Regulatory Open Forum

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  • 1.  Final Printed Labeling

    This message was posted by a user wishing to remain anonymous
    Posted 10-Jul-2017 14:37
    This message was posted by a user wishing to remain anonymous

    Dear Open Forum-

    For the final printed labeling (the insert that is folded and placed inside the packaging), does it need to match the SPL version that was approved 100%?  I know the text, tables and figures need to be identical, but are sponsors allowed to add artwork, such as the company logo to the printed material, which is not included in the electronic version submitted with the application?

    Thank you for your time.


  • 2.  RE: Final Printed Labeling

    Posted 11-Jul-2017 08:33
    Hi, UWtRA,

    Is this a drug, device, or combination product? 

    If this is a Class III device, the FDA will approve an application on the basis of draft final labeling. Read the approval letter carefully.  It will contain conditions upon which the approval is based.  One condition is usually that the applicant submits to FDA a copy of the final printed labeling before marketing.  This can be done in the form of a CBE supplement.

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    John Minier, RAC
    Consultant, Principal
    Minier Medical Device Consulting
    john@johnminier.com
    1(914)850-4432
    Highland Mills, NY
    United States
    ------------------------------



  • 3.  RE: Final Printed Labeling

    Posted 19-Jul-2017 15:02
    In general they should match.

    Ultimately, the final SPL version of your label is what is going to be used for posting on DailyMed. What is on DailyMed should really match what you have in the market.

    That said - it is possible for your marketed label to have some differences from your submission labeling but these should be relatively small changes (i.e., changes that could be considered annual reportable or non-reportable).

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    Brandon Stempo RAC
    Regulatory Labeling Manager
    Easton PA
    United StatesRegulatory Labeling Manager
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