AB 2605 Summary

• Establishes separate licensing for third-party logistics providers (3PLs) as distinct from wholesalers, requiring each 3PL facility to obtain its own board license and be supervised by a licensed "designated representative-3PL" and "responsible manager."

• Reduces surety bond requirement for 3PLs from $100,000 to $90,000, while maintaining $100,000 requirement for wholesalers; allows smaller entities with annual gross receipts of $10 million or less to post $25,000 bond.

• Permits wholesalers and 3PLs under common ownership to operate at the same location if they maintain separate records, don't commingle drugs, have separate supervisory personnel, and meet other specified conditions.

• Requires manufacturers, wholesalers, 3PLs, and pharmacies to notify the State Board of Pharmacy within 72 hours if they have reasonable cause to believe a drug or device in their possession is counterfeit or subject to fraudulent transaction.

• Requires 3PLs using carriers to implement written policies ensuring carrier security obligations and verifying recipients are legally authorized to receive drugs; extends wholesaler liability for drugs in transit through 3PLs until delivery.