator
Any record that can move a projection: a hold, a delay notice, a shipment exception, a demand change.
26 · Sources
Sources
Accessed November 2026. Regulatory status statements are as of November 3, 2026. Where we could read only a trade publication's account of a source, the entry says so.
21 CFR 314.81(b)(3)(iii), discontinuance or interruption in manufacturing, Code of Federal Regulations, Title 21 revised as of April 1, 2025, the newest edition on govinfo on November 3, 2026. govinfo.gov
FDA, "Notifying FDA of a Discontinuance or Interruption in Manufacturing of Finished Products or Active Pharmaceutical Ingredients Under Section 506C of the FD&C Act", draft guidance, Revision 1, February 2024, Docket FDA-2020-D-1057. FDA's page, content current February 5, 2024, read November 3, 2026: draft, not for implementation. fda.gov
European Medicines Agency, "Frequently Asked Questions (FAQs) on the European Shortages Monitoring Platform (ESMP)", dated December 16, 2025 on its first page; EMA's listing shows a later update on February 2, 2026. Questions 1.3, 2.6, 2.8, 2.9. ema.europa.eu
FDA, "Drug Shortages CY 2025", report to Congress under section 506C-1: notifications, prevented and new shortages, ongoing shortages, non-compliance letters, expedited reviews, PreCheck. Figures 1 to 3 give the yearly counts. fda.gov
Regulatory Affairs Professionals Society, "USP: Drug shortages declined in 2025 but are lasting longer", June 10, 2026, reporting the 2025 USP Annual Drug Shortage Report on shortages FDA listed at December 31, 2025. We read this account, not USP's report. raps.org
The American Journal of Managed Care, "Active US Drug Shortages Rise for Third Straight Quarter", July 20, 2026, reporting the ASHP and University of Utah Drug Information Service count for the second quarter of 2026 and the causes for 2025. We read this account, not ASHP's own data. ajmc.com
FDA Drug Shortages data through openFDA, last updated November 2, 2026, read November 3, 2026: 1,153 rows with status Current. Each row is one package, and openFDA warns that its data is unvalidated. Our counts. api.fda.gov; FDA's own list: accessdata.fda.gov
Federal Food, Drug, and Cosmetic Act, section 506C, 21 U.S.C. 356c, United States Code, 2024 edition (latest amendment Pub. L. 117-328, December 29, 2022): who must notify, timing, non-compliance letters, expedited review, the definition of meaningful disruption and redundancy plans. The statute sets no five-business-day limit. govinfo.gov
21 CFR 600.82, the same notification duty for biological products, Code of Federal Regulations, Title 21 revised as of April 1, 2025, the newest edition on govinfo on November 3, 2026. govinfo.gov
FDA, page listing non-compliance letters and responses under the shortage notification requirement, content current January 18, 2024. fda.gov
FDA, draft guidance on the supply redundancy plans section 506C(j) requires, May 2022, Docket FDA-2022-D-0277, still labeled draft on FDA's page (content current May 20, 2022). regulations.gov
Heads of Medicines Agencies and European Medicines Agency, "Guidance on detection and notification of shortages of medicinal products for Marketing Authorisation Holders (MAHs) in the Union (EEA)", EMA/674304/2018, July 1, 2019. It quotes Directive 2001/83/EC, Articles 23a and 81. ema.europa.eu
Regulation (EU) 2022/123 on a reinforced role for the European Medicines Agency in crisis preparedness and management, Article 13 on the European Shortages Monitoring Platform. publications.europa.eu
European Court of Auditors, Special Report 19/2025, "Critical shortages of medicines: EU measures were of added value, but structural problems remain", September 2025: paragraphs 30 to 36, Figures 5 and 6, Annex II. eca.europa.eu
European Medicines Agency, "European Shortages Monitoring Platform (ESMP)", read November 3, 2026: launch dates and the three reporting scenarios. ema.europa.eu
European Medicines Agency, "European Shortages Monitoring Platform (ESMP): informational brief", December 2025. ema.europa.eu
European Medicines Agency, "Medicine shortages and availability issues: guidance for companies", update log to August 6, 2026, read November 3, 2026. ema.europa.eu
Council of the European Union, position at first reading on the proposed pharmaceutical regulation, document 7105/2/26 REV 2, September 28, 2026, Articles 120 to 123, Annex IV and the final provisions. A Council text, not law. data.consilium.europa.eu
European Parliament, Legislative Observatory, procedure 2023/0131(COD), read November 3, 2026: awaiting Parliament's second reading, no final act. oeil.europarl.europa.eu
European Medicines Agency, "Guidance for industry on implementing Shortage Prevention Plans (SPP)", EMA/160238/2026, July 17, 2026. ema.europa.eu
HMA/EMA task force, "Good practices for industry for the prevention of human medicinal product shortages", EMA/760980/2022, dated February 28, 2023, first published May 17, 2023. ema.europa.eu
European Medicines Agency and Heads of Medicines Agencies, "Guidance for industry on implementing Shortage Mitigation Plans (SMP)", EMA/183138/2024, September 10, 2024. ema.europa.eu
ICH, Q9(R1) Quality Risk Management, Step 4, January 2023, section 6.1 on product availability risks. database.ich.org
European Parliament, Legislative Train, "Critical Medicines Act", page dated September 20, 2026: provisional agreement May 12, 2026, Council approval June 30, committee vote July 14. europarl.europa.eu
European Parliament, Legislative Observatory, procedure 2025/0102(COD), read November 3, 2026: no final act. oeil.europarl.europa.eu
European Medicines Agency, "Union list of critical medicines", version 2.1 (revision 1), EMA/361872/2025, first published December 12, 2025, updated January 19, 2026. ema.europa.eu
UK Department of Health and Social Care, "Management information on medicines supply issue notifications", September 12, 2024: data from October 2020 to June 2024. Yearly sums are ours. gov.uk
Health Canada, draft for consultation, "Guide to reporting drug shortages and discontinuations (GUI-0120): Understanding the regulations", page modified July 31, 2026. canada.ca
FDA Drug Shortages Task Force, "Drug Shortages: Root Causes and Potential Solutions", 2019, updated February 21, 2020: 163 drugs that went into shortage from 2013 to 2017. fda.gov
Pall R, Gauthier Y, Auer S, Mowaswes W. "Predicting drug shortages using pharmacy data and machine learning", Health Care Management Science 2023;26(3):395-411, abstract. doi.org
Okafor CC, "Can AI Help Predict Drug Shortages?", Pharmacy Times, October 19, 2026, an informal single-author analysis; the author says a fuller report is in preparation. pharmacytimes.com
FDA, "Considerations for the Use of Artificial Intelligence to Support Regulatory Decision-Making for Drug and Biological Products", draft guidance, January 2025, Docket FDA-2024-D-4689; still labeled draft on November 3, 2026. fda.gov
European Commission and PIC/S, draft EU GMP Annex 22, Artificial Intelligence, consultation July 7 to October 7, 2025. picscheme.org
European Commission, EudraLex Volume 4, EU GMP guidelines, read November 3, 2026: Annex 11 at its January 2011 revision and no Annex 22. health.ec.europa.eu
European Commission, "AI Act", regulatory framework page: the AI Omnibus entered into force July 27, 2026; Annex III dates to December 2, 2027 and Annex I to August 2, 2028. digital-strategy.ec.europa.eu
21 CFR 11.10, controls for closed systems, including audit trails and the use of operational and authority checks. law.cornell.edu
MHRA, "GXP Data Integrity Guidance and Definitions", March 2018, section 3.10 on ALCOA and ALCOA+. gov.uk
Vizient, "Drug shortages" solutions page, read November 3, 2026: $894M annual labor cost and 20.2M labor hours a year for managing drug shortages. The page gives no year; the Xtalks account (source 28) gives 2023 data and 132 hospitals. vizient.com
Xtalks, on Vizient's hospital survey, June 18, 2025: nearly $900 million in labor and over 20 million hours in 2023, 132 hospitals. xtalks.com
The American Journal of Managed Care, report on Vizient's survey, June 27, 2025: pharmacy staff hours per week, 2019 and 2024 survey. ajmc.com
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