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  • 1.  Over labeling -Countries OUS

    This message was posted by a user wishing to remain anonymous
    Posted 08-Jan-2021 11:37
    This message was posted by a user wishing to remain anonymous

    Dear All,

    Have ever you had experience with over-labeling for Medical Devices? is it allowed out of the US?  (Sterile and non-steril Medical Devices)

    thank you


  • 2.  RE: Over labeling -Countries OUS

    Posted 08-Jan-2021 13:03
    Dear Anon,

    Thanks for reaching out - 

    To clarify, is your question whether over-labeling devices are allowed to move outside the US or whether they are allowed into?  This may impact the final answer for some geographies.

    Regardless - the broader questions to confirm are...why is it necessary and are there sufficient processes for identification and traceability in place?

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    Scott Bishop
    Houston TX
    United States
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  • 3.  RE: Over labeling -Countries OUS

    Posted 10-Jan-2021 23:50
    Hello Anon,

    It depends on the region, depends on what is being over-labelled, if the over-label changes any perceived safety or performance of device, etc.  Generally, I would say this is frowned upon by any regulatory agency though depends on if this is a distributor address label or if there are additional "functional" labels being added.  In some cases, when say a distributor contact label is added, sometimes this is accepted, but the question is a bit too broad to answer specifically.

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    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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