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Basic UDI with GS1

  • 1.  Basic UDI with GS1

    Posted 22-Jan-2020 14:10
    Has anyone that uses GS1 as their issuing entitiy created their Basic UDI?  I am reading up on it and it seems a new number, the Global Model Number (GMN) was created for this purpose.  What I can't figure out is how to create or register the number.  Does the manufacturer define the "model reference"?

    Any info anyone has would be greatly appreciated.


  • 2.  RE: Basic UDI with GS1

    Posted 22-Jan-2020 21:40

    The Basic UDI-DI (GS1 GMN) is for a device family. It is not the same as the UDI-DI (GS1 GTIN), but the concept is similar. The manufacturer assigns the model number and combines it with the company prefix and the check digits to form the GMN. GS1 has a GMN check digit calculator at https://www.gs1.org/services/check-character-calculator

     

     



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 3.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 06:08
    Elizabeth,

    The Basic UDI-DI (B-UDI) you refer to ... and also assuming you are referring to the Basic UDI-DI from the EU MDR ... this is typically a number assigned internal to the company (at least for now).  As Dan mentioned, this is for a product or device family, it does not have to be related to the Device Identifier (DI) that is obtained from GS1.  GS1, as far as know, is the only Issuing Entity that has incorporated a new key into their system to handle this B-UDI.  The B-UDI also does not need to be incorporated into the UDI (at least for the moment) as you can just assign this an arbitrary number internal to your company and get the DI number(s) for the version/model of the device through the existing system.  If you only have one model or version this is quite easy, but if you have product families with many models, this can get a bit complicated.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
    ------------------------------



  • 4.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 08:20
    Do I understand correctly, one can assign a Basis UDI yourself to your product and not require GS1 for any input. I look for this since client has a software product going for application review by a notified body, MDR class IIa, and they indicated that a BASIS UDI is needed for starting the review. (MDR application). Can the manufacturer invent a own basic udi without the need of e.g. GS1?

    ------------------------------
    Erwin Waas
    Nuland
    Netherlands
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  • 5.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:05

    The Basic UDI-DI relates to a family of devices. In the GS1 system it includes the company number assigned by GS1, a family number assigned by the manufacturer, and two check digits assigned by a GS1 algorithm.

    For each device family, the manufacturer assigns the family number. I recommend that you use the definition of device family in ISO 13485:2016 to assign the family numbers.

    The Basic UDI-DI and the UDI-DI are both, along with other information, loaded into the EUDAMED module. The Basic UDI-DI has other uses as well.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 6.  RE: Basic UDI with GS1

    This message was posted by a user wishing to remain anonymous
    Posted 23-Jan-2020 08:56
    This message was posted by a user wishing to remain anonymous

    I struggle with the same question. For a software manufacture that currently only has a product name and version in the technical dossier, it now requires this Basic-UDI for application under MDR (Class IIa). The latter is confirmed by the Notified Body. Understand I correctly that for a basic UDI, this manufacturer can assign an inhouse number themselves and not require any external source like GS1?


  • 7.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:26

    In the GS1 system the Basic UDI-DI and the UDI-DI follow similar rules.

    Each is composed of the number GS1 assignes to the device manufacturer, a number assigned internally by the device manufacturer, and some check digits.

    The UDI-DI also have a packaging level that is not in the Basic UDI-DI.

    For the Basic UDI-DI the device manufacturer assigns a number to the family.

    For the UDI-DI the device manufacturer assigns a number to the device.

    When loading the UDI module in EUDAMED, each device includes its Basic UDI-DI and the UDU-DI.

    The GS1 assigned manufacturer number is the method to ensure both the Basic UDI-DI and the UDI-DI are unique.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 8.  RE: Basic UDI with GS1

    This message was posted by a user wishing to remain anonymous
    Posted 23-Jan-2020 08:56
    This message was posted by a user wishing to remain anonymous

    Do I understand correctly, one dan assign a Basis UDI yourself to your product and not require GS1 for any input. I look for this since a current client has a software product going for application review by a notified body and they indicated that a BASIS UDI is needed for starting the review. (MDR application)


  • 9.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:31

     

    Your understanding is not complete.

    In the GS1 system the Basic UDI-DI has three parts:
    A manufacturer's number assigned by GS1
    A family number assigned by the device manufacturer
    Check digits calculated by a GS1 algorithm

    You, as the manufacturer, build the Basic UDI-DI from these pieces.

    Remember that the Basic UDI-DI is for the device family and is is different from the UDI-DI which is for the device itself.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 10.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:53
    Thanks for all the input.  I think I understand now.

    Follow-up question.  Would it be possible or make sense to use something like the GMDN code for the model reference?


  • 11.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:59
    It is possible, as Richard's example shows, but not practical. In the EU, the GMDN codes will go away in favor of the CDN codes.

    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 12.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 09:45
    The GS1 GMN is a new key ... a new field within the UDI/barcoding system/process.  As a company, you would assign the product or family number yourself which then you would enter into the link above to get a two digit check characters for the entire GMN.  The company information is linked through the GS1 Company Prefix or GTIN number.

    The GMN is composed of the GS1 Company Prefix + Model/Product/Family number + 2 digit check - if you scroll to the bottom of the link above this is shown in graphical format.  This must be limited to 25 characters in length (though there is a discrepancy because another source in GS1 says maximum of 30 characters).  It is also a bit confusing because they call it a Model Reference, when it should be more a Family Reference.

    So to give an example for the Basic UDI-DI:
    The company's GTIN number is 00444973
    The Model/Family Reference X300LITE
    So in the Check Calculator would be 00444973X300LITE - gives a two digit 4R

    Therefore the GMN would be: 00444973X300LITE4R.

    Then thinking about the UDI-DI, say my X300 product family has 3 models in it my UDI-DI numbers.  These 3 numbers I would request from GS1 which is assigned for the GTIN + DI - it would be something like:
    - Model X300-10: 00444973010015
    - Model X300-20: 00444973010016
    - Model X300-30: 00444973010017

    My Product Family is still X300LITE for the Basic UDI-ID (or GMN designation 00444973X300LITE4R) which I would put on my EU MDR application, Technical Documentation file, Declaration of Conformity, etc.  What I found interesting was the GS1 GMN takes both alpha and numeric for the GMN.  I personally would only use numbers to keep it simple, but the GMN can handle alpha and numeric.

    The Model/Family Reference number is something the company determines, creates, and maintains for each of their product families.  As far as I can see, GS1 does not assign the Model/Family Reference because this is up to the company to define, then they input into the GS1 system.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 13.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 10:06
    Thanks.  This is very helpful.  I also noticed that the model reference is alpha numeric, so you could use just the family name for this, but for some reason I also feel like sticking to numbers is the better route.


  • 14.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 10:25
    Hello Dan

    Do you have any insights for dealing with situations where a company has multiple GS1 company prefixes, and UDI-DIs for a device family have been assigned across more than one company prefix?

    Specifically, the company I work for is a small startup that originally purchased a GS1 prefix associated with a very limited number of GTINs.  Recently, we developed a large orthopedic implant system with ~1000 new SKUs, so we purchased another GS1 prefix to be able to assign UDI-DIs to all the new devices.  But now within the same device family we have some assigned UDI-DIs with the old GS1 prefix and some with the new GS1 prefix.

    Now that I know how GS1 is recommending to assign Basic UDI-DI (GS1 GMN), I am concerned that I will need to change the assigned UDI-DIs for some of our devices to ensure that all of the devices in the same family have the same prefix.  I would me interested in your thoughts on the situation.

    Thanks tons and Best Regards!  Lauren



    ------------------------------
    Lauren Kamer RAC
    Sr. Director of Regulatory and Clinical Affairs
    United States
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  • 15.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 20:58

    The requirement for the Basic UDI-DI comes from the EU-MDR, not from GS1. All four agencies have a method for the Basic UDI-DI.

    I know of no reason why the Basic UDI-DI and UDI-DI must have the same company prefix. In your situation, I would expect a mixture inside the same family. Moreover, if you were to also involve another issuing agency, I don't see any reason why the Basic UDI-DI and the UDI-DI have to come from the same agency.



    ------------------------------
    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
    ------------------------------



  • 16.  RE: Basic UDI with GS1

    Posted 03-Feb-2020 09:49
    Good Morning Dan

    Thank you so much for your reply!  I'm glad to hear that the GS1 prefix in the Basic UDI-DI does not need to match the GS1 prefix in the UDI-DIs for all of the items in the family. 

    As Anne LeBlanc opinioned in another post on this topic (and I agree), it is certainly not "tidy", but I am glad to hear that there is some flexibility here for companies that purchase prefixes/GTINs from GS1 in small batches.  I wonder why GS1 doesn't provide an option to purchase additional GTINs under the same company prefix (assuming of course that there was sufficient capacity left)?  

    Best Regards,  Lauren

    ------------------------------
    Lauren Kamer RAC
    Sr. Director of Regulatory and Clinical Affairs
    United States
    ------------------------------



  • 17.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 15:43

    The establishment of a UDI-DI system has four steps:

    1. Establish a working relationship with an Issuing Agency (GS1) that is accepted by all countries.
    2. Develop a standardized system to create the UDI, which includes a process to generate the UDI in new product releases, a process for existing products, creating a barcode template.   If it's a liner barcode it needs to be concatenated, this is a requirement for some countries. However, it is not a requirement for the US or EU. Therefore, a 2D barcode is better specially for a device that has product labels with space constraints.
    3. Place the UDI on the label. A verification and validation process should be performed the first time to ensure that the barcode reads the DI and PI information. The barcode has to be in AIDC format and Human Readable Information (HRI) format. The UDI is required to be on the Finished Device product label, in same cases it can be on the device depending on the space available on the labels. The UDI information is not required to be on the outer box or container.
    4. The final step is to create and maintain a UDI database. Many countries have their own database, for example: US- GUDID, EU- EUDAMED, Australia- ausUDID, Japan- MEDIS-DC, Turkey – TITUBB & Importer (UTS), India- Portal of Central Gov, etc.,

    There are 10 countries that have UDI requirements: US, Turkey, Taiwan, South Korea, China, India, EU, Saudi Arabia, Australia, and Japan. The deadline for the UDI implantation it depends on the product classification.

     The UDI numbering system is the same for all the countries above. GS1 provides the DI, which includes the company location and the product identification. This is not the same as the reference number assigned by the companies.

    The basic-UDI-DI is supposed to identify the device or a group of devices.  is supposed to provide it by EUDAMED. This number is supposed to be provided when entering information into EUDAMED and it supposed to be entered into the Declaration of Conformity for each product. The basic-UDI-DI does not need to be on the product labels.

    Also, the single registration number (SRN) is a code assigned to a manufacturer, Authorized Representative etc., This code is used to register company's devices in EUDAMED database and to be able to submit assessments to the Notified Body. 

     



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    Warm Regards,
    Aurelia Brownridge
    Sr. Regulatory Affairs Specialist
    San Diego CA
    United States
    ------------------------------



  • 18.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 21:00
    Hi Lauren. Having UDIs and/or BasicUDIs with different prefixes might feel a little untidy,​ but I don't know any rule that says they have to match. They really only have to be unique, and associated with the correct manufacturer.

    ------------------------------
    Anne LeBlanc
    Manager, Regulatory Affairs
    United States
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  • 19.  RE: Basic UDI with GS1

    Posted 24-Jan-2020 16:24

    Dear Vikram,

     Let's clarify some items first.  

    • The lot number is part of the PI
    • Usually either the expiration date or date of manufacture is required, you don't have to have both of them. However, China requires both of them!
    • The catalog number and lot number are requirements for all countries, these items and there processes are not replaced by the UDI
    • The UDI is an addition to the manufacturer's process for traceability purposes to avoid or prevent injuries and to take immediate action on recalls/Field Safety Corrective Actions.
    • The AIDC is a barcode format. The meaning of the AIDC is the human readable format, which is usually placed next to the barcode
    • The date format used by the FDA is YYYY-MM-DD
    • The UDI number usually is place on the product labels, but due to space constraints it can be placed in higher labels. There is no requirement to have the UDI on the shipping container, but you can place it on the outer box, if needed.
    • Software, the DI and PI information should be on the CD and coded in the SW, so when the user plays the CD the interface should have the DI and PI information, which includes the version of the SW.
    • As far as the standards go, it depends on the agency that you select. For example: GS1 uses a data matrix that contains a special start sequence to differentiate GS1 from other ISO/IEC data matrix symbols. So, there are many choices and it is up to your company to select an agency and standards.
    • Standards/Type of barcodes, this selection depends on the company's products. There are many different types. Example: GSI-128, is a high density barcode, can provide a GTIN up to 14 digits.

     Now, the lot expiration date or use by date should be identified according to the stability studies performed for your product. Let's say that your studies performed demonstrated that your product is good for 12 months. In your system you enter the lot number and the issue date of each lot produced. If you do not have a system that can trace the used by date you can easily create an Excel spreadsheet to trace the use by date.

    There is no check to trace the use by date in the UDI. The UDI includes the company location and product information. The lot number is part of the Product Identifier (PI) and the UDI is not replacing any of the current company's processes. The UDI is an additional step that would help companies, regulatory agencies, and hospitals to trace the products.

    I recommend you read the MDR or IVDR Regulations and the US FDA has excellent training videos/materials in their website about the UDI. Good luck!



    ------------------------------
    Aurelia Brownridge
    Sr. Regulatory Affairs Specialist
    San Diego CA
    United States
    ------------------------------



  • 20.  RE: Basic UDI with GS1

    Posted 04-Feb-2020 11:46
    Aurelia,

    How do you physically generate the barcode image of the PI information?  I get the GS1 UPC, but how is the lot #, expiration date, and catalog number ​encoded into an appropriate AIDC to create concatenated barcode image?

    Additionally, can anyone recommend a consultant who is an expert in the UDI implementation?

    Thanks,

    ------------------------------
    William Coulston PMP, MS, RAC
    Quality & Regulatory Manager
    San Antonio TX
    United States
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  • 21.  RE: Basic UDI with GS1

    Posted 23-Jan-2020 23:21
    Edited by Vikram Upadhya 23-Jan-2020 23:45
    Hi Aurelia,
     Thank you for providing a clearer guidance on the UDI-DI/PI !.
    I have some question regards how the expired/lot based products may be traced based on the Use-By Indication.
    https://www.fda.gov/files/udi-label-example_1.jpg
    If, say a product has expired, or is beyond a Use-By date. how would this product be traced to the shipped Lot?. is there a specific check to be made to trace the lot with the UDI?. I see a CAT and LOT label which are not listed as mandatory. Are these traceable to GS1/EUDAMED or Manufacturer supply chain software?.

    Which Standard is applicable for numbering?.
    • ISO/IEC 646:1991, Information technology - ISO 7-bit coded character set for information interchange  IMDRF guidance Doc
    Section 6.4 Auto Identification Data Capture (AIDC) representation of UDI
    or
    • ISO 8601 DATE AND TIME FORMAT( is this US FDA specific)

    In another example we have Package and Labels for a Software CD. How would the User know a specific version of software from the UDI. The Listed UDI-DI needs to be on the outer carton/package rather than on the CD Label to know the version being shipped. Shipped Software needs to be identifiable by country/language option.
    Would a Graphic listing this option suffice?.
    Are there any details the Manufacturer has to list?.


    IMDRF Guidance: http://www.imdrf.org/docs/imdrf/final/consultations/imdrf-cons-udi-system-n48-180712.pdf 
    Ref:
    1. ICCBA does not list Expiry format
    2. GS1 UDI samples
    3. HIBCC Expiry format  does not list Dates in UDI

    Thank you for your guidance.

    Vikram Upadhya
    Tech Lead
    MDD-MDR Transition
    HCL Tech
    India
    ------------------------------



  • 22.  RE: Basic UDI with GS1

    Posted 24-Jan-2020 03:47
    Lauren,

    Just a short comment: the GMN and the UDI-DI do not have anything in relation except the GS1 Company Prefix.  For the DI portion the actual model numbers these are not linked to a Model/Family Reference number.  However, if you have multiple GS1 Company Prefix - meaning multiple GTIN for different company identities, it might be an opportunity to consolidate at some point (through the information contained in GS1 which they can help with this).  Otherwise you will probably have to keep some internal reference database to keep track of all the numbers floating around.

    ------------------------------
    Richard Vincins RAC
    Vice President Global Regulatory Affairs
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  • 23.  RE: Basic UDI with GS1

    Posted 24-Jan-2020 08:29

    There are three concepts often convolved: identification, tracking, and tracing.

    UDI provides identification only. By looking at the UDI-DI, for example, you can identify the device. Production identifiers, when used, can provide additional information.

    The UDI cannot tell where the device has been or where it is.

    The EU-MDR recitals say that UDI provides traceability but it doesn't. See recital #41.

    Chapter III includes Identification and Traceability of devices, but does not include any traceability requirements. Article 25 requires economic operators to keep records of the comings and goings of devices, but does not require UDIs in the records.

    Two analogies. When I buy books from Amazon, I get a tracking number so I can track the package from the warehouse. The tracking number does not provide the contents of package.

    A manufacturer makes 1,000 identical devices in a lot, puts them in stock, and fills orders. All the devices have the same UDI (DI + PI), but could go to 100 different customers. Knowing the full UDI does not identify which customer received which part of the lot.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 24.  RE: Basic UDI with GS1

    Posted 05-Feb-2020 09:37
    Hi William

    Generating a barcode requires a little bit of software.​

    If you search for "barcode generator" you'll find many options. Be aware that the different barcode formats are not interchangeable. The most common 2-D encoding is probably the QR code, but for GS1 UDIs the DataMatrix format is recommended.

    ------------------------------
    Anne LeBlanc
    Manager, Regulatory Affairs
    United States
    ------------------------------