FDA has released a final rule under which all medical devices will be marked with a Unique Device Identifier (UDI) that will appear on the label and package of a device which is used to identify the devices through their distribution and usage of it. UDIs should be on the device labels in both a human-readable format and a machine-readable format (e.g., a barcode) unless the rule provides for an exception or alternative. The UDI should be marked directly on the devices that are intended for more than one use and has to be reprocessed before each use.
A UDI consists two parts, Device Identifier (DI) and Product Identifier (PI), where
Device Identifier (DI) is a mandatory, fixed portion of a UDI which identifies the specific version or model of a device and its labeler. Labeler has to apply for New DI if there is any change in version or model of the device.
Product Identifier (PI) which is a conditional and variable portion of a UDI is required to identify the lot or batch number of a specific device , serial number, expiration date, date of manufacture and the distinct identification code(If applicable). PI will change for each lot or batch.
FDA has accredited the following agencies in assignment of UDIs according to the UDI regulations.
- GSI – http://www.gs1.org/
- Health Industry Business Communications Council (HIBCC) – http://www.hibcc.org/
- International Council for Commonality in Blood Banking Automation (ICCBBA – http://www.iccbba.org
Each issuing agency has a unique device identifier (UDI) format that was assessed and approved by FDA as part of its process for accrediting issuing agencies. Any changes to the format of the UDI by an issuing agency must be approved by FDA before implementation.
Device labelers are required to submit information about each device to FDA’s Global Unique Device Identification Database (GUDID), where the public can search and download information from GUDID at AccessGUDID. GUDID has a standard set of basic elements for each device with a UDI, which contains only DI that helps to get the device information in the database. Product Identifiers (PI) are not part of GUDID
Compliance Dates issued by FDA in conjunction with UDI Final Rule are
- Class III medical devices which includes stand –alone software – September 24, 2014
- Implantable, life supporting and life sustaining devices which includes stand-along software – September 24, 2015
- Class III reusable devices that are required to have UDI on the device itself, Class II devices – September 24, 2016
- Class II reusable devices that are required to have UDI on the device itself, Class I which includes stand-alone software and Unclassified devices – September 24, 2018
- Class I reusable devices that are required to have UDI on the device itself – September 24, 2020
- For Class I and unclassified devices manufactured and labeled on or after September 24, 2018 – September 24, 2022
- For Finished Class I and unclassified devices manufactured and labeled before September 24, 2018 – September 24 , 2022
Liberty Management Group, a leading FDA consulting group in the United States, provides assistance with UDI account creation, selection of Accrediting agency, GUDID submission.
Sudha S
Regulatory Consultant
Mail : office@libertymanagement.us