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  • 1.  UDI - Expiration date and Batch#

    This message was posted by a user wishing to remain anonymous
    Posted 22-Feb-2024 09:08
    This message was posted by a user wishing to remain anonymous

    For a conductive gel classified as a Class II medical device in the US, which is subject to UDI requirements, I have a question. The product packaging currently includes both an expiration date and batch number, and these are also printed as part of the UDI-PI. Is it necessary to duplicate the printing of the expiration date and batch number, or can we omit this additional printing since they are already included as part of UDI-PI?

    Is there a guidance document I can refer in regards to this requirement?



  • 2.  RE: UDI - Expiration date and Batch#

    This message was posted by a user wishing to remain anonymous
    Posted 22-Feb-2024 16:49
    This message was posted by a user wishing to remain anonymous

    Additional question - what is the date format (YYMMDD or YYYY-MM-DD) should be under UDI-DI?




  • 3.  RE: UDI - Expiration date and Batch#

    Posted 22-Feb-2024 17:28

    The UDI-DI does not have a date format. However, some production identifiers do.

    There are really two issues. One is how to represent the date on label exclusive of the ADIC and HRI. The other is how to represent it in in the ADIC and HRI.

    For the regulations exclusive of the ADIC and HRI, various regulatitry regions have different requirements. For example, the US has a specified format which the EU would accept. But the EU is a little more relaxed.

    The ADIC and HRI format must meet the requirements of the Authorized Agency. In the US there are three options and in the EU there are four options.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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  • 4.  RE: UDI - Expiration date and Batch#

    This message was posted by a user wishing to remain anonymous
    Posted 26-Feb-2024 16:48
    This message was posted by a user wishing to remain anonymous

    Apologies, I mean the HRI date format under UDI-PI. Should it be YYYY-MM-DD as per US regulation?




  • 5.  RE: UDI - Expiration date and Batch#

    Posted 23-Feb-2024 11:03

    Hi Anon,

    as far as I can see, the information in the UDI-PI cannot replace the information on the label because it is drawn from it (see FDA's FAQ on UDI, A.3).

    With respect to the date format: I think the date format within the HRI portion of the UDI (if that is what you mean with "under UDI-DI") follows the rules set by the issuing agency.

    Best regards, Christoph



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    Christoph Kiesselbach
    Schrack & Partner
    Reutlingen
    Germany
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  • 6.  RE: UDI - Expiration date and Batch#

    This message was posted by a user wishing to remain anonymous
    Posted 26-Feb-2024 16:48
    This message was posted by a user wishing to remain anonymous

    Apologies, I mean the HRI date format under UDI-PI. Should it be YYYY-MM-DD as per US regulation?




  • 7.  RE: UDI - Expiration date and Batch#

    Posted 26-Feb-2024 21:51

    Anon, what kind of UDIs are you using? GTINs? HIBCs? Each has a different guidance.



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    Anne LeBlanc
    United States
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  • 8.  RE: UDI - Expiration date and Batch#

    Posted 27-Feb-2024 07:31

    Start by thinking of the information in two places. One is the text printed on the label designed for the user to read.

    The other is the UDI designed for a scanner to read. The UDI has two parts. One is the scannab;\le information, the ADIC, the other is the HRI, included as a backup to the ADIC. The format of the ADIC and the HRI is set by the issuing agency.

    Tformat of the text printed on the label is set by the regulatory authority.



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    Dan O'Leary CQA, CQE
    Swanzey NH
    United States
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