Including Manufacturer's URL on Electronic Product Labels
This guidance recommends manufacturers to include their Uniform Resource Locator (URL) on electronic product labels in addition to the mandatory requirements for identification tags/labels under 21 CFR 1010.3(a)(1) and (2).
Recommended Actions
- Review current product labeling to assess feasibility of adding URL
- If feasible, update product labels to include company URL
- Ensure website contains required manufacturer information or clear link to it
- Implement process to update website address information within 15 days of any change
- Maintain compliance with existing identification tag/label requirements
- Review website content considering it may be interpreted as product labeling
- Document decision-making process regarding URL inclusion or exclusion based on label space constraints
Key Considerations
Labelling
- Manufacturer’s full name and address must be included on product identification tag/label
- Place, month, and year of manufacture must be included on product identification tag/label
- URL should be added when feasible
- URL should point directly to:
- A web page with manufacturer’s full name and current physical address, or
- A web page with an easily identifiable link to contact information
- Physical address on website should be updated within 15 days following any change
- Label information must be legible and readily accessible when product is fully assembled
Other considerations
- Website information may be considered “labeling” under section 201(m) of the Federal Food, Drug, and Cosmetic Act
- URL inclusion is not recommended if it compromises the legibility of required information on the current product label
Relevant Guidances
- Device Labeling Requirements and Content for Premarket Approval Applications
- Labeling Requirements and Recommendations for Medical Devices
Related references and norms
- 21 CFR 1010.3: Performance standards for electronic products: general
Original guidance
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