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.


After discussion with the different ID Issuers, Primary Providers and Economic Operators (EO) and in agreement with the European Commission and Member States, it has been recognized that the sequence validation defined in the List of Specification 1.4 requires an extensive testing and qualification phase.

In order to protect the system, and to allow the different stakeholders to complete the testing and QA activities in a sufficient manner, the following update to the timeline is announced.


  • Jan 2nd 2020, deployment in QA (1.3 and 1.4)
  • Jan 31st 2020, deployment in PROD for the Secondary repository
  • From Jan 31st 2020 to Feb 13th 2020 – roll out of the primary repositories
  • Feb 14th 2020 – roll out of the Router
  • From Feb 15th to Feb 28th – roll out of the ID Issuer and the EO systems


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.