Data Dictionary and List of Specification 1.3 and 1.4 Timeline update

We would like to inform you of an important update regarding the roll out planning of the Data Dictionary 1.3 and 1.4 implementation.

Data Dictionary and List of Specification 1.4.2

For the sake of clarity, and by official request from IT providers, it has been decided to issue an amendment of the List Of Specification 1.4.  This update only clarifies the technical implication of the Sequence Validation Controls described in the List of Specification 1.4 provided on October 17th 2019. These technical implications such as the implicit disaggregation controls and the Sequence Validation Grace Period have been discussed in a number of Questions and Answers documents and shared with the stakeholders.

This clerical update clarify the following elements that are directly linked to the sequence validation implementation.

  • Clarification on Implicit Disaggregation
  • Clarification on Recall processing
  • Clarification on the Sequence Validation Grace Period

Publication Date: Dec 20th 2019

Roll out Timeline

In order to simplify the overall roll out period, the functionalities described in Data Dictionary and List of Specification 1.3, 1.4 and 1.4.2 are combined in a single software update.

Following the update management rules defined in the Implementing regulation, the roll out period will be updated in order to respect the two months implementation period. The roll out period is therefore reduced to 10 days in order to maintain the overall sequence validation roll out date and the sequence validation grace period date.

  • Jan 6th 2020: QA release of version 1.4  (without validation enforcement)
  • Feb 20th to Feb 23th 2020: roll out of the Secondary repository and the Primary repositories
  • Feb 24th to Feb28th 2020: roll out of the Distributors and service providers
  • Feb 29th 2020 to March 31st: sequence validation grace period
  • April 1st: enforcement of the validation on the router and secondary repository


The implementation of the sequence validation is an important technical upgrade for manufacturers, importers and distributors. It ensures that the messages transmitted to the traceability system comply with the EU regulatory requirements. 

A 4 weeks sequence validation grace period is provided from Feb 28th 2020 to March 31st 2020. During this grace period, the Router and Primary repository will only provide warnings in case of non-compliance and still accept the messages. These warning should be used by the EO to fine tune their systems and to ensure that they comply with the new technical validation. After the end of the transition period on March 31st, the validation will be enforced.