3.3 T3 Transaction Data — TI, TH & TS

The Three Transaction Documents — TI, TH, TS

DSCSA's pre-EDDS tracing backbone was a trio of documents collectively called the T3 (or "transaction data"). Each transaction in a covered product — from manufacturer to repackager to wholesale distributor to dispenser — had to be accompanied by these three pieces of information. The three are distinct, and the exam tests the distinctions precisely.

Transaction Information (TI)

Transaction Information (TI) is the data specific to a particular transaction: the product, lot number(s), date of the transaction, quantity, and similar transactional details. TI answers "what was sold, in what quantity, on what date, and in what lot." TI is generated for each sale and travels with the product as it moves downstream.

Transaction History (TH)

Transaction History (TH) is the chain-of-ownership record — the cumulative list of transactions tracing the product back to the manufacturer. TH includes the TI from each prior transaction in the chain, so a dispenser can see the full path: manufacturer → repackager → wholesale distributor → dispenser. TH answers "who owned this product, in what order, back to the manufacturer."

Transaction Statement (TS)

Transaction Statement (TS) is the seller's attestation — a statement by the seller that the product is not counterfeit, not diverted, not stolen, and that the seller is an authorized trading partner. TS is a compliance representation, not a data log. It answers "is the seller vouching for the legitimacy and authorization of this product."

Comparison Table

Methods of Transmission

T3 data may be transmitted in several forms:

• Paper — paper documents accompanying the shipment (the legacy form; permitted under earlier DSCSA phases).
• Electronic / EDI — electronic data interchange, including standardized EDI transactions used widely by wholesalers.
• EPCIS — the Electronic Product Code Information Services GS1 standard, which captures package- and lot-level event data in a structured, interoperable format. EPCIS is the standard most aligned with the EDDS package-level regime.

How T3 Flows at Each Sale

When a wholesale distributor sells a covered product to a pharmacy, the distributor provides TI for that sale, TS attesting to the sale's legitimacy, and TH that captures the prior chain (manufacturer → distributor). When the pharmacy receives the product, it must be able to access and retain these documents. If the pharmacy later transfers the product to another pharmacy in a permitted transfer, it in turn provides TI and TS for its sale and passes the TH forward.

The EDDS Nuance — Read Carefully

Under the EDDS regime, the system moves from lot-level transaction data to interoperable, electronic, package-level tracing. This changes the T3 picture in an important way:

• TI and TS still flow at each transaction — the per-transaction information and the seller's attestation remain part of DSCSA.
• TH (cumulative chain-of-ownership) is no longer required to be passed in the same way, because the package-level interoperable system allows a trading partner to query a package's full history through its package identifier rather than receiving a cumulative document with each sale.

Be precise and do not overclaim. Under full EDDS interoperability, a wholesaler may still provide TI and TS, but the historical requirement to pass the entire cumulative TH with each sale is replaced by the ability to verify package history through interoperable, package-level tracing. The exam may frame this as "T3 documents are still required" versus "package-level tracing replaces TH" — the accurate statement is that TI/TS continue, while the cumulative TH function is served by package-level interoperable tracing rather than by a passed document.

Who Provides T3, and When It Is Not Required

The obligation to provide transaction data runs with each sale of a covered product by an authorized trading partner. A manufacturer provides T3 when it sells to a repackager or wholesale distributor; a wholesale distributor provides T3 when it sells to a dispenser; a dispenser that transfers a covered product to another dispenser in a permitted transfer provides T3 for that transfer. Transaction data is generally not required for transactions involving products that fall outside DSCSA's scope (the exclusions in Section 3.1) or for transactions that qualify for a specific DSCSA exemption (such as certain intracompany or affiliated-entity transfers and limited pharmacy-to-pharmacy transfers). The exam typically tests the general rule — covered product + sale by an authorized trading partner → provide TI/TS (and, pre-EDDS, TH) — rather than the narrow exemptions, so anchor on the general obligation first.

Worked Example

A pharmacy receives a shipment of a covered product from its wholesaler. Under the pre-EDDS regime, the wholesaler's packing list/paperwork would include TI (this sale's product, lot, date, quantity), TS (the wholesaler's attestation), and TH (the cumulative chain from the manufacturer). Under EDDS, the pharmacy can scan the package-level identifier and query the interoperable system for that package's history, while still receiving TI and TS for the transaction. The shift is from "passing a big cumulative document" to "querying package-level data plus retaining TI/TS."

Exam Tip

A common distractor says "all three T3 documents are eliminated under EDDS." That is wrong — TI and TS continue. The accurate framing is that the cumulative TH function is served by package-level interoperable tracing, not that all transaction documentation disappears.