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  • 1.  Repackager / Relabeler

    This message was posted by a user wishing to remain anonymous
    Posted 27-Sep-2022 15:49
    This message was posted by a user wishing to remain anonymous

    I work for a medical device distributor in the US and our sister company (manufacturer) would potentially like us to repackage and relabel devices for them that get returned to our distribution center. Sometimes the marketing box would be damaged upon return and instead of returning the marketing box/device back to the manufacturer, and to save on shipping costs back to the manufacturer, they would send us marketing boxes/labels for us to repackage/relabel.

     

    We would not change any content of the labeling supplied from the manufacturer and would only repackage in the marketing boxes they supply to us.

     

    So, my question is – would we have to register/list as a repackager/relabeler?

     

    Thank you for any help!



  • 2.  RE: Repackager / Relabeler

    This message was posted by a user wishing to remain anonymous
    Posted 03-Oct-2022 09:14
    This message was posted by a user wishing to remain anonymous

    See definitions at https://www.fda.gov/medical-devices/device-registration-and-listing/who-must-register-list-and-pay-fee

    <main>

    Repackager - Packages finished devices from bulk or repackages devices made by a manufacturer into different containers (excluding shipping containers).

    Relabeler - Changes the content of the labeling from that supplied from the original manufacturer for distribution under the establishment's own name. A relabeler does not include establishments that do not change the original labeling but merely add their own name.

    </main>
    Sounds more like you'll simply be supplying a service to the manufacturer.


  • 3.  RE: Repackager / Relabeler

    This message was posted by a user wishing to remain anonymous
    Posted 04-Oct-2022 15:34
    This message was posted by a user wishing to remain anonymous

    In the eyes of the FDA, the answer is yes you would need to register to be able to repackage the medical devices.


  • 4.  RE: Repackager / Relabeler

    This message was posted by a user wishing to remain anonymous
    Posted 05-Oct-2022 16:37
    This message was posted by a user wishing to remain anonymous

    Anon number 3, can you supply a rationale to support that conclusion?​


  • 5.  RE: Repackager / Relabeler

    This message was posted by a user wishing to remain anonymous
    Posted 06-Oct-2022 09:10
    This message was posted by a user wishing to remain anonymous

    I appreciate the feedback.  Also, I reached out to the FDA, and they also said I need to register to repackage the medical devices.