I don't completely agree with Jay's comment.
Both, the US and EU have specific minimum requirements about what needs to be placed on device labels (c.f. EU MDR 2017/745 GSPR 23.2 and US 21 CFR Part 801). Depending on the device type there may be additional requirements e.g. from IEC 60601-1.
GS1 does recognize QR codes (although it has additional requirements for its implementation) among other variants of 1D and 2D codes (c.f. clause 5.1.1 of their specs). But for direct marking of medical devices it is specified that a data matrix shall be used as per clause 2.1.8 of their General Specifications (https://ref.gs1.org/standards/genspecs/).
Thanks, Anne LeBlanc, for your below clarifications.
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Roger Christinger
Lead RA/QM Consultant
Zühlke Group, Switzerland
www.zuehlke.com
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Original Message:
Sent: 17-Oct-2023 05:15
From: Jay Crowley
Subject: UDI Label on Medical Device itself
I agree that neither the US nor EU have rules about what information needs to go on which label.
However, note that the UDI shown is not compliant - as GS1 does not recognize QR code for UDI implementation.
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Jay Crowley
Vice President, Medical Devices and UDI Practice Lead
USDM Life Sciences
jcrowley@usdm.com
+1-805-880-2591
Baltimore MD
United States
Original Message:
Sent: 16-Oct-2023 15:22
From: Arslan Rahat
Subject: UDI Label on Medical Device itself
Can we put CE logo along with UDI label?
Just trying to remove extra step for assemblers and reducing the chances of missing CE mark labeling.
Please provide your valuable feedback from FDA and EU MDR perspective
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Arslan Rahat
QARA Manager
Toronto ON
Canada
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