Regulatory Open Forum

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  • 1.  Crowded labels with EU, UK, Swiss, etc representatives

    Posted 10-Sep-2021 16:09
    With all the new requirements for representatives in multiple jurisdictions, such as EU, UK, Switzerland, India, etc. that must be displayed on the product or packaging label, our labels are getting very tight on space.  We can't be the only ones encountering this.  What actions are others taking to meet the regulatory requirements for including the representatives name and address while not overloading your labels?  Is anyone using lack of space as a reason to move this information to the IFU only?  Any ideas and suggestions are welcome.  Thanks!

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    Kathleen Aras
    SUGAR LAND TX
    United States
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  • 2.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    Posted 11-Sep-2021 03:57
    Edited by Hannes Hyvonen 11-Sep-2021 03:58
    Good point. Couple of options could be:
    #1. Have separate configuration per each country (not optimal, mfg costs etc.)
    #2. Moving them to IFU or separate leaflet/label. Could be justifiable if very small product or limited space. (as long as allowed by regulation)
    #3. e-labelling? if device has display and/or is software, add them to "About" or "Legal & Regulatory"  -screen​​​
    #4. Using foldable package labels, e.g. encountered in cosmetics.

    Seems like world is just getting more complex and every country wants to have their own labels... some harmonization would be nice :)​

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    Hannes Hyvonen
    RA Manager at Icare Finland
    Vantaa
    Finland
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  • 3.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    Posted 11-Sep-2021 10:20
    Following...
    We have the same issue. Our operations team is really pushing to have the 5 primary languages on the label as well. We may need to increase our packaging size a bit to accommodate the regulatory and operational requirements.
    Jackie

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    Jackie Jaskula
    Regulatory Affairs Manager
    OrthoPediatrics
    Warsaw, IN
    USA
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  • 4.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    Posted 12-Sep-2021 07:54
    Hello Kathleen,

    Indeed this is getting to be a real issue and unfortunately the regulatory authorities mandating these information are not being very pragmatic ... at all.  Completely agree with Hannes there should be some harmonisation in the world for the labelling and how this is handled, but every country wants to do their own thing.  It always reminds me when FDA called their UDI database the Global Unique Device Identification Database ... GLOBAL being the key word.  Now in a couple years there are going to be minimum 6 or 7 databases UDI experts will have to update.  The concern with space on labelling is really an issue and unfortunately regulators are not providing the flexibility in the 21st century.  And indeed going against all of the mandates by governments around the world to become more "green" and reduce packaging.  I have seen packaging increasing because of need to regulatory information, UDI, etc.

    There are many ways I have seen companies addressing this, if there are packaging spaces which can be used, this is usually not an issue.  However, when there are small devices and small packaging this gets to be a large concern.  The suggestions above have been ones I have seen where companies are generally trending toward 1) separate "country configuration" of labelling or 2) switching over to e-labelling methods.  If I could comment a little further (rant maybe), I do not see why this information needs to be on the actual label itself for the product.  In fact, I think it causes more confusion than anything because the end users do not need who is the in-country representative.  Often customers call the in-country representative to file a complaint which is more frustrating for the customer because they end up hearing, "We are the authorised representative, please call ..."  This is primarily for the regulatory authorities.  U.S. FDA does it right where this does not need to be on the label, nor even on the IFU.  Where it needs to be is in the establishment registration database so the regulatory can contact the local in-country representative.  Hopefully, EU, UK, Swiss, etc., will start using some brain matter and understand it is 2021 with much available information being able to be kept in databases and not on the actual product where honestly it is not relevant.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 5.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    Posted 13-Sep-2021 02:34
    Hi all,

    Thank you all for this discussion and all your insights, I found it really useful.
    How about RFID label and maybe some info there? Anyone found it useful?

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    Aiste Simokaitiene
    Kaunas
    Lithuania
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  • 6.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    This message was posted by a user wishing to remain anonymous
    Posted 13-Sep-2021 09:46
    This message was posted by a user wishing to remain anonymous

    Hi, 

    As we were having the same issue, we contacted the MHRA (UK) with our concerns and they just replied this: "UK Responsible Person must appear on the label, or the outer packaging, or instructions for use". So this give us the option to move the information to the IFU or outer packaging. One thing there were very clear about is that the information has to have a way to contact us (tel or email address).


  • 7.  RE: Crowded labels with EU, UK, Swiss, etc representatives

    Posted 13-Sep-2021 10:33
    Edited by John Gibbs 13-Sep-2021 10:46
    Hi,
    MHRA website: https://www.gov.uk/guidance/regulating-medical-devices-in-the-uk#labelling-requirements
    states: " ... However, the name and address of the UK Responsible Person, where applicable, needs to be included on product labelling where the UKCA mark has been affixed"
    So no email or tel N°

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    John Gibbs
    Mortsel
    Belgium
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