India's QR code programme: Part 3 - how to repair and reform
Can India repair the damage that has been caused by an earlier failed programme to protect its export drug market, and now the counterfeiting debacle that is unfolding on its domestic front? This article explores that very question and offers a way forward for repair, reform and redemption.
The past few months have not been kind to India's fight against counterfeit medicines. A series of reports showed a range of medicines being targeted, including those for treatment of cancer, high blood pressure, diabetes and other serious conditions [1-5]. Collectively, this sudden spike in fake medicines across India is reported to represent nearly a 50 per cent increase since the end of the COVID-19 pandemic [6].
A damning new report from The Pulitzer Center in Washington asserts the counterfeiting problems in India have been aggravated by the government's failure to install an effective regulatory framework [7]. Around the time India launched a barcoding programme to protect its export industry in 2011, calls began to emerge that the domestic sector also needed protection [8]. A task force was convened to advise the Indian Ministry of Health & Family Welfare on how to move forward [9,10]. After a decade of consideration and consultation, the Health Ministry finally rolled out its anti-counterfeiting programme in 2023. The top 300 drugs were required to have a QR code on the package so that consumers could obtain key information on that drug and its manufacturer [11].
Despite the prolonged review process that went into the new regulation, the concerns raised in the Pullitzer report are now coming to light through a very disheartening outcome — QR codes meant to protect the public were instead being hijacked by counterfeiters and represent a serious new threat to consumers.
In this third article of the series, I first explain how those drug makers facing extreme threat can quickly repair their programme in order to protect their brand and customers. I then explain how the Indian drug protection programme can benefit from much-needed reforms that would actually deliver on its promise of public safety. It is important however to first have a brief review on why India is suddenly facing these problems.
A) Recognition — how to understand root cause of the problem
There are four distinct problems with the current Indian regulation for protecting the domestic drug supply. The first article in this series discussed these problems in detail and therefore what follows is a condensed outline [12].
1) Use of QR codes — The choice of using QR codes as the data carrier was most unfortunate because of their well-known vulnerability to multiple attack vectors [13,14]. Federal agencies in the United States, such as the FBI and FTC for example, had issued public warnings on the danger of QR codes [15,16]. The security problems were in fact so well established that it remains unclear why influential bodies such as GS1, a standards organization based in Brussels, had become such a strong advocate of using QR codes [17].
The result has been that within just eighteen months after India's programme went into effect, waves of counterfeit medicines began appearing with fake QR codes that mimicked the original version and therefore gave false assurance of safety to consumers. Fake QR codes have now been found on counterfeit drugs for treatment of diabetes [18], high blood pressure [19], blood clotting problems [20], vertigo [21] and epilepsy [22]. Of these, four products belonged to drug makers that had opted to follow the GS1 QR coding format [23].
Criminal entities have now been handed the perfect tool to mimic genuine drugs and provide an illusion of authenticity to patients through the very coding regime that was meant to protect them [24]. In fact, the counterfeiters could not have hoped for a better gift from the Health Ministry, GS1 and its enablers [25].
2) Loophole #1 | primary package exemption — There are two major loopholes in programme design that are now having a crippling effect. India's Health Ministry rightly wanted to empower consumers through this programme, for which a key requirement would have been to ensure that the customer-facing unit (CU) itself is coded so as to permit instant verification at time of purchase. The most common CU sold in India is the blister pack and therefore had become a frequent target of counterfeiters.
Several drug makers were able to successfully place QR codes directly on blister packs as well as other CUs such as bottles and vials, as shown in Figure 1, which can be found on the online portal for this article [26]. Some manufacturers however bypassed CU coding and instead opted to encode higher-level packs that contain multiple CUs. In fact, 30 per cent of Indian drug makers chose this route for medicines that were in scope for the programme.
The reason many drug companies could circumvent the benefit of CU coding is due to a serious loophole in the regulation — "… manufacturers of drug formulation products … shall print or affix Bar Code or Quick Response Code on its primary packaging label or, in case of inadequate space in primary package label, on the secondary package label …". The "primary" package is that in direct contact with the medicine, such as a blister pack. Drug companies were therefore at liberty to bypass blister coding to take the easier path of protecting the next higher package (such as a secondary carton) by claiming a lack of space on the blister [27].
3) Loophole #2 | serialization exemption — The second major loophole in the Indian programme is the absence of any requirement to uniquely number (serialise) each CU. The published mandate is entirely silent on this requirement, which is a remarkable omission. A one-to-one relationship between the buyer and product can only be created through a unique serial number, which in turn allows the buyer to receive key information on the drug and its maker on an individual product basis. It was therefore important that every product CU in scope be endowed with its own unique digital identity.
The omission of a serialization requirement allowed several companies to still comply with the mandate but entirely avoid the arduous task of CU-level serialization. Instead, these companies embedded the batch number into the QR code, which then served as the tool to recover and display drug and manufacturer data after a QR scan. The probability of detecting a fake product under a batch number lookup scheme is practically nil because of the many packages clubbed in a batch. It is therefore fundamentally unknowable whether multiple successful authentications arise due to the same QR code appearing on many fake packs or whether many different customers are authenticating its genuine packs from that same batch.
Nearly one-quarter of drug companies in India took this shortcut. And many of them also opted to bypass barcoding CUs. These two acts together allowed those drug makers to have considerable savings and yet still be fully compliant with India's barcoding regulation. Unfortunately, their conduct also placed these companies in the highest risk category because counterfeiters can target their products through QR mimicry with near total immunity from discovery.
4) False reassurance — A further drawback in the Ministry's mandate relates to another omission that allowed drug companies (and their contracted solution providers) to outright state that a drug is genuine after it is scanned. This hazard was found pretty much across the board. In nearly all cases, the drug company issued an explicit notice to the patient that the scanned drug is genuine, sort of as a certificate of authenticity.
But what happens when a consumer receives that same certificate after scanning a copied QR code on a fake drug? This is no longer a theoretical question because it is taking place right now with several batches of an anti-epileptic drug from Sun Pharma that has been recently counterfeited [28]. The illusion of authenticity and the false reassurance associated with it represents a highly dangerous outcome. There is nothing worse than for a patient to believe that a genuine drug is being consumed when in fact it is a fake variant [29].
B) Repair — how to immediately protect drugs in extreme risk category
The preceding section summarised key elements of Part 1 of this article series that was devoted entirely to flaws in India's ill-conceived regulatory framework, which then set the stage for exploitation by criminal entities.
The counterfeiters however are also receiving help from a very unlikely source — the Indian drug industry itself. In Part 2 of this series, I analyzed how drug makers had complied with the mandate by running each company through an assessment matrix that covered several key risk properties. The outcome of that analysis led to the companies being placed in one of four threat categories [30].
It turned out that several drug makers, including some of the largest multinational companies in the world, have complied with India's coding mandate in the worst manner that will further enable counterfeiters and bring immense harm to the Indian people. In other words, these companies capitalized on the intrinsic weakness and loopholes in the Indian mandate by taking a coding approach that has now produced substantial jeopardy to their patients.
1) Companies at the highest threat level — Nearly one-third of the 47 drug companies assessed in Part 2 opted to take a coding approach that placed them in the extreme risk category. These companies, which are shown in Table 1 below, are the focus of discussion in this Section B.
Recall the four fatal qualities of the Indian regulation outlined in Section A above. Of these, drug makers had no choice but to follow the first requirement — use of QR codes. Beyond that, the drug industry was given considerable latitude as to how it followed the mandate and whether it took advantage of two key loopholes related to primary package barcoding and unique number serialization.
The companies listed in Table 1 implemented their QR coding programme by embracing these two loopholes in the worst way possible.
1) A convergence of poor choices — A common feature of companies in the highest threat category is avoidance of serialised (unique number) barcoding. Most companies instead placed the batch number in the QR code. Furthermore, these drug makers did not place the QR code on the CU but rather the next higher package. A summary of these twin shortcuts across the various companies is given in Table 2, found in the online portal [31].
It is important to understand the extreme danger that both these shortcuts present to consumers, and why. Two specific drug makers highlighted in Table 1 — Dr. Reddy's Laboratories and GSK — are used as exemplars for this discussion, with the qualification that the same threat applies equally to the other listed companies as well. The various panels in Figure 2 will be used for this discussion.
The antibiotic Augmentin is owned by multinational giant GSK, which opted to comply with India's mandate by placing the required QR code on the secondary carton and not the blister pack (Figure 2A). The blister in this case serves as the CU in India, and ten of those are packed into each secondary carton. Dr. Reddy's also took the same approach for its anti-inflammation drug Ketorol, i.e., only the secondary carton containing multiple blisters displayed the QR code (Figure 2B).
This act by both companies creates a dilemma — a patient cannot scan the QR code at time of purchase, which was a key goal of India's programme, because it is absent on the CU. And it is a certainty that no patient will ask to see the secondary carton, which is usually discarded by pharmacists because it is used as tradable package with no further use beyond being a carrier of multiple blisters.
GSK's second decision to bypass unique number serialization and replace that with the product's batch number creates a further serious problem. A single production batch will produce many Augmentin blisters and therefore the batch number is associated with that entire lot. Scanning the QR code on a secondary carton returns a confirmatory message. GSK provides a declarative affirmation ("Verified Product") whereas Dr. Reddy's shows only the drug information required under India's mandate.
So, where is the danger in all this? The mere use of batch code-based QR coding on secondary packages presents substantial jeopardy because of the open opportunity it affords to counterfeiters to target these products. All that is needed is for the counterfeiter to obtain an original secondary package from the market and then simply replicate its QR code and place it on exact copies. No further printing is need on the fake blister CUs because the original ones are uncoded to begin with.
And this is where things become really convenient for counterfeiters because of their fortuitous ability to penetrate the market now armed with a simple means to convince retailers they are supplying the same branded medicines but at discounted prices (Figure 2C). All that a suspicious retailer is told to do is scan the QR on the secondary package and an affirmative message of authenticity will appear (Figure 2D). After all, many regulatory bodies are telling pharmacies to do just that [32,33]. The shop owner has now been duped into believing genuine medicines have been brought to him, which in turn will be transferred to consumers. There is no way out of this potential nightmare for the drug makers listed in Table 1 unless they urgently take one of three actions discussed next.
3) Safeguarding extreme risk products — The companies in Table 1 have rendered their products to be the most vulnerable in the Indian market because they took advantage of two key loopholes in the regulation. As a result, their products suffer from the twin adversities of helping counterfeiters to easily distribute fake versions (due to absence of CU coding) combined with an accompanying failure to discover them through the QR code (due to batch number coding).
There are three approaches to redemption these companies can consider. The first option is straightforward — place the QR code on CU packages and make sure those are uniquely serialised and not just batch number encoded. Many other companies have successfully achieved that goal, as evidenced by the full compliance database assembled from the study in Part 2 and given in Table 3, found in the online portal [34].
Drug makers may find however that it is too late to enforce change on their packaging lines that would require installing industrial printing, online inspection and data management systems on products for which such an operation was not envisioned. That change will not be quick due to both cost and complexity.
A second option is to transform their package format so that a single blister is packed in its own dedicated carton (so-called monocarton). GSK used to actually have Augmentin monocartons a few years back. A cartoning approach would greatly reduce the burdensome act of QR coding on blisters. The need for online printing and inspection would still remain however, which would have to be considered in addition to the additional cost of the monocarton.
The third option is the most economical and effective, and which can be quickly implemented in the least painful way into existing production lines. This approach involves placing a digital security label on each CU, which is allowed under the Indian mandate. The label must satisfy all other requirements, including placement of a QR code that can be scanned by consumers. This approach would fix the current absence of CU protection and also permit unique number serialization of each label — in essence resolving the two major drawbacks currently plaguing companies in the extreme risk category.
India is blessed with several excellent security printers and therefore fulfillment operations can be streamlined to meet short deadlines. Drug makers can either continue to work with their existing solution provider, though many security printers have strong IT programmes that can easily deliver a complete solution in line with the Ministry's mandate, thereby offering a more cost-effective integrated physical and digital product.
The drug makers in the highest threat category shown in Table 1 together produce 95 medicines that fall under the Indian barcoding mandate. Thus, nearly one-third of the drugs identified by the Ministry currently have high exposure and vulnerability to being targeted. The options outlined above need to be considered and implemented in quick order to remove the risk these companies face with regard to their corporate image, potential liability and consumer safety.
C) Reform — how to make things right for Indian consumers
The Indian mandate to protect the domestic drug sector was developed with all good intentions. Its flawed design however now exposes the public to even greater threats than before because of the ease with which counterfeiters can place replica QR codes on fake products and then take advantage of their remarkable luck — neither consumers nor inspectors can use the barcode to detect their accomplishment. These facts inflict a need to re-evaluate the entire programme and undertake immediate curative action [35-37].
The reparative steps described in Section B above are meant to provide urgent relief to the most vulnerable drug makers so that their brands and consumers can be protected. However, that is not a long-term fix nor will it remove the substantial danger that open format QR codes bring to this programme on all the other products. Instead, what is needed is for the Ministry to fully apprehend the flaws described here and proceed to undertake true programme reform with care, urgency and aplomb. The singular objective should be to create a new framework that will truly protect Indian citizens.
This section outlines some best practices to guide the creation of an effective and durable new drug protection programme for the nation. The goal here is not to provide detailed technical specifications but rather an outline of ten guiding principles that should be considered for undertaking meaningful reform.
1) Develop a programme based only on authentication — A common misunderstanding in many circles is that a drug traceability programme (Track and Trace) is needed in India to stem the flow of counterfeits, an idea that has been forcefully promoted by GS1 [38,39]. Such advocacy is simultaneously naïve and dangerous because it fails to take into account the substantial challenges that a country like India would face in installing a full traceability programme. This fact is supported by the catastrophic failure of India's effort to do just that for its export drug programme [40; article starts on page 10].
It appears that India's Health Ministry may have been aware of this problem and therefore designed the current domestic programme around an authentication framework [41]. A future reform of India's programme must retain the current authentication design, with outright rejection of any effort to install a Track and Trace component [42]. A purely authentication-based solution is far more effective and economical, and will continue to be the right approach for India.
2) Focus on consumer empowerment, but also engage other stakeholders — Authentication programmes are most effective when people use it, and therefore the more persons engaged in verifying medicines, the greater the success. One way to ensure that outcome is to develop a digital verification programme with maximum access in mind. That was precisely the objective of the current programme and therefore this approach must also be retained but substantially improved, as taken up in the upcoming sections here. Additionally, there should be empowerment of agents and inspectors by supplemental means of verification through use of covert security features.
3) Create a programme based on security labels — The current programme requires printing of QR codes on different package formats such as blisters, carton, bottles and vials. The variability in package type, content, colour and structure make it difficult for consumers to find the QR code (see Figure 1 in the online portal; ref. 26). Consequently, it becomes challenging for consumers to interact with a QR code on the package where many times it is barely scannable due to poor print contrast, foil knurling, specular reflection or other reasons.
Security labels, on the other hand, are comparatively immune to readability problems because they provide a stable and defined surface for all packages. Ease of recognition by consumers is also a key feature — labels provide a salient and predictable element that can be easily identified and interacted with on virtually any package type. Together, these characteristics would help to increase consumer engagement with the product.
There are additional benefits to this approach. First, a label-based programme is much easier to deploy, especially with the many drug makers who are yet to be drawn into the programme and therefore have not procured industrial printing equipment, vision inspection, etc. The only requirement for them would be to obtain and apply the labels, which can be undertaken manually or in an automated fashion on high-throughput lines.
Second, in addition to bypassing the need for expensive equipment acquisition, operating expenses for equipment maintenance and support is also removed. Consequently, there is cost parity across all drug makers, small and large. A label programme would create a defined unitary cost per item and therefore all companies regardless of size and wealth would pay the exact same amount per product. As the Indian programme grows, many more drug makers would be brought in and therefore face a huge capital and operational cost that had previously been a source of great concern [43].
And finally, security labels allow integration of additional security features that is just not possible with barcodes directly printed on a package. India's programme would therefore be endowed with far greater ability to resist duplication or other forms of compromise.
Taken together, a security label approach can be more economical on an ongoing basis compared to direct printing. It will also provide a level playing field across the entire industry, and usher in participants in greater numbers from the consumer base. The result would be a far more secure programme than currently in place and whose migration can be comparatively quick and smooth, with the result of an integrated digital and physical product that offers many benefits [44].
A key component of programme revision then would be to mandate application of security labels on each saleable (consumer facing) drug package, whether it is a blister, bottle or carton.
4) Use protected barcodes — The inherent risks in India's current QR coding programme have been long known and widely covered [45]. Future reform of the programme therefore must fortify that digital element. One way to do so is to consider other barcode symbologies that are not automatically detected by native applications in Smartphones but rather require a dedicated mobile application (see next point). If QR codes must be retained, then there are now technologies that claim to protect them from duplication, though the risk will still remain for counterfeiters to embed their own links into a QR code. The good news here is that the Ministry can evaluate several worthy options.
5) Develop a national mobile application — Consumer empowerment comes with a challenge in programme design. On the one hand, it must be open enough to easily allow the citizenry across all socioeconomic levels to participate, and on the other it must be secure enough to protect against programme hijacking by the criminals.
One way to meet these twin challenges is through a mobile application that has been customised for the programme and made freely available. Indian consumers are among the most agile app users and accustomed to using them regularly on various personal tasks. A public-facing national app that is backed by the government and protects personal safety would be widely accepted.
A dedicated app would also confer added security protection because the barcode's utility is associated only with the app itself. In other words, this becomes a closed-loop environment where only the dedicated app can interact with and provide feedback to consumers after a scan. Counterfeiters would have far more limited options on how they can clone the barcode as compared to the current open-loop framework [46].
6) Choose security features judiciously — Whereas the digital element in the smart label is primarily meant for consumer interaction, there will be a need to embed additional features to fortify its security. A wide range of options is available that fall into overt and covert categories, with some even having strong forensic qualities. These additional components are meant for use by agents and inspectors. A well-designed programme would encourage consumer engagement to provide mass verification whereas an accompanying inspection component would augment market surveillance through random checks.
A well-designed programme need not have many different security layers but just those that provide high protection at low cost. It is a certainty that India's hologram industry will lobby very hard for inclusion. It would be terrible mistake to bring holograms into this programme for a number of reasons that are now well accepted [47]. Holograms are very easy to closely replicate, making copied versions nearly indistinguishable from the original. Furthermore, consumers often take the mere presence of a hologram as an assurance of authenticity even though it could easily be a copy. The problem of false reassurance is therefore re-introduced into the programme with holograms or similar products.
7) Encourage new solution providers with strong platforms — A smart label programme in India can be easily fulfilled by various security printers who have developed both competence and scale. Many also have strong IT platforms by virtue of participation in similar programmes in the tax stamp and other sectors. Therefore an integrated physical-digital solution is likely to be available through the printing vendors alone. In fact, it is likely that a national drug protection programme could involve multiple such printers to meet the staggering volumes in play, with all of them following technical specifications to be determined by the Ministry. This scenario would be similar to the current fulfillment of India's national ID card programme, known as Aadhar [48].
Drug companies small and large will therefore have many options beyond the small current set of solution providers that don't appear capable of handling the cyber threats that are now unfolding on India's domestic programme. The absence of a Track & Trace component in the programme also means that drug companies, especially new ones suddenly facing mandatory compliance, will not need to register into the GS1 system, thereby saving further on ongoing costs.
8) Provide detailed guidance to industry — The current regulation contains fewer than 400 words and yet is meant to guide the entire Indian drug industry into launching a major strategic programme [see ref 41; English text starts on page 10]. The absence of many key details led to confusion and opportunities for interpreting the mandate in different ways, especially via the two key loopholes — entire absence of a serialization requirement and an option to bypass coding consumer-facing packages.
Future reform must remove any ambiguities and instead outline a detailed set of technical specifications with key details of exactly how the drug makers are to execute the mandate. Repeated poor guidance from the Health Ministry will mean another lost opportunity to protect the people of India in ways that can be easily achieved if only properly communicated.
9) Design an effective rollout period — The current programme in place, which requires the top 300 selling drugs to be barcoded, has been falsely hailed as impacting a substantial portion of the market [49]. Instead, a recent excellent analysis showed that at most 5 per cent of medicines in the market are affected [50]. And given the comparatively high cost of many of the drugs on the protected list, it is a certainty that impoverished parts of India would be especially vulnerable to their counterfeit versions. A national programme must in quick order install a solution that protects far more medicines, and eventually all of them.
To achieve the goal of universal protection, it will be important to have a staggered rollout scheme so that eventually every medicine, prescription and OTC, is protected. A programme based on security labels provides advantages in this regard due to agility and speed. A uniform low cost on a per-unit level without the need for major capital expense would also help with adoption, especially in the SME sector.
The government can play a further important role by allowing the label cost to be recovered from the market. Many years ago, the National Pharmaceutical Pricing Authority of India allowed cost recovery by drug makers of up to one (1) Indian rupee if they embedded a proprietary anti-counterfeiting technology that was in vogue at the time on their packages [51]. In the case of the current programme, it is envisioned that the cost for a security label with its security features and associated IT services should be a fraction of that earlier allowance, and in line with the cost recovery that Indian drug makers have asked for [52].
10) Promote programme widely — The last point is obvious but missing from the current programme — widespread public communication about how consumers can protect themselves at the point of sale against counterfeit medicines. Is is also clear that most retailers are not even fully aware of the QR programme, which products are coded and how the programme works [53,54].
Future programme revision must therefore be accompanied by strong public promotion combined with engagement of supply chain stakeholders, most notably retailers, to convey the message to buyers. The idea here is to create a 'whole of society' programme that effectively becomes a national cause drawing in the masses to work cooperatively with health authorities to stamp out counterfeit drugs.
The success of the programme therefore boils down to simplicity — an easy to use authentication feature that is applied across all medicines and engages the populace to in turn create an extremely strong deterrence effect. Criminal entities and their supply chain enablers are now suddenly at risk of exposure due to massive community oversight. And that itself is the most compelling argument for universality of product coverage and empowerment.
D) Synthesis
The first attempt by India to protect medicines against counterfeiting focused on its export market. That programme failed due to a number of reasons and was withdrawn earlier this year [55]. The surge of counterfeit medicines in the homeland then paved the way for India's Health Ministry to create a domestic programme based on QR coding. This programme too quickly ran into predictable problems, as discussed here and in the first two parts of this series [refs 12 and 30]. The failure of both programmes has been attributed to many causes, including the oversized influence that GS1 has had in guiding both the government and drug industry, for which outstanding questions remain yet to be answered [56].
A third failure would create further embarrassment to India. But social embarrassment is not intrinsically a deadly thing. It is the cause behind that embarrassment that harms people and can even kill. Governments are slow to react unless there is a national security issue at play.
The counterfeiting plague affecting India is just that and should not be considered in any other way. Imagine if a missile from a hostile neighbour should kill a few people, something that would lead to an immediate and muscular response. India's respected Central Bureau of Investigation claimed a decade back that counterfeit medicines kill more people than terrorism [57], a fact that has only increased with the surge in fake drugs during the intervening period.
India can get this right by undertaking the needed reform to its current national drug protection programme. The objective of this article was to start that important discussion and stimulate a much-needed debate.
Now, it's over to India.
Top image by Jon Tyson on Unsplash
E) References
[1] https://ddnews.gov.in/en/health-ministry-cracks-down-on-spurious-drugs-major-seizure-in-kolkata/
[5] https://www.pharmabiz.com/NewsDetails.aspx?aid=178145&sid=3
[7] https://pulitzercenter.org/stories/massive-failures-indias-drug-regulatory-system
[8] https://indianexpress.com/article/cities/lucknow/high-court-warns-govt-against-fake-drug-menace/
[10] https://app.box.com/s/mfat4u7zf6bpm9nkfhk77gtw32x1u502
[11] https://egazette.gov.in/WriteReadData/2022/240392.pdf
[13] https://www.cyber.gc.ca/en/guidance/security-considerations-qr-codes-itsap00141
[14] https://www.ncsc.gov.uk/blog-post/qr-codes-whats-real-risk
[15] https://threatpost.com/fbi-malicious-qr-codes/177902/
[21] https://drugscontrol.org/news-detail.php?newsid=42246
[23] https://ref.gs1.org/docs/2023/QR-Code_powered-by-GS1-best-practices
[26] https://app.box.com/s/cvibxohsel98edzsemfog1v4j5lypo95
[28] https://www.expresspharma.in/a-troubling-new-development-in-indias-qr-code-saga/
[29] https://www.expresspharma.in/sun-pharma-must-immediately-declare-a-voluntary-recall-of-levipil-500/
[31] https://app.box.com/s/lyted14io150bhxp94uwbtlwguasej19
[32] https://www.pharmabiz.com/NewsDetails.aspx?aid=177847&sid=1
[34] https://app.box.com/s/hvgxsghzmphf0jxeglncl23xdysatpyb
[35] https://www.pharmabiz.com/NewsDetails.aspx?aid=178145&sid=3
[36] https://www.expresspharma.in/how-counterfeiters-are-breaching-indias-qr-code-system/
[37] https://www.forgestop.com/blog/pharma-qr-code-authentication-failure-nfc-alternative
[38] https://www.gs1india.org/blog/pharmaceutical-industry-supply-chain-risk/
[39] https://www.gs1india.org/blog/traceability-in-indian-pharmaceuticals/
[40] https://www.saffronmedia.in/eMagazines/CP/2025/CP01052025/index.html
[41] https://egazette.gov.in/WriteReadData/2022/240392.pdf
[42] https://www.pharmabiz.com/NewsDetails.aspx?aid=177022&sid=1
[43] https://www.pharmabiz.com/NewsDetails.aspx?aid=172329&sid=1
[44] https://www.pharmabiz.com/NewsDetails.aspx?aid=176750&sid=9
[45] https://www.pharmabiz.com/NewsDetails.aspx?aid=178145&sid=3
[46] https://cdn2.hubspot.net/hubfs/3844090/A%20Gift%20to%20Counterfeiters.pdf
[47] https://www.securingindustry.com/pharmaceuticals/the-case-against-holograms/s40/a9353/
[50] https://sayacare.in/blogs/can-qr-codes-protect-you-from-fake-medicines
[53] https://www.forgestop.com/blog/pharma-qr-code-authentication-failure-nfc-alternative
[54] https://www.linkedin.com/pulse/counterfeit-medicines-silent-threat-undermining-indias-ratwani-pa3gf/
[56] https://www.expresspharma.in/a-defining-opportunity-for-clarity-from-gs1/
Dr Avi Chaudhuri is an acclaimed expert in the field of anti-counterfeiting, working with both governments and the private sector. He founded The Kulinda Consortium, a global alliance of solution providers that focuses on emerging nations to protect their citizens from fake drugs.
Dr Chaudhuri is now engaged in designing anti-counterfeiting programmes for several countries across Africa, working closely with senior government officals. The Kulinda programme in Tanzania-Zanzibar rolled out in 2024 resulted in the complete elimination of counterfeit medicines within four months of launch for products on which his solution was applied.
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