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Understanding Health Canada’s Approval on Grape Seed Extract in Foods

Grape Seed Extract Allowed in Foods by Health CanadaHealth Canada has made an important decision regarding grape seed extract, now approved for use as a supplemental ingredient in foods. This modification marks a major development for businesses operating in the health and nutrition sector. Keep reading to learn how this change can affect your products and compliance strategies. 

Health Canada’s Decision on Grape Seed Extract 

Health Canada’s Food and Nutrition Directorate has completed a safety assessment of grape seed extract (oligomeric proanthocyanidins) for use in foods, concluding that its safety for consumption. As of January 16, 2025, this ingredient is now officially listed as a permitted supplemental ingredient under the Supplemented Foods regulatory framework. 

What Does This Mean for Your Business? 

Does your company manufacture or market food products containing grape seed extract? If so, it’s important to be aware of the recent regulatory changes. This decision allows you to include the ingredient in your formulations, but compliance with the updated regulations is still required.

Steps for Ensuring Compliance 

As the industry adapts to this new regulation, staying compliant will be crucial. We recommend reviewing Health Canada’s guidelines on supplemented foods and consulting with experts to ensure your products meet all safety standards. You can find further information in the Notice of Modification. 

The Importance of Ongoing Safety Assessments 

Health Canada’s process involved a thorough safety assessment and a public consultation, ensuring that the ingredient’s use in food is safe for consumers. As a result, they determined the ingredient is safe for inclusion in food products. Therefore, you must follow future updates regarding similar ingredients and stay informed about the regulatory landscape.

New Opportunities Ahead 

The approval of the ingredient for use in foods is a significant move by Health Canada that can open new opportunities for the health and nutrition industry. By staying informed and adhering to the new regulations, your business can continue to innovate while ensuring consumer safety. 

For more information and guidance on compliance, contact us at Quality Smart Solutions. 

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Why Are FDA Food Contact Notifications No Longer Effective?

FDA Food Contact Notifications are no longer effective

Have you heard about the recent updates to FDA Food Contact Notifications (FCN)? The FDA has determined that several FCN are no longer effective due to changes in manufacturing and regulatory standards. These updates directly affect businesses that rely on food contact substances (FCS). Furthermore, they include strict compliance deadlines that organizations must meet.

Understanding these changes is essential to stay ahead of compliance requirements and avoid disruptions. In this article, we will explore what these updates mean, highlight the FCN that are affected, and explain how your business can adapt effectively.

What Are Food Contact Notifications (FCN)? 

Food Contact Notifications (FCN) are approvals issued by the FDA for specific substances used in food contact materials. The FDA assesses these substances for safety and ensures they comply with regulations under the Federal Food, Drug, and Cosmetic Act (FD&C Act). Each FCN has the following characteristics:

  • Manufacturer-specific: Valid only for the listed manufacturer or supplier. 
  • Purpose-specific: Tied to a particular use case or food contact material. 
  • Safety-driven: Assessed for human and environmental safety. 

When the FDA declares an FCN ineffective, businesses must stop using the associated substance unless it receives re-approval.

Why Are Some FCN No Longer Effective? 

The FDA declared specific FCN ineffective for two main reasons: 

  1. Abandonment by Manufacturers: Manufacturers voluntarily informed the FDA that they have ceased producing, supplying, or using specific substances. Commitment letters submitted by these manufacturers confirmed that these substances would no longer be used in food contact applications. 
  1. Regulatory Updates: Recent changes to FDA regulations now allow the agency to declare an FCN ineffective for reasons beyond safety, such as the cessation of production. This aligns with updates to Section 170.105, enabling the FDA to streamline approvals and ensure public safety. 

Highlighted Affected Substances  

Some of the affected food contact substances include: 

  • Glycine, N,N-bis[2-hydroxy-3-(2-propenyloxy)propyl]-, monosodium salt: Used in coatings for food packaging (FCN No. 59). 
  • Fluorinated polyurethane anionic resin: Commonly applied in grease-proofing food paper products (FCN No. 187). 
  • Diphosphoric acid polymers with ethoxylated perfluoroether: Found in grease-proof paper coatings (FCN No. 195). 

These are just a few examples. The FDA has provided a compliance deadline of June 30, 2025, for certain FCN to give businesses time to transition. For the complete list of affected substances, visit the FDA’s No Longer Effective FCN Inventory. 

What Does This Mean for Your Business? 

If your company uses any of the affected FCS, you must act swiftly to remain compliant: 

  1. Audit your inventory: Identify materials containing ineffective FCS. 
  2. Transition to alternatives: Replace discontinued substances with FDA-approved options. 
  3. Monitor deadlines: Ensure that products under the compliance deadline are phased out before June 30, 2025. 

Failing to meet compliance requirements could result in operational disruptions and legal consequences. The FDA’s updates to Food Contact Notifications reflect the evolving nature of food safety regulations.  

By understanding these changes and adapting your processes, you can ensure compliance and maintain operational continuity. For expert guidance on navigating FDA regulations, contact Quality Smart Solutions today! 

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Health Canada Fees 2025 Guide

Canadian flag symbolizing Health Canada Fees 2025 and regulatory compliance.Are you ready for the upcoming changes to Health Canada Fees in 2025? These fees, effective from April 2025, impact businesses dealing with drugs, medical devices, and cannabis. With updates spanning licensing, submissions, and compliance requirements, staying informed is key to avoiding disruptions.

Health Canada is introducing a phased fee structure that ensures businesses contribute to maintaining high standards for product safety and efficacy. From updated pre-market evaluation fees for drugs and medical devices to regulatory costs for cannabis producers, these changes could affect your budget and planning.

Want to know how these updates might impact your operations? Keep reading to explore the details and learn how to navigate these fees effectively with expert tips from Quality Smart Solutions.

Medical Devices

If you’re in the medical device sector, you will encounter fees tied to your initial Medical Device License (MDL) Application. These fees vary based on the classification of your medical device. The following are the fees for an MDL application as of April 1, 2025:

  • Class 2 Devices: $632
  • Class 3 Devices: $13,926
  • Class 3 Devices (Near Patient): $29,664
  • Class 4 Devices: $30,199

Applicable MDL amendments are also subject to additional application fees.

If you wish to apply for a Medical Device Establishment License (MDEL), you will need to pay both the initial application fee and the annual license renewal fee each year. The following are MDEL fees as of April 1, 2025.

  • Application for a new MDEL and annual review of license: $5426

Annual fees for right to sell licensed devices also apply. The fee as of April 1, 2025 is $452. These fees support ongoing regulatory oversight, ensuring that devices meet safety and compliance standards.

Drugs (Drug Identification Number Registration)

For drugs for human use requiring a Drug Identification Number (DIN), Health Canada has detailed fees based on the type of submission:

  • New Active Substance: $606,286
  • Clinical and Non-Clinical Data with Chemistry: $313,944
  • Comparative Studies Only$70,750
  • Administrative Submissions: $1,002
  • Labelling only: $6,328
  • Disinfectant – Full review: $13,186
  • Drug identification number application – Labelling standards: $1,912

These fees cover the rigorous evaluation process, ensuring products meet Health Canada’s stringent standards.

Additionally, companies engaged in various activities must hold a Drug Establishment License (DEL) which requires annual renewal. Fees are determined by the scope of activities and the types of products handled. The DEL fees for 2025 are:

  • Fabrication – Sterile dosage form: $49,558
  • Importation: $38,265
  • Fabrication – Non-sterile dosage form: $36,740
  • Distribution: $19,531
  • Wholesaling: $11,398
  • Packaging/labelling: $7,164
  • Testing: $5,913
  • Building outside Canada (each): $1,088

DEL fees ensure that establishments meet Good Manufacturing Practices (GMP) standards, supporting the safety and quality of pharmaceutical products in Canada.

For drugs already holding a Drug Identification Number (DIN), companies are required to pay an annual “Right to Sell” fee. The fee are as follows:

  • Human drugs – Disinfectant: $1,730
  • Human drugs – Non-prescription: $3,334
  • Human drugs – Prescription: $5,531

These fees enable ongoing compliance monitoring and market authorization renewal.

Cannabis

For businesses operating in Canada’s cannabis industry, Health Canada Fees cover several areas, including application screening, security clearance, and regulatory oversight. As of now, Health Canada has not published updated cannabis-related fees for the fiscal year 2025-2026. The most recent fee adjustments, effective April 1, 2024, are as follows:

  • Application Screening Fee: $3,933 for a standard-level license or sale for medical purposes and $1,969 for a micro-level license.
  • Security Clearance Fee: $1,987 per individual requiring clearance.
  • Annual Regulatory Fee:
    • Micro Cultivator: If the cannabis revenue is $1 million or less, the greater of 1% of the cannabis revenue, and $2,500 OR if the cannabis revenue is greater than $1 million, the maximum amount plus 2.3% of the amount by which the cannabis revenue exceeds $1 million.
    • Standard Cultivator: The greater of 2.3% of gross revenue or a minimum of $23,000.

Navigating these fees is critical for maintaining compliance and ensuring uninterrupted operations.

Why It Matters

Missing deadlines or miscalculating Health Canada fees can lead to costly delays or penalties. By planning ahead and leveraging expert guidance, you can focus on what matters most: growing your business.

Regulatory compliance doesn’t have to be daunting. At Quality Smart Solutions, we provide expert guidance to help you stay informed and save money. Explore more about our services to see how we can support your regulatory journey.

For a complete overview of all fees, visit Health Canada’s Funding and Fees page$1,002$36,740$3,334

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Health Canada’s New Nicotine Rules: What’s Changing in 2024

Nicotine pouches in a round container on a wooden surface.

If you’re in the business of nicotine products like pouches, gums, patches, sprays, or lozenges (collectively known as nicotine replacement therapies, or NRTs), you need to know about Health Canada’s new nicotine rules. Major regulatory changes are now in place to ensure NRT products are marketed responsibly, labeled clearly, and sold in ways that prioritize consumer safety.

These new regulations introduce tighter advertising restrictions, comprehensive labeling requirements, and significant limits on where and how nicotine pouches can be sold. So, what do these changes mean for your business?

Whether you’re a manufacturer, supplier, or marketer, they could impact your products, packaging, and promotions. Keep reading to learn what’s changing, how it affects your operations, and how you can stay ahead. 

What’s Changing and Why It Matters

Health Canada’s new regulations are reshaping the nicotine industry, particularly for products like NRTs. These changes intend to tackle growing concerns about youth access and ensure consumers have accurate, transparent information. Here’s a closer look at the updates and their impact on your business:

Clearer Labeling Standards 

All nicotine products must now display nicotine content in milligrams. This gives consumers a clear understanding of product strength, helping them make better choices. Labels also require bold health warnings about addiction risks to ensure safety information is easy to spot. 

For businesses, this is an opportunity to strengthen customer trust. Transparent labelling shows accountability and can help your product stand out in a competitive market. 

Stricter Advertising Guidelines 

Marketing campaigns must focus on adult smokers looking for smoking cessation tools. Claims like “helps reduce cravings” now require solid evidence to back them up. Additionally, anything that could appeal to youth or non-smokers, like colourful imagery or playful language, is strictly prohibited. 

As you may already know, this shift is about responsible promotion. Therefore, aligning your campaigns with these rules keeps your business compliant while ensuring your message resonates with the right audience. 

New Sales and Distribution Rules

The sale of nicotine products, especially pouches, is now only available in pharmacies and must stay behind the counter. Convenience stores and other general retailers can no longer stock them, ensuring tighter control over access.

This change might seem limiting, but it also provides businesses with a sales channel that prioritizes specific goals and follows strict rules. Partnering with pharmacies can streamline distribution and help you reach your target audience more effectively.

How These Changes Impact Your Business

Adapting to Health Canada’s new rules requires strategic adjustments across various aspects of your business:

  • Manufacturers: Labels and packaging need to be updated to meet the new standards. Additionally, products may need reformulation to comply with flavor restrictions, as only mint and menthol are permitted.
  • Suppliers: Distribution channels must shift to focus on pharmacy sales. This may involve building new partnerships and streamlining supply chains.
  • Marketers: Advertising strategies must be reviewed and refined. Focus on clear, evidence-based messaging that targets adult smokers and highlights approved therapeutic benefits.

While these adjustments may seem challenging at first, they also create opportunities to demonstrate your commitment to safety, compliance, and customer trust.

How to Stay Ahead

Navigating these changes doesn’t have to be overwhelming. Here are actionable steps to ensure compliance:

  1. Understand the rules: Start by reviewing Health Canada’s full guidelines on advertising nicotine replacement therapies.
  2. Update your products: Ensure your labels and packaging clearly display the required nicotine content and health warnings in a way that meets the standards. If necessary, you’ll need to adjust product formulations to meet flavor restrictions.
  3. Revise your marketing: Focus on approved claims, like smoking cessation benefits, and target adult smokers. Avoid any messaging that could appeal to youth or non-smokers.
  4. Optimize your sales strategy: Shift your focus to pharmacy sales and strengthen partnerships with regulated distributors.
  5. Get expert support: Compliance can be complex, but it doesn’t have to be. At Quality Smart Solutions, we specialize in helping businesses meet regulatory requirements quickly and effectively.

The Bottom Line

As you’ve learned, Health Canada’s new nicotine rules are all about creating a safer, more transparent market for consumers. By adapting to these changes, you protect your business, build trust with your audience, and position yourself as a leader in the industry.

Need help with the new rules? Quality Smart Solutions can help you meet NRT compliance. Contact us today and let us guide you through the process!

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FDA 510(k) Pre-Submission: Steps for Medical Device Approval

Medical diagnostic device with a control panel and digital screen displaying test results, used for optical measurements.Are you trying to make sense of the FDA’s 510(k) pre-submission process? You’re not alone. Many companies, especially those new to the regulatory landscape, find themselves wondering where to start, what’s required, and how to get FDA approval for their medical devices. Without a clear plan, it’s easy to waste time and money on unnecessary steps, or worse, miss critical requirements that delay approval by years. 

That’s where the pre-submission process helps by clarifying what’s needed early on. Connecting with the FDA at this stage can prevent costly mistakes, keep your submission on track, and give you a roadmap for moving forward with confidence.  

By engaging with the FDA early, you’ll gain insights that can help avoid unexpected requirements or delays, setting you up for a smoother journey to approval. Keep reading to learn more about how the pre-submission process works and what steps to follow. 

What is the FDA 510(k) Pre-Submission Process? 

The FDA 510(k) pre-submission process is a chance to open a conversation with the FDA before committing to a full application. It begins by creating a structured document package that explains your device’s technology, intended use, and operation.  

This preparation demonstrates to the FDA that you’ve thoroughly researched your regulatory needs and are ready to proceed with compliance. Amit Guruprasad, a Quality Smart Solutions regulatory expert, explains, 

“The pre-submission process actually helps you build your regulatory strategy by connecting with the FDA early. You’re allowed to ask questions on specific topics, like intended use, regulatory strategy, or software validation, to get clear, actionable feedback that helps you avoid missteps.”

And here’s something you might not know: this process is part of the FDA’s Q-Submission Program, which supports several regulatory pathways, including 510(k). Curious to learn more? You can find more details in the FDA’s official guidance on the Q-Submission Program

Key Steps in the FDA 510(k) Pre-Submission Process 

Following these steps in the pre-submission process can help you avoid roadblocks and streamline your path to FDA approval. Here are the essential steps to follow in the FDA 510(k) pre-submission process: 

  1. Build your document package 
    To begin, start by putting together a comprehensive package that details your device’s technology, intended use, and comparisons with similar products. This package should reflect your due diligence regarding regulatory requirements and competitive products. 
  2. Ask targeted questions 
    Once your package is ready, you can submit questions on specific topics, such as intended use, regulatory strategy, or validation methods. While you have flexibility, Amit recommends focusing on well-chosen questions for the most practical feedback. “Clients pay us to ensure their document package is clear and to choose the right questions.” FDA responses typically arrive within 60 days, depending on their workload. 
  3. Review FDA responses and follow-up 
    After receiving responses, review the FDA’s feedback carefully. If anything is unclear, schedule a follow-up meeting with FDA specialists to discuss your technology and clarify any points. These one or two-hour meetings are ideal for getting additional insights into questions that may need further discussion.
  4. Reuse pre-submission documents 
    Did you know? One of the biggest advantages is that much of the work done in pre-submission can be reused in your official submission. Documentation developed during pre-submission serves as a foundation for your final 510(k) application, saving time and effort. 

Why the FDA 510(k) Pre-Submission Process Matters 

Many companies feel the pressure to get their devices to market as fast as possible, but skipping or rushing through pre-submission can often lead to setbacks. For complex devices, approval timelines can vary widely, sometimes stretching from two years to five years or even longer if unexpected issues arise. Who wants to face delays like that? 

That’s why the pre-submission process is so valuable: it gives you a clear preview of what the FDA expects, helping you avoid surprises and keep your device on a faster, more reliable path to approval. 

Amit emphasizes the importance of approaching pre-submission with careful planning, saying, 

“The work we do in pre-submission isn’t just about getting FDA feedback, it’s also about creating a foundation for a successful, streamlined approval process. By investing in pre-submission, clients set themselves up for a smoother journey through FDA approval, avoiding costly and time-consuming mistakes.”

Common Questions in FDA 510(k) Pre-Submission 

Here are a few examples of questions that can guide your device approval process: 

  • Is clinical testing required for this device? 
  • What specific performance standards should we meet? 
  • Can we use a particular testing approach, or are alternatives preferred? 

These questions help focus your efforts and make sure you’re on the right path from the start. 

How Quality Smart Solutions Can Help 

Navigating the FDA pre-submission process for medical devices doesn’t have to be overwhelming. At Quality Smart Solutions, our consulting team is here to guide each step, from creating your regulatory strategy to building a well-prepared submission package. 

  • Regulatory strategy: We help you find the best path to FDA approval. 
  • Submission package: Our team prepares a clear, complete package that meets FDA standards. 
  • Targeted FDA questions: We guide you in asking the right questions to avoid roadblocks. 
  • Follow-Up support: We’re here to guide you through each step with the FDA. 
  • Efficient 510(k) submission: We make sure all your pre-submission work flows right into your final application, saving you time. 

Let us help you bring your device to market with confidence and clarity, every step of the way. 

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Canada’s Strict Infant Formula Registration: How Quality Smart Solutions Ensures Compliance and Success

baby Formula

Are you ready to introduce your infant formula to the Canadian market? Health Canada’s stringent regulations ensure the safety, quality, and nutritional adequacy of all infant formulas. Registering an infant formula in Canada can feel overwhelming, but you can navigate the process smoothly with expert guidance. Quality Smart Solutions offers invaluable expertise to ensure every detail is compliant, so you’re fully prepared to meet Canada’s high standards. 

Step-by-Step: Canada’s Infant Formula Registration Process 

  1. Understand Canada’s Regulatory Requirements

Before applying, it’s crucial to grasp Health Canada’s requirements for infant formula registration, especially since the regulations under the Food and Drugs Act and Food and Drug Regulations (FDR) set strict standards for safety and nutrition. 

Key focus areas include: 

  • Nutritional Composition: Infant formula must meet specific dietary thresholds for proteins, fats, carbohydrates, vitamins, and minerals. 
  • Labeling Requirements: Labels must adhere to detailed guidelines on nutritional claims, ingredient listings, and preparation instructions. 
  • Pre-Market Notification (PMN): To bring an infant formula to market, a PMN must be submitted detailing the formula’s composition, manufacturing process, and safety. 
  1. Pre-Market Notification

A thorough Pre-Market Notification (PMN) submission is required for any new or modified formula. Health Canada assesses whether your formula aligns with Canadian safety and nutritional standards before reaching consumers. 

What you need for a successful PMN: 

  • Nutritional Analysis: Provide detailed nutrient data that aligns with FDR standards. 
  • Safety and Efficacy Data: Include clinical trials or other safety data proving the formula’s safety. 
  • Manufacturing Process: Describe the production process, including ingredient sourcing, quality controls, and safety measures to prevent contamination. 
  1. Conduct Clinical Studies (If Required)

For novel or significantly altered formulas, Health Canada may request clinical studies. These must follow Good Clinical Practices (GCP) to confirm the formula’s safety and that it supports average infant growth and development. 

  1. Adhere to Strict Labeling Guidelines

Compliance with labeling regulations is essential for Health Canada approval. Your formula’s label must clearly present: 

  • Nutrition Information: A complete breakdown of all essential nutrients. 
  • Approved Health Claims: Only regulated claims about nutritional adequacy are permissible. 
  • Preparation Instructions: Clear directions for safe preparation and feeding to avoid misuse. 
  1. Submit Your Application to Health Canada

Once you’ve gathered all documentation, submit your PMN via the Electronic Regulatory Submissions (ERS) Gateway. Ensure every detail is accurate to avoid costly delays. 

  • Typical Review Time: Health Canada’s review can take 90-180 days. Missing information can result in longer delays, so precision is vital. 
  1. Maintain Ongoing Compliance Monitoring

Once your infant formula is approved, maintaining compliance doesn’t end. Canadian regulations require continuous monitoring and adherence to evolving standards: 

  • Adverse Event Reporting: Report any incidents promptly to Health Canada. 
  • Product Recalls: Prompt reporting and recall procedures are mandatory for contamination or safety concerns. 
  • Label Updates: Be prepared to adjust your label when new regulations are implemented. 

 

Common Questions About Registering Infant Formula in Canada 

How long does the approval process take? 

Approval timelines range from 90-180 days, depending on the completeness and complexity of your submission. 

Do clinical studies have to be conducted? 

Not all formulas require clinical studies, but novel products or those with unique claims may require them to verify safety and effectiveness. 

Are health claims permitted on infant formula labels? 

Yes, but only approved claims in line with Health Canada’s nutritional guidelines can be included. 

The Challenge you face 

Navigating Canada’s strict infant formula registration requirements may be challenging but it’s achievable with the proper guidance. From understanding pre-market notifications to ongoing compliance, taking each step with accuracy ensures that your product meets Health Canada’s high standards. By adhering to these steps, your company can confidently enter the Canadian market with a safe, compliant, and nutritionally adequate formula for infants. 

What is really at stake? 

Incorrect registration can result in costly delays for your infant formula submission, especially considering the volume of correct and verified documentation needed. Another aspect is clinical trials which can be difficult and time-consuming to complete correctly. Quality Smart Solutions is your trusted and experienced partner in this process and save you both time and cost to get your infant formula on the market as quickly as possible.  

How Quality Smart Solutions Can Help You Register Successfully 

Quality Smart Solutions offers expert guidance through every stage of Canada’s infant formula registration process. Our experienced team ensures your submission is accurate, complete, and compliant, reducing the chances of delays or rejections. With Quality Smart Solutions, you gain a partner who understands Health Canada’s regulations profoundly and helps you achieve faster, smoother market entry. Fill out the form below and submit to ask us any questions you have. 

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Health Canada Opens 75-Day Consultation on Batch 4b – Share Your Input

FDA Warning Letter

Health Canada Opens 75-Day Consultation on Batch 4b – Share Your Input

The Natural and Non-Prescription Health Products Directorate (NNHPD) invites industry stakeholders to provide feedback on Batch 4b, with consultation open for 75 days. We encourage you to support any suggestions for monograph revisions with published evidence or clear rationale.

What’s Included in Batch 4b?

  • Updated Monographs for Topical Ingredients
    • 16 single-ingredient monographs for traditional plants now represent ingredient quantities as percentages. Your input confirms whether these concentrations are reasonable and align with industry standards.
  • New Topical Analgesics/Antipruritic Monograph
    • This addition, featuring natural health product ingredients, is based on the Nonprescription Drug Topical Anaesthetic/Analgesic/Antipruritic Labelling Standard.

Access all documents in Batch 4b, including new monographs, directly here.

Step-by-Step Instructions to Submit Comments

Follow these steps to access and comment on the documents:

  1. Choose Your Language
    • Double-click the language-specific folder.
  2. Download the Monograph
    • Double-click the monograph you wish to view and click “Download” in the top right corner.
  3. Enable Editing
    • Open the document on your computer and click “Enable Editing” if prompted by a Protected View banner.
  4. Add Comments
    • Go to the “Review” tab in Word and use “New Comment” to add your input.
  5. Send Back Your Edited Document
    • Save your version with comments and email it to: nnhpd.consultation-dpsnso@hc-sc.gc.ca

Prefer Text-Based Comments?
You can also email your comments directly, clearly linking each comment to the corresponding monograph.

Deadline for Submission: January 14, 2025

We appreciate your insights and participation in shaping health product standards. Feedback must be submitted by January 14, 2025.

How Quality Smart Solutions Can Assist

Quality Smart Solutions specializes in guiding businesses through regulatory challenges like this consultation. Our experts clarify the comment submission process, ensuring your insights are aligned with regulatory expectations—partner with us to make your voice heard in compliance consultations like Batch 4b. Reach out to us by filling out the form below.

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How to Master FDA Audits for Your Dietary Supplement Facility: A Complete Preparation Guide

Introduction 

Preparing for an FDA audit can be challenging, especially for dietary supplement manufacturers who must meet stringent Good Manufacturing Practices (GMP) requirements. The FDA regularly inspects dietary supplement facilities to ensure manufacturing, labeling, and safety regulations compliance. But how can you ensure you’re ready? Failing to meet FDA standards can lead to severe consequences, including costly recalls and facility shutdowns. This guide will outline practical strategies to help you confidently and efficiently navigate the FDA audit process. 

What is an FDA Audit and Why is it Essential? 

An FDA audit is a thorough review of your manufacturing facility, focusing on processes, practices, and documentation to verify compliance with the FDA’s Current Good Manufacturing Practices (cGMP). The FDA’s primary concerns during an audit include: 

  • Ensuring safe manufacturing practices. 
  • Validating that product labeling is accurate and non-misleading. 
  • Confirming adherence to testing standards. 

Why Does It Matter? 

Failing an FDA audit could damage your brand’s reputation, disrupt your supply chain, and, in extreme cases, halt operations entirely. Ensuring your facility is always ready for inspection can minimize risk, safeguard your business, and build consumer trust. 

How to Prepare for an FDA Audit: Step-by-Step Guidelines 

1. Review and Update Your SOPs Regularly 

Ensure your Standard Operating Procedures (SOPs) are thorough, up-to-date, and reflect daily operations accurately. SOPs are crucial for: 

a. Detailing manufacturing processes. 

b. Outlining quality control protocols. 

c. Documenting employee training and qualifications. 

d. Ensuring traceability of raw materials. 

Action: Appoint a dedicated team to review SOPs regularly and ensure employees understand these protocols inside and out. 

2. Conduct Routine Internal Audits 

Internal audits allow you to identify issues before an official inspection. Prioritize areas such as: 

a. Documentation accuracy. 

b. Maintenance logs for equipment. 

c. Sanitation and cleanliness. 

d. Traceability of ingredients and products. 

Action: Schedule quarterly internal audits to address any potential gaps in compliance. Use these audits as practice to refine your processes for the real audit. 

3. Invest in Comprehensive Employee Training 

The FDA assesses employee training quality, as untrained staff can contribute to errors in manufacturing, packaging, and documentation. 

Action: Develop a training program that includes onboarding and ongoing education for all staff. Keep detailed training records to demonstrate competency and compliance readiness. 

4. Ensure Accurate, Detailed Record-Keeping 

Record-keeping is crucial for FDA audits, covering areas like: 

a. Batch production records. 

b. Results of quality control tests. 

c. Supplier qualification documents. 

d. Product labeling approvals. 

Action: Implement a structured system to ensure all records are up-to-date, complete, and readily accessible. Automating this process reduces the risk of errors and ensures records are audit-ready. 

5. Enhance Product Testing and Quality Control 

Dietary supplements require rigorous quality control to guarantee product safety including: 

a. Testing raw materials and finished products for contaminants. 

b. Keeping records of all testing for each batch. 

c. Ensuring validated testing methods. 

Action: Partner with a reliable third-party lab to conduct product testing and ensure your protocols meet FDA standards. Organize testing records for easy access during inspections. 

6. Verify Your Product Labeling and Claims 

The FDA scrutinizes dietary supplement labels to verify compliance with regulatory guidelines. Misleading or exaggerated claims can lead to penalties. 

Action: Review all product labels to ensure they align with FDA regulations. Avoid claims suggesting your product treats, cures, or prevents diseases, as these could reclassify the supplement as a drug. 

7. Schedule Mock Audits for Stress-Free Preparation 

Mock audits simulate the inspection process, allowing you to identify weaknesses and make improvements. 

Action: Hire a third-party consultant to conduct a mock FDA audit. This external perspective provides invaluable insights and allows you to fine-tune operations before the actual audit. 

Frequently Asked Questions (FAQs) 

  1. How frequently does the FDA audit dietary supplement facilities?

Typically, the FDA audits facilities every 2-3 years, but high-risk or more extensive facilities may see more frequent inspections. 

  1. What if my facility fails an FDA audit?

A failed audit can result in warning letters, product recalls, or even legal action. Fortunately, manufacturers often have an opportunity to address deficiencies before facing penalties. 

  1. How long does an FDA audit usually last?

Audits can last from a few days to several weeks, depending on the facility’s complexity and size. 

Conclusion 

Preparing for an FDA audit doesn’t have to be stressful. You can ensure your facility is always audit-ready by following these steps—regular SOP reviews, internal audits, staff training, accurate record-keeping, thorough testing, compliant labeling, and mock audits. Staying proactive and addressing any issues early will strengthen your compliance and help you confidently face FDA inspections. 

How Quality Smart Solutions Can Help 

At Quality Smart Solutions, we specialize in comprehensive FDA audit preparation for dietary supplement manufacturers. Our expert team offers services ranging from SOP development and employee training to mock audits, helping you achieve compliance with ease. Trust us to guide you through every step of the audit process so you’re fully prepared to meet FDA standards and build lasting consumer confidence. 

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Unlocking Health Canada’s ANDS, SNDS, and NDS Pathways: Which is Right for Your Product?

Navigating Health Canada’s drug submission pathways can be daunting. How do you know which pathway—ANDS, SNDS, or NDS—best suits your product? Each submission route holds unique requirements and implications for compliance, review time, and cost. Choosing the right one can accelerate your time to market, streamline the regulatory process, and significantly impact your business’s bottom line.  This article breaks down each pathway, helping you determine which aligns with your goals, regulatory needs, and product type. Here’s what you need to know to make an informed decision on your drug submission. 

What is a New Drug Submission (NDS)? 

A New Drug Submission (NDS) is essential when launching a new drug in Canada. This pathway applies to drugs with new active ingredients, formulations, or therapeutic uses that haven’t been marketed in Canada.  Critical Characteristics of NDS: 
  1. Comprehensive Data Requirement: An NDS requires detailed clinical trial data showcasing the drug’s safety, efficacy, and quality. Preclinical data may also be required based on the drug’s nature. 
  2. Longer Review Time: NDS applications undergo rigorous review, typically lasting between 300-600 days. 
  3. When to Use: Choose the NDS pathway for introducing an entirely new drug or a novel therapeutic use for an existing drug not previously approved in Canada. 
Example: If you’re developing a breakthrough treatment for a chronic illness, you’ll need an NDS to gain Health Canada approval. 

What is a Supplemental New Drug Submission (SNDS)? 

The SNDS pathway is for significant changes to an already approved drug. These modifications can impact a drug’s safety, efficacy, or quality, necessitating regulatory review to ensure compliance. 
Key Characteristics of SNDS: 
  1. Modification Coverage: SNDS is needed for alterations in formulation, manufacturing, labeling, dosage, or therapeutic use. 
  2. Clinical Data: New clinical trial data may be required if changes affect the drug’s intended use or safety profile. 
  3. Moderate Review Time: SNDS submissions generally take 180-300 days for approval. 
  4. When to Use SNDS: Use the SNDS pathway when making substantial modifications to an approved drug. 
Example: If you have an approved drug for high blood pressure and want to add a therapeutic use for diabetes, submit an SNDS to ensure regulatory approval for the new indication. 

What is an Abbreviated New Drug Submission (ANDS)? 

Designed for generic drug products, the ANDS pathway allows manufacturers to show their product is bioequivalent to an already approved reference drug without conducting new clinical trials. 
Key Characteristics of ANDS: 
  1. Bioequivalence: This is the main requirement; manufacturers must prove that their generic product matches the brand-name drug in bioavailability through bioequivalence studies. 
  2. No Need for New Clinical Trials: New clinical data isn’t required since safety and efficacy are already established. 
  3. Shortest Review Time: ANDS submissions are reviewed within 180-300 days. 
  4. When to Use ANDS: Choose the ANDS pathway for bringing a generic version of a previously approved drug to market. 
Example: Developing a generic version of a cholesterol medication already available in Canada would require an ANDS submission. 

Comparing Health Canada’s ANDS, SNDS, and NDS Pathways: Which to Choose? 

1. Type of Product: 
a. NDS: For new drugs with unapproved ingredients or therapeutic uses.  b. SNDS: For significant changes to an existing, approved drug.  c. ANDS: For generics proving bioequivalence. 
2. Data Requirements: 
a. NDS: Requires full clinical data for safety, efficacy, and quality.  b. SNDS: Requires data based on the modification’s impact on the drug.  c. ANDS: Focuses on bioequivalence studies; no extensive clinical trials. 
3. Review Times: 
a. NDS: Longest review time of 300-600 days.  b. SNDS: Moderate review time of 180-300 days.  c. ANDS: Shortest review time, typically 180-300 days. 
4. Associated Fees: 
a. NDS: CAD 590,346.  b. SNDS: CAD 305,690.  c. ANDS: CAD 305,690.  These pathways represent a regulatory requirement and a strategic business choice. Submitting under the correct pathway ensures a more streamlined review process, reducing potential delays and fees. 

Frequently Asked Questions 

  1. Which pathway is appropriate if I’m reformulating a drug?
If the reformulation significantly impacts safety, efficacy, or quality, an SNDS is required. 
  1. How long does the ANDS approval process take?
An ANDS typically takes between 180-300 days, depending on the submission’s completeness. 
  1. Can I use the NDS pathway for a generic drug?
No, generics follow the ANDS pathway to demonstrate bioequivalence to an approved reference product. 

How Quality Smart Solutions Can Help 

Quality Smart Solutions specializes in guiding pharmaceutical companies through Health Canada’s regulatory pathways, including ANDS, SNDS, and NDS submissions. With expert insights and thorough support, they help streamline the submission process, ensure complete and accurate documentation, and expedite regulatory approval. Partnering with Quality Smart Solutions could save your business time, reduce costs, and prevent unnecessary setbacks in bringing your product to market. References 
  1. Health Canada. (2024). Fees for the Examination of Drug Submissions and Applications. Government of Canada. Retrieved from https://www.canada.ca/en/health-canada/services/drug-health-product-review-approval/submission-applications/fees.html 
  1. Canada Gazette, Part 1, Volume 158, Number 13. (2024). Notice amending Health Canada’s National Dosimetry Services Products, Services, and Fees Schedule. Government of Canada. Retrieved from https://gazette.gc.ca/rp-pr/p1/2024/2024-03-28/html/notice-avis-eng.html 
  1. Health Canada. (2023). Drug Submission Application Review Fees. Government of Canada. Retrieved from https://www.canada.ca/en/health-canada/services/submission-applications/review-fees.html 
 
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Blog

Understanding the Differences Between a Health Canada Drug Monograph and Product Monograph – A Must-Know Guide

Navigating Canada’s pharmaceutical regulations can be overwhelming for businesses, especially those dealing in food products, ingredients, and additives. Two pivotal documents in this regulatory landscape—the Health Canada Drug Monograph and Product Monograph—hold distinct roles and purposes. Understanding these differences is crucial for any business looking to introduce food-related products or other regulated substances into the Canadian market. When preparing these essential documents, Quality Smart Solutions is your expert partner, ensuring your submission is accurate, complete, and compliant, ultimately helping to fast-track your product to market.  

In this article, we break down the key differences between a Health Canada Drug Monograph and a Product Monograph, emphasizing why knowing these distinctions can be the difference between quick market access and costly delays. Let’s dive in!  

What is a Health Canada Drug Monograph?  

A Health Canada Drug Monograph serves as a regulatory framework set by Health Canada that outlines the pre-approved conditions for selling specific classes of drugs, typically non-prescription, without needing clinical trials. This guide is handy for companies dealing with non-prescription or over-the-counter products, as it provides a standardized way to bring these items to market with reduced time and financial investment.  

Critical Characteristics of Health Canada Drug Monographs:  

Predefined Standards  

Health Canada Drug Monographs include predefined dosages, indications, and labelling standards that manufacturers must follow. These monographs enable manufacturers to market products in specified categories without a full clinical trial.  

Simplified Approval Process  

Products that fit within these predefined standards can bypass the clinical trial requirement, making it a cost-effective and time-efficient path to the market.  

Common Examples  

Common categories include pain relievers, antihistamines, and cough suppressants. The approval process is far more straightforward for products that meet monograph standards.  

Why Are Drug Monographs Important?  

Drug monographs streamline product approval by providing a clear pathway with pre-approved guidelines. They allow manufacturers to move forward quickly while ensuring products remain safe and compliant under Health Canada’s established regulations.  

What is a Product Monograph?  

Unlike the Drug Monograph, a Product Monograph is a comprehensive, specific document that companies must submit to Health Canada to market a new prescription or over-the-counter drug requiring unique clinical data. This document details how a particular drug is used and prescribed, serving as a crucial reference for healthcare professionals.  

Critical Characteristics of Product Monographs:  

Detailed Clinical Data Required  

Unlike a Drug Monograph, a Product Monograph demands extensive clinical data, including safety, efficacy, and dosage. This information is essential for Health Canada to evaluate the risks and benefits of a specific drug.  

Three-Part Structure  

A Product Monograph is divided into:  

  • Part I: Health Professional Information – Prescribing details for professionals.  
  • Part II: Scientific Information – Clinical trial results, safety, and pharmacodynamics.  
  • Part III: Consumer Information – User-friendly instructions on safe drug use for consumers.  

Uniqueness of Each Product  

Product Monographs are exclusive to the specific drug they cover, unlike Drug Monographs that apply to a whole class of drugs.  

Why is a Product Monograph Important?  

Product Monographs are critical in ensuring that healthcare providers have comprehensive knowledge of a drug’s safety, risks, and prescribing guidelines. This document is essential for achieving regulatory approval from Health Canada for prescription drugs.  

Critical Differences Between Health Canada Drug Monographs and Product Monographs  

To simplify, here are the four main distinctions:
 

  • Purpose 

a. Health Canada Drug Monograph: Offers a pre-approved, standardized approach for classes of drugs. 

b. Product Monograph: Details all aspects of a unique drug’s safety, efficacy, and instructions. 

  • Scope of Coverage 

a. Drug Monograph: Applies to broad classes (e.g., pain relievers). 

b. Product Monograph: Applies to a specific drug only. 

  • Clinical Data Requirement 

a. Drug Monograph: No new clinical data required. 

b. Product Monograph: Extensive data and clinical trial results needed. 

  • Approval Time to Market 

a. Drug Monograph: Faster approval, lower regulatory burden. 

b. Product Monograph: Longer review process due to the need for comprehensive data. 

Frequently Asked Questions  

Why are Health Canada Drug Monographs Faster to Approve?  

Answer: Because they don’t require new clinical trials, these monographs offer a quicker path to market for products that fit pre-approved categories.  

Does Every Drug Need a Product Monograph?  

Answer: No, only drugs that are prescription-based or require unique clinical evidence need a Product Monograph.  

Can a Product Have Both Types of Monographs?  

Answer: Typically, no. A drug falls into a class requiring a Drug Monograph or a detailed, unique Product Monograph.   

How Quality Smart Solutions Can Help  

Quality Smart Solutions specializes in helping businesses navigate Canada’s complex regulatory landscape. With expertise in Health Canada Drug Monographs and Product Monographs, their team ensures every submission is complete and compliant and fast-tracks your product to market. Reach out to us today by filling out the form below. 

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News

FDA Fees Summary for 2025

FDA User Fees for Fiscal Year 2025 (FY2025) 

The FDA’s user fees for FY2025, which runs from October 1, 2024, to September 30, 2025, apply to various industries, including pharmaceuticals, medical devices, biologics, and animal drugs. These fees help support the FDA’s regulatory and review processes, promoting efficient approval and compliance. 

1. Prescription Drug User Fee Act (PDUFA) Fees 

For human prescription drugs and biologics, PDUFA fees expedite the drug approval process: 

  • New Drug Application (NDA) with clinical data: $4,310,002 
  • NDA without clinical data: $2,155,001 
  • Program Fees (for approved drugs): $403,889 per product 

2. Medical Device User Fee Amendments (MDUFA) Fees 

MDUFA fees apply to medical devices to support review and regulation: 

  • 510(k) Premarket Notification Submission: $24,335 
  • Premarket Approval (PMA) Application: $540,783 
  • De Novo Classification Request: $162,235 
  • Annual Establishment Registration Fee: $9,280 

3. Generic Drug User Fee Amendments (GDUFA) Fees 

GDUFA applies to generic drug manufacturers to enhance the generic application review process: 

  • Abbreviated New Drug Application (ANDA) Fee: $252,453 
  • Program Fees: 
    • Large companies (20+ approved ANDAs): $1,891,664 
    • Medium companies (6-19 ANDAs): $756,666 
    • Small companies (1-5 ANDAs): $189,166 

4. Biosimilar User Fee Act (BsUFA) Fees 

BsUFA fees are for biosimilar biological products to aid in regulatory review: 

  • Application Fee (with clinical data): $1,471,118 
  • Application Fee (without clinical data): $735,559 
  • Biosimilar Program Fee: $256,168 

5. Animal Drug User Fee Act (ADUFA) Fees 

ADUFA fees apply to veterinary drug manufacturers: 

  • Animal Drug Application (NADA): $581,735 
  • Supplement requiring safety or efficacy data: $290,867 
  • Annual Product Fee: $10,705 
  • Annual Establishment Fee: $157,702 

6. Animal Generic Drug User Fee Act (AGDUFA) Fees 

AGDUFA supports generic animal drug manufacturers: 

  • Abbreviated New Animal Drug Application (ANADA): $161,907 
  • Annual Product Fee: $116,139 
  • Annual Establishment Fee: $157,702 

7. Over-The-Counter (OTC) Monograph Drug User Fee 

Fees for non-prescription drugs marketed under OTC monographs: 

  • OTC Monograph Order Request (Tier 1): $559,777 
  • OTC Monograph Order Request (Tier 2): $111,955 
  • Annual OTC Monograph Drug Facility Fees: 
    • Monograph Drug Facility (MDF): $34,166 
    • Contract Manufacturing Organization (CMO) MDF: $22,777 

Key Notes 

  • Establishment Fees: Annual registration fees apply to industries like medical devices, prescription drugs, and animal drugs. 
  • Small Business Reductions: Some fees may be reduced for small businesses in medical devices and pharmaceuticals that meet eligibility criteria. 
  • Annual Adjustments: The FDA reviews and adjusts these fees annually based on inflation and regulatory demands to improve review efficiency and post-market safety. 

How Quality Smart Solutions Can Help 

Keeping up with regulatory fees and submission requirements is crucial for your business’s success in FDA-regulated industries. Quality Smart Solutions is here to simplify the registration and compliance process for your company, whether you’re working with the FDA, Health Canada, or the European Food Safety Authority (EFSA). Contact Quality Smart Solutions today to ensure smooth, cost-effective compliance that aligns with the latest regulatory standards. 

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New Modification to Buffer Zone Affects Food Manufacturers and Suppliers

Simplified Explanation of Changes to Labeling Rules 

Starting July 2022, food manufacturers and suppliers have been required to display special labeling symbols on certain food products. These include a front-of-package (FOP) nutrition symbol for products high in saturated fat, sugar, or sodium, and a supplemented food caution identifier (SFCI) for supplemented foods with specific health or safety concerns (e.g. added caffeine). Some products may require both symbols on the front of the package, which has caused concerns about space on labels and packaging design. 

Why Was a Change Needed? 

Manufacturers and suppliers raised concerns that placing both symbols on the packaging would take up too much space, leaving less room for other important information. To address this concern, Health Canada modified the rules to allow these symbols to be placed directly next to each other without a gap between them. This is especially helpful for products that need more than one FOP nutrition symbol or both the FOP symbol and the SFCI. 

What Has Changed? 

Before this change, there was a required empty space, or “buffer zone,” around each symbol. Now, if the FOP nutrition symbol and the SFCI are next to each other, there doesn’t need to be a gap where they touch. This also applies to products needing multiple FOP symbols. However, any remaining sides of the symbols not touching another symbol must still have the required space around them. 

How This Affects Food Manufacturers 

This modification gives manufacturers and suppliers more flexibility in how they design their labels. They can now place these symbols side-by-side without worrying about taking up too much space, while still meeting legal requirements. This helps reduce the impact on available label space, making it easier for manufacturers and suppliers to comply with the rules, while still maintaining their brand integrity and marketing design. 

Next Steps 

The change was finalized after Health Canada received feedback from industry representatives and other stakeholders. This adjustment should make it easier for manufacturers to follow labeling guidelines while maintaining the integrity of the symbols for consumers. This update allows more efficient use of space on food packaging while keeping important health information visible and clear. 

Quality Smart Solutions Can Help

Navigating the latest labeling requirements can be challenging, but Quality Smart Solutions is here to simplify the process. With recent changes to Canada’s labeling rules, Quality Smart Solutions offers expert guidance to ensure your labels meet these updated requirements efficiently and effectively. Let us help you create compliant, clear, and consumer-friendly labels that uphold the integrity of your brand. Reach out to Quality Smart Solutions to streamline your labeling process and stay ahead in the industry. Fill out the form below to get started.

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Quality Smart Solutions Launches GRAS Experts to Protect Against Food Safety Risks

GRAS Experts, a new division aimed at tackling ingredient safety concerns and helping businesses stay ahead of regulatory changes and avoiding recalls

In light of McDonald’s recent recall of Quarter Pounders due to E. coli contamination, the need for stringent oversight on food ingredients has never been more critical. Quality Smart Solutions has launched GRAS Experts, a new division aimed at tackling ingredient safety concerns and helping businesses stay ahead of regulatory changes and avoiding recalls.

“Everyone’s talking about food safety right now, and for good reason,” said Andrew Parshad, President & Founder of Quality Smart Solutions. “The McDonald’s recall is a stark reminder of what can happen when ingredient or food safety isn’t airtight. GRAS Experts was created to help businesses avoid these exact scenarios by ensuring their ingredients are proven safe and fully compliant with evolving regulations.”

As more companies face scrutiny over what goes into their products, the GRAS (Generally Recognized as Safe) process has become a critical standard for ingredient approval. GRAS Experts simplifies this complicated process, providing businesses with expert guidance to secure GRAS status for their ingredients, navigate Health Canada approvals, and meet EFSA Novel Food regulations.

Additionally, the Toxic Free Food Act just introduced, complicates the compliance process. The issue being the self affirmed GRAS pathway (not filing with FDA) gives any novel ingredient supplier the ability to put together a dossier or evidence without a government agency vetting it. The Act proposes to end that and require that novel ingredients mandatorily be filed with FDA. GRAS Experts was designed to successfully navigate this process.

With a dedicated team of regulatory specialists, GRAS Experts takes the stress out of compliance, helping food manufacturers and ingredient suppliers prevent costly recalls and protect their reputation.

In a time when consumers are more concerned than ever about what’s in their food, Quality Smart Solutions is stepping up to ensure businesses can deliver products that meet the highest safety standards. GRAS Experts is not just about compliance—it’s about trust.

Read the News Release on GlobalNewsWire

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Blog

Government of Canada Launches Consultation on Plant-Based Egg Alternative Labelling: What Businesses Need to Know

The Canadian Food Inspection Agency (CFIA) has launched a 90-day consultation on proposed guidance for labelling plant-based alternatives to egg products, a critical development for businesses involved in Novel Food Products and ingredients. As the plant-based food market skyrockets, this new consultation presents both an opportunity and a challenge for companies to ensure their products meet compliance standards. Businesses must now navigate the complex landscape of food labelling, and the right strategy can make all the difference. If you’re in the plant-based or novel food space, this consultation is something you can’t afford to ignore.

The Growing Importance of Clear Food Labelling

With plant-based foods booming, clarity in labelling is essential for legal compliance and consumer trust. The Government of Canada’s proposed guidelines seek to ensure that plant-based alternatives to egg products are labelled truthfully and are not misleading to consumers. These guidelines are vital as more people turn to plant-based diets and expect transparency in the products they purchase. But how can businesses keep up with the ever-evolving regulations in the food industry?

If you’re a company that deals with Novel Food Products or innovative plant-based alternatives, now is the time to act. Ensuring compliance with new labelling standards will protect your brand from legal challenges and boost your reputation for honesty and transparency. Are you prepared for this shift?

Why This Matters for Businesses in the Novel Food Space

The plant-based food sector is no longer niche—it’s mainstream, and the competition is fierce. The CFIA’s consultation focuses on creating clear distinctions between plant-based alternatives and traditional egg products. Businesses need to get ahead by revisiting their product labels to ensure they meet the proposed guidelines while standing out in a crowded marketplace.

So, what does this mean for you?

If your company deals in plant-based or novel food products, you are entering a complex compliance maze. The terms, images, and packaging design must be clear and non-misleading. Simple errors could lead to consumer confusion, a damaged brand image, or even costly legal ramifications.

Here’s where it gets more complicated: the CFIA is not just asking for feedback from businesses but also asking for input from consumers. Consumer perception of your product is under the microscope, and businesses must consider how their labels resonate with the end-user.

Now, more than ever, it’s essential to ask: Is your product being perceived in the right way?

The Stakes Are High—Don’t Let Your Brand Get Left Behind

According to the CFIA, this consultation aims to “help the industry comply with the legislation and support consistency in how these foods are promoted.” For companies, this means adopting clear and honest labels that don’t mislead consumers. While the proposed guidance provides tools like the Industry Labelling Tool to help businesses, it’s not just about following the rules—it’s about staying ahead of them.

This consultation ends on October 28, 2024, giving businesses a narrow window to evaluate their labelling practices and prepare for potential changes.

Is your company prepared to handle the upcoming changes in labelling regulations?

How Quality Smart Solutions Can Help You Navigate This Complex Process

Having a trusted partner like Quality Smart Solutions can make all the difference when dealing with regulatory changes, especially those involving novel and plant-based foods. Navigating the maze of CFIA compliance and staying updated on evolving standards can be daunting. That’s why businesses need expert guidance to ensure their products are compliant and competitive. Quality Smart Solutions specializes in helping companies meet GRAS (Generally Recognized as Safe), Health Canada, and CFIA standards, ensuring your product stays on the shelf and in consumers’ good graces.

Final Thoughts: You Must Ensure Compliance and Consumer Trust

The CFIA’s new consultation on plant-based egg alternatives is critical for businesses involved in Novel Food Products and plant-based alternatives. It’s an opportunity to strengthen your brand’s reputation by showing consumers you’re serious about transparency and safety. But the window for action is short, and the stakes are high.

How Quality Smart Solutions Can Help

With a deep understanding of food regulations, Quality Smart Solutions offers expert guidance in navigating compliance for plant-based alternatives and Novel Food Products. Whether you aim to meet CFIA standards or require help with Health Canada approvals, they provide tailor-made solutions to ensure your product is compliant and market-ready. Reach out to QSS today by filling out the form below.

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New Hydration Product Monographs Launched

The NNHPD Opens Consultation on Batch 4 

Through new guidelines, stakeholders are invited to shape the future of homeopathic and topical health products. 

The Natural and Non-Prescription Health Products Directorate (NNHPD) has made a significant announcement, opening a crucial consultation period for Batch 4 of their latest product monographs, including several that will impact the growing market for hydration-related health products. This new development is not just about regulatory changes—it represents an opportunity for stakeholders to influence the standards governing these products directly, ensuring they are both safe and effective for consumers. For companies and professionals in the natural health sector, this consultation is a chance to align their products with the latest health regulations, cement their place in a rapidly evolving market, and contribute to the overall advancement of health product innovation. 

Why These New Hydration Monographs Matter 

The release of the new monographs has implications beyond simple regulatory compliance. With health-conscious consumers seeking more natural solutions for hydration, the products covered in Batch 4a, particularly those related to homeopathic remedies and topical treatments, offer companies an opportunity to meet growing demand confidently. Hydration products are now a central part of self-care routines, and the NNHPD’s focus on these products demonstrates their significance in the modern health landscape. 

According to experts at Quality Smart Solutions, leading consultants in regulatory affairs, these monographs play a critical role in setting product safety, efficacy, and consumer trust standards. Companies that integrate these regulations into their hydration product development can expect to meet compliance requirements and strengthen their credibility in a competitive market. 

A Closer Look at New Homeopathic Hydration Monographs 

Batch 4a introduces six homeopathic-like monographs, particularly relevant to hydration products aimed at maintaining and restoring fluid balance in the body. Homeopathy, a system of alternative medicine, is gaining momentum in wellness circles, and hydration-focused homeopathic products are poised to address a variety of consumer needs—from electrolyte balance to skin hydration. 

These monographs are a crucial development for manufacturers looking to introduce innovative, natural hydration solutions. By adhering to the guidelines set out by the NNHPD, companies can ensure their products are both compliant and positioned to capitalize on the growing trend toward natural, non-prescription health products. 

In this consultation, stakeholders are encouraged to provide suggestions for revisions supported by published evidence or rationales. This collaborative process ensures that the final monographs are scientifically sound, practical for manufacturers, and beneficial for consumers. 

Batch 4b: Spotlight on Topical and Buccal Hydration Products 

While the homeopathic monographs in Batch 4a focus on internal hydration and fluid balance, Batch 4b, slated for release on November 1, will center around topical and buccal (oral mucosal) hydration products. With 17 single-ingredient topical/buccal monographs under review, this consultation will explore traditional plant-based ingredients used for hydration, from aloe vera to hyaluronic acid. 

Topical hydration products, such as moisturizers, serums, and gels, are essential for maintaining skin health, particularly in harsh climates and dry conditions. The new monographs will provide clear guidelines on the traditional quantity crude equivalent amount of these ingredients, ensuring that products using these ingredients are both practical and safe for consumer use. 

Buccal hydration products are equally important, particularly for individuals with specific hydration needs related to oral health. These products, often in sprays or lozenges, provide targeted hydration and relief, and the upcoming consultation will establish concentration guidelines that ensure their efficacy. 

A direct link to all the monographs in batch 4a and to the new monographs can be found here.   

Or copy and paste the link below: 

https://drive.google.com/drive/folders/1zOpHiShCS6VOWgJgW2fOCjw9pw4wkEyE?usp=sharing 

 

Your Chance to Shape the Future 

One of the most critical aspects of this consultation is its collaborative nature. The NNHPD is actively seeking input from industry professionals, manufacturers, and other stakeholders to ensure that the new hydration monographs are both scientifically accurate and practically applicable. This open consultation is a unique opportunity to influence the regulatory landscape for hydration products. 

The NNHPD encourages stakeholders to carefully review the monographs and provide comments by October 2, 2024, for Batch 4a and by January 14, 2025, for Batch 4b. These deadlines provide ample time for carefully considering the monographs, ensuring that feedback is comprehensive and informed. 

When submitting feedback, stakeholders can use the “Comments” function in the restricted Word documents provided by the NNHPD. Detailed instructions are available, ensuring that the process is straightforward and accessible. Alternatively, comments can be submitted via email with explicit references to the associated monographs. 

How to Participate in the Consultation 

Participating in the consultation process is simple. To review the documents and provide input, stakeholders are encouraged to follow these steps: 

  1. Access the Monographs: Visit the NNHPD’s official website, where links to Batch 4a monographs are available. 
  2. Download the Documents: Double-click the folder in your preferred language, download the monographs you would like to view and open them on your computer. 
  3. Enable Editing: The documents are in “Protected View,” so you will need to click “Enable Editing” to add comments. Click the Review tab in Word. 
  4. Submit Comments: Use the “New Comment” function in Word to provide feedback. Once complete, save the file and email it to the NNHPD at mailto:mnnhpd.consultation-dpsnso@hc-sc.gc.ca. 
  5. Alternatively, You can submit feedback via email, ensuring that each comment references the appropriate monograph. 

Building a Better Future for Hydration Products 

This consultation period is a defining moment for the future of natural hydration products. Participating allows stakeholders to shape regulations that will ultimately improve product quality, safety, and consumer trust. Whether you’re a product developer, a regulatory affairs expert, or a consumer advocate, your input could have a lasting impact on the health and wellness industry. 

Quality Smart Solutions emphasizes regulatory compliance is not just about meeting minimum standards; it’s about leading the market by offering products that consumers can trust. It’s important to underscore these consultations for companies looking to innovate in the natural health product space. Navigating these regulatory waters with expertise and precision is undoubtedly essential for success. 

Don’t Miss This Opportunity 

For stakeholders in the hydration product industry, the NNHPD’s Batch 4 consultation is a critical opportunity to help shape the future of homeopathic and topical hydration products. With the rising consumer demand for natural health products, this is your chance to ensure that your products meet the highest safety, efficacy, and quality standards. 

Submit your comments by October 2, 2024, for Batch 4a, and be part of this collaborative effort to improve the hydration product landscape. Your insights could make all the difference in helping consumers access the best natural health products. 

If you need help making your contribution, reach out to Quality Smart Solutions at 1(800)396-5144, and we will help you navigate this exciting new opportunity. 

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7 Must-Know EFSA Novel Food Regulation Changes for 2025: You Need To Be Ready

Are your novel food products ready for the new European Food Safety Authority (EFSA) regulations? If you’re planning to enter the European market in 2025, significant updates to the EFSA novel food regulatory framework are on the horizon, effective from February 1, 2025. These changes will affect everything from risk assessments to labelling, sustainability, and more. Staying ahead of these updates could be the difference between success and costly delays.

This guide breaks down the fundamental regulatory changes and how your business can prepare for them. Plus, we’ll reveal how the common industry practice of partnering with experts can help you navigate these complex updates smoothly and avoid potential roadblocks.

What are these new EFSA Regulations?

1. Stricter Risk Assessments for Novel Foods

The EFSA is sharpening its focus on safety, particularly for foods created using cutting-edge technology like nanomaterials or synthetic biology.

Fundamental Change: Comprehensive assessments of potential toxicological, allergenic, and nutritional impacts.

What This Means: You should conduct long-term safety studies, especially for foods with novel production processes or bioactive components.

FAQ: Do I need new safety studies for already approved products? Answer: If your novel food includes new technology or production processes, you will need updated safety data that aligns with EFSA’s enhanced criteria.

2. Simplified Process for Traditional Foods from Non-EU Countries

Good news for those introducing traditional foods from outside the EU! EFSA is streamlining the process for these products if you can prove a safe consumption history.

Fundamental Change: Foods with at least 25 years of safe consumption in non-EU markets will benefit from a fast-tracked approval process.

What This Means: Less time-consuming reviews and easier entry into the European market.

FAQ: How do I prove my food has been consumed safely for 25 years? Answer: You must provide documented evidence like historical records, studies, or testimonials from recognized institutions.

3. Transparency in the Application Process

EFSA is taking steps to increase transparency, making more information about novel food applications accessible to the public.

Fundamental Change: A public database will feature safety evaluations and risk assessments.

What This Means: Consumers, researchers, and competitors can see the details of novel food approvals, increasing industry accountability.

4. Stricter Labeling and Health Claims Regulations

Misleading labels and exaggerated health claims will no longer be tolerated under EFSA’s new rules.

Fundamental Change: Labels must include clear information about the food’s novel nature, allergens, and proper preparation or consumption instructions.

What This Means: Ensure health claims are backed by scientific evidence to avoid non-approval or removal from the market.

FAQ: What happens if my product label is misleading? Answer: EFSA could reject or remove your product from the market, costing you time and money. Avoid exaggerated claims by relying on robust scientific evidence.

5. Protection of Proprietary Data

While EFSA is enhancing transparency, it’s also offering more protection for proprietary data submitted during novel food applications.

Fundamental Change: A five-year protection period for proprietary data ensures competitors can’t use your research for similar product approvals.

What This Means: You maintain a competitive advantage while benefiting from data exclusivity.

6. Sustainability Takes Center Stage

Sustainability is more important than ever, and EFSA’s updates reflect this by incorporating environmental factors into its review process.

Fundamental Change: Foods produced through sustainable practices—like alternative proteins and insect-based products—will receive added support in the approval process.

What This Means: Highlighting your food’s sustainability metrics (like carbon footprint) can boost your chances of approval.

FAQ: Can sustainability give my product an edge? Answer: Absolutely! Emphasizing low environmental impact practices aligns your product with EFSA’s sustainability goals and may lead to a priority review.

7. Increased Scrutiny of Supplements

If you’re producing supplements with novel ingredients, expect stricter rules.

Fundamental Change: New upper safety limits on bioactive compounds and mandatory consumer warnings.

What This Means: Supplements must now include clear usage instructions to prevent overconsumption.

How GRAS Experts Can Help

Navigating the intricate EFSA updates can be daunting, but GRAS Experts, a division of Quality Smart Solutions, can help your business comply with the new regulations. From assisting with long-term safety studies to advising on sustainability metrics, GRAS Experts ensure you meet all the latest requirements and successfully launch your novel food in the European market.

Don’t Wait Until it is too Late, Contact GRAS Experts Today

Ready to comply with EFSA’s 2025 regulations? With these updates around the corner, now is the time to ensure your novel food products meet all requirements. Whether providing long-term safety data, fast-tracking traditional foods, or crafting compliant labels, understanding the changes is critical to your success. With EFSA’s emphasis on sustainability, transparency, and public health, companies must stay proactive to stay competitive.

Don’t let complex regulations hold your product back—prepare now and position your business for success in 2025 and beyond.

References: 

https://efsa.onlinelibrary.wiley.com/doi/full/10.2903/j.efsa.2024.8966 

https://www.efsa.europa.eu/en/news/navigating-novel-foods-what-efsas-updated-guidance-means-safety-assessments 

https://efsa.onlinelibrary.wiley.com/doi/full/10.2903/j.efsa.2024.8961 

https://efsa.onlinelibrary.wiley.com/doi/full/10.2903/j.efsa.2024.8946 

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Blog

Breaking News: Health Canada’s New GMP Guide for Natural Health Products – Are You Ready?

Health Canada has just released a draft Good Manufacturing Practices (GMP) guide for natural health products (NHPs), marking a monumental shift in how businesses will manufacture, package, label, and store their products. This guide introduces sweeping changes, the first since 2015, to ensure NHPs sold in Canada meet modern safety and quality standards. With updates that will affect every aspect of your production process, if your business does not fully understand or is not clear on these updates, the penalties for non-compliance could be serious. 

If you’re an NHP business or manufacturer, this draft GMP guide isn’t just another regulatory hurdle—it’s a roadmap to protecting your brand, safeguarding your consumers, and avoiding potentially severe consequences of non-compliance. So, what’s new, and how can you prepare? 

What’s Inside the Draft GMP Guide for NHPs? 

1. Major Focus on Quality Management Systems (QMS) 

In an era of growing consumer demand for transparency and safety, Health Canada’s new draft emphasizes the need for robust Quality Management Systems (QMS). For the first time, NHP manufacturers must align their practices with industries like pharmaceuticals and medical devices, where QMS is already essential. 

What does this mean for you? 

You’ll need to develop detailed procedures for everything—from sourcing raw materials to final product testing. Failing to implement a strong QMS can open the door to product recalls, tarnished reputation, and heavy fines. This updated system will ensure consistency, safety, and quality in your production process, protecting both your brand and your customers.

2. Enhanced Record-Keeping and Traceability 

With the new draft, record-keeping takes center stage. Detailed records will need to track each part of your production process, including where ingredients are sourced, batch numbers, production methods, and quality control tests. 

Why is this crucial? 

In the event of an audit or product recall, your business must show a clear trail of accountability—from raw materials to finished product. Enhanced traceability safeguards consumers and protects your business from regulatory non-compliance. Are your records ready for scrutiny? 

3. Rigorous Testing and Stability Requirements 

The draft introduces stricter testing and stability requirements to ensure that NHPs remain safe and effective throughout their shelf life. This means more frequent testing and precise documentation. 

What’s new? 

Expect Health Canada to ask for real-time stability tests, justification for rotational testing, and robust finished product testing practices. These measures guarantee your products deliver on their promises, ensuring long-term consumer trust. 

4. International Standards Now in Play 

The inclusion of the Pharmaceutical Inspection Co-operation Scheme (PIC/S) is a game-changer. This allows greater international flexibility for companies sourcing products or ingredients from abroad. 

 

How does this help your business? 

By adopting these internationally recognized standards, Canada aims to modernize and smooth out inspections and ensure NHPs made or sourced globally meet Canadian safety and quality requirements. This opens up opportunities for businesses that rely on international suppliers while raising the bar substantially for compliance. 

5. Supplier and Ingredient Verification Now Critical 

Supplier verification is no longer optional—it’s mandatory. Health Canada expects NHP businesses to conduct thorough audits of suppliers, particularly those outside of Canada. This is where an NHP business can’t afford to miss anything and should use a partner fully versed in Health Canada regulatory compliance to help navigate this potentially risky juncture.  

What’s at stake? 

Businesses must maintain ongoing verification processes to ensure their ingredients meet Canadian standards. Those importing foreign-manufactured NHPs must pay particular attention to the new expectations for supplier audits. As a result of audits now being mandatory, demand for them has skyrocketed and wait times are getting longer. Don’t wait until it’s too late—get your supplier audits in order now. 

6. Push for Internal Audits and Continuous Improvement 

Additionally, Health Canada now requires NHP manufacturers to conduct regular internal audits, identifying compliance gaps before they become costly problems. 

For Health Canada, it is a way to make your business better 

By adopting a proactive approach to continuous improvement, you’ll not only comply with regulations but also enhance your production processes, ensuring consistent product quality and fewer regulatory issues. 

Why These Changes Matter to Your Business 

Canada’s natural health product industry is booming, and these new GMP guidelines aim to align with international standards and modern consumer expectations. Here’s why these updates are so important, and why any non-compliance is taken very seriously: 

  • Consumer Protection: Stricter controls ensure that products are safe, effective, and traceable from source to shelf. 
  • Global Harmonization: By incorporating international standards like PIC/S, Canadian businesses can more easily navigate cross-border trade. 
  • Enhanced Compliance: With internal audits, record-keeping, and stricter supplier verification, businesses can avoid compliance risks and focus on growth. 

But navigating these changes is no small task, and failure to comply could result in product recalls, loss of consumer trust, and even hefty penalties that could cripple your business or worse, bring lawsuits. So how can you prepare? 

How to Ensure Compliance with Health Canada’s New GMP Guide 

  1. Review Your Quality Management Systems (QMS):

Make sure your QMS covers the entire production process, from raw material sourcing to final product testing, and incorporates a culture of continuous improvement. 

  1. Conduct Thorough Supplier Audits:

Ensure your suppliers meet the new verification standards. For importers, this is especially critical to prevent non-compliance from international suppliers. 

  1. Strengthen Your Record-Keeping Systems:

Keep detailed, accessible records that track your entire production cycle, from ingredients to final products. 

  1. Prepare for More Rigorous Testing:

Update your product testing protocols to meet the new stability and testing requirements. This will ensure that your NHPs remain safe throughout their shelf life. 

  1. Engage with Health Canada:

Take advantage of the consultation period to review and comment on the draft guide. The consultation runs from October 15 to December 16, 2024—use this time to ask questions and prepare your business for what’s to come. 

Preparation in the key 

Health Canada’s draft GMP guide for natural health products is a major regulatory update designed to ensure transparency, safety, and quality across the NHP industry. With the global market for natural health products rapidly expanding, this new guide aims to protect consumers and align Canadian businesses with international best practices. 

By preparing for these changes now, you can stay ahead of the curve and ensure your products meet the highest standards, protecting your brand and your bottom line. 

How Quality Smart Solutions Can Help 

Quality Smart Solutions specializes in helping NHP businesses navigate the complexities of regulatory compliance. From implementing robust QMS to conducting supplier audits and ensuring proper documentation, our experts can guide your company through Health Canada’s new GMP guidelines and position you for long-term success. Don’t wait for these updates to take your business by surprise. Reach out to QSS now and position yourself for success. Fill out the form below to get started. 

 

Reference 

Health Canada. (2024). Consultation: Draft Good Manufacturing Practices Guide for Natural Health Products. Government of Canada. Retrieved from https://www.canada.ca/en/health-canada/programs/consultation-draft-good-manufacturing-practices-guide-natural-health-products/overview-about-nhp-quality-systems.html 

 

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Blog

Understanding the Key Changes to Natural Health Product (NHP) Labeling in Canada

Natural health products (NHPs) are widely used in Canada, ranging from vitamins, minerals, and herbal remedies to probiotics and homeopathic medicines. As these products play a vital role in promoting health and wellness, clear and accurate labeling is essential to ensure consumers can make informed decisions about the products they use.

To strengthen consumer safety and product transparency, Health Canada has introduced new labeling regulations for NHPs that align closely with non-prescription drug labeling standards. These changes are aimed at improving readability, consistency, and access to important product information. Below is a comprehensive breakdown of the most significant changes to NHP labeling and what they mean for manufacturers, retailers, and consumers.

Why Health Canada Updated NHP Labeling Requirements

The updated regulations reflect a growing concern for consumer safety, particularly as the market for natural health products continues to expand. With so many products available, it is essential that consumers have access to clear and concise information regarding ingredients, usage, risks, and allergens. The goal of these updates is to provide standardized and user-friendly labels that enhance transparency and facilitate better decision-making.

In addition, these changes address challenges identified through consumer feedback, industry consultations, and research on product labeling practices. By ensuring that NHP labels follow stringent standards, Health Canada is also working to increase confidence in the products available on the market.

Key NHP Labeling Changes: An Overview

The new NHP labeling rules include several critical changes designed to improve clarity, transparency, and accessibility. Below are the most important elements of these changes:

1. Product Facts Table

One of the most significant changes to NHP labeling is the introduction of a standardized Product Facts Table. This table is similar to the Drug Facts Table found on non- prescription drugs and serves as a quick reference for consumers to find essential product information.

  •  Required Information: The Product Facts Table must include key details such as active ingredients, dosage instructions, uses, warnings, and potential allergens.
  • Format: The table must follow a consistent format, making it easier for consumers to compare products and access relevant information quickly.
  • Importance: This change ensures that important safety information is highlighted and easily accessible, especially for consumers with specific health concerns or allergies.

2. Minimum Font Size

The updated regulations set strict requirements for minimum font sizes to improve the legibility of NHP labels.

  • Why It Matters: Previously, some NHP labels were difficult to read due to small fonts, especially for older consumers or those with vision impairments.
  • New Standards: The new rules specify that key information, such as the product name, dosage, and warnings, must be printed in a minimum font size to enhance readability. This requirement applies to both the Product Facts Table and other parts of the label.

3. Use of Plain Language

Another critical update is the requirement for labels to use plain language. This change is aimed at ensuring that the health claims, warnings, and instructions provided on NHP labels are written in simple, easy-to-understand terms.

  • Health Claims: Label must list at least one recommended purpose and must use the exact wording on your terms of market authorization.
  • Warnings and Risk Information: Warnings about potential risks, side effects, or interactions with other products must be communicated as they are on your terms of market authorization and must be in specific order under the new regulations.

4. Allergen Disclosure

Allergen labeling is a critical aspect of food and natural health product regulations, and the new NHP rules enhance allergen disclosure to align with food labeling requirements.

  • Required Information: NHP labels must clearly identify potential allergens such as

peanuts, tree nuts, gluten, and other common allergens that may be present in the product.

  • Why It’s Important: This change helps protect consumers with allergies and ensures they can make safe choices when selecting products. Clear allergen disclosure also prevents accidental exposure, which could lead to serious health consequences.

5. Expiry Date and Lot Number

Consumers rely on product labels to determine the shelf life and safety of natural health products. The updated regulations require that expiry dates and lot numbers be displayed more prominently on NHP labels.

  • Visibility: Expiry dates must be easy to locate and read, ensuring consumers are aware of when the product may lose its efficacy or safety by expressing in a specific format.
  • Lot Numbers: Lot numbers are essential for tracking purposes, especially in the case of product recalls. This ensures that manufacturers, retailers, and consumers can identify specific batches of products quickly and efficiently.

6. Standardized Risk Information

In addition to clear instructions on product use, labels must now include standardized risk information that outlines any potential side effects, interactions, or precautions associated with the NHP.

  • Risk Information: Cautionary statements must be clearly stated as they are written on the terms of market authorization. Subsections such as Allergens, Flammability warning, Choking Warning, and Keep out of reach of children may be included on the Product Facts Table.

7. Contact Information

The updated labeling regulations also require NHP labels to include contact information for the license holder.

  • Why This Matters: Including a phone number or email address or website ensures that consumers can quickly reach out to the company if they have questions about the product or wish to report any adverse reactions. This promotes greater accountability and transparency in the NHP industry.

8. Transitional Period for Compliance

License holders are given a transitional period of up to 3 years from the effective date of the new label regulations to comply with the new labeling requirements, allowing time to adjust packaging and update label designs.

  • Products with NPNs issued before June 21, 2025: They will have until June 21, 2028 to comply with the new label regulations.
  • Products licensed on or after June 21, 2025: Labels must comply with the new label regulations immediately. No grace period

What the Changes Mean for Consumers

These new labeling requirements have been implemented with the consumer in mind. By standardizing how information is presented on NHP labels, Health Canada aims to

improve the consumer experience and ensure that all individuals have access to accurate, easy-to-understand product information.

1. Enhanced Clarity and Transparency

Consumers will benefit from clearer labels that provide straightforward, easy-to-find information about product usage, risk information and ingredients. The new Product Facts Table makes it simpler to compare products and understand essential details about their use and safety.

2. Improved Safety for Vulnerable Populations

With better allergen disclosures, clearer warnings, and standardized expiry date formats, consumers can make safer, more informed choices when selecting natural health products. This is particularly important for individuals with allergies, chronic health conditions, or those taking other medications.

3. Easier Access to Product Information

The inclusion of plain language, readable fonts, and contact information ensures that all consumers, regardless of literacy level or health knowledge, can access the information they need to use NHPs safely and effectively.

Implications for Manufacturers and Retailers

The updated labeling regulations present both challenges and opportunities for manufacturers and retailers in the NHP industry. While the changes require adjustments to packaging and label design, they also offer several long-term benefits.

1. Increased Consumer Trust

By adhering to the new labeling standards, manufacturers can enhance the trust consumers place in their products. Clear, transparent labeling signals that the company is committed to safety and regulatory compliance, boosting brand reputation.

2. Streamlined Compliance

While the new regulations may require an initial investment in redesigning labels, they provide a standardized framework for compliance, reducing ambiguity and ensuring that all manufacturers are held to the same standards.

3. Competitive Advantage

Companies that implement these labeling changes promptly and effectively may gain a competitive advantage by being seen as early adopters of best practices in the NHP industry. Consumers are more likely to trust and purchase products that prioritize safety and transparency.

4. Need for Regulatory Guidance

To ensure compliance, manufacturers and license holders may need to seek guidance from regulatory experts who are familiar with the updated labeling requirements. This can help streamline the process and avoid costly mistakes that could lead to product recalls or regulatory penalties.

Why NHP License Holders should start Updating Labels Now

Though current NHP license holders have until 2028 to update their labels to meet the new label requirements the reason to start the changes now is consumer clarity. Having two types of label formats under the same brand will inevitably create confusion in the short term. Major retailers will likely require current NPN holder brands to comply with the new label regulations much sooner than the 2028 deadline. Managing packaging inventory and product turns will be key to developing a roll out strategy for new NHP label implementation.

Also, NHPs with product license/s issued on or after June 21 2025, must meet the new labeling requirements.

A Positive Step for Consumer Safety and Transparency

The new NHP labeling requirements represent a significant step forward in improving consumer safety, transparency, and product consistency in Canada. By introducing standardized labeling practices, Health Canada is ensuring that natural health products are labeled in a way that is clear, concise, and accessible to all consumers.

For manufacturers and retailers, these changes may require an investment of time and resources to ensure compliance, but the long-term benefits—both in terms of consumer trust and regulatory alignment—are substantial. As the natural health product market continues to grow, the importance of clear and transparent labeling will only increase, making these updates a vital component of public health and consumer protection.

How Quality Smart Solutions Can Help

With thousands of natural health product registrations and NHP label reviews we can ensure your packaging complies with the new NHP label regulations. We can help strategize the optimal time to begin this process if your products are licensed before the effective date so you minimize packaging liability. Reach out to us today by completing the form below.

Reference: https://www.canada.ca/en/health-canada/services/drugs-health- products/natural-non-prescription/legislation-guidelines/guidance- documents/labelling.html

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Blog

FDA Considerations Selling Foods in USA

 
Regulatory Considerations when Selling Foods and Beverages in the United States 

Selling food products in the United States requires compliance with various regulations to ensure consumer safety and public health. The regulatory framework is complex, involving multiple federal agencies, state laws, and industry standards. Here’s an overview of the key regulatory requirements: 

Federal Agencies: 
  1. Food and Drug Administration (FDA): Responsible for ensuring the safety and labeling of most food products, including dietary supplements.
  2. United States Department of Agriculture (USDA): Oversees meat, poultry, and egg products, as well as organic and bioengineered foods. 
  3. Federal Trade Commission (FTC): Regulates advertising and marketing claims. 
Three Regulatory Requirements: 
  1. FDA Compliant label – A Canadian Nutrition Facts table (NFT) differs from a Nutrition Facts Panel (NFP). Some noticeable differences include “calories from fat” required on an NFP. Rounding rules differ which could result in different numbers and impact nutrient claim qualifier statements. There are many other differences.  Bottom line is that you must prepare a new nutrition facts panel and have a FDA compliant label when launching in the United States.
  2. FSVP Agent – Under the Food Safety Modernization Act (FSMA) that came into effect in 2016, similar to the Safe Foods for Canadians Regulations (SFCR), this preventive plan was to protect US consumers from foodborne illness and ensure food safety measures and practices are adhered to by all food businesses. A FSVP Agent is a designated representative responsible for ensuring that foreign food suppliers meet the US food safety standards under the Foreign Supplier Verification Program (FSVP). The FSVP Agent verifies that foreign suppliers have adequate procedures in place to prevent or significantly minimize hazards in the food they produce 
  3. Food Facility Registration and US Agent (if applicable): Manufacturers, processors, packers, and holders of food products must register with the FDA. In addition, for foreign sites (ie. outside the United States) a US Agent must be linked to the registered food facility. Site renewal occurs every 2 years on the even numbered year.  
Penalties for Non-Compliance: 

Failure to comply with regulatory requirements can result in: 

  1. Warning letters and fines 
  2. Product recalls and seizures 
  3. Detainment at US border entry point
  4. Legal action and criminal penalties 
  5. Damage to reputation and consumer trust 
Conclusion: 

Selling food products in the United States requires a thorough understanding of the regulatory landscape. Compliance with federal agencies, industry standards, and, in some cases, state laws is crucial to ensure consumer safety and avoid legal consequences. Food businesses must stay up-to-date on changing regulations and industry developments to maintain a competitive edge and build trust with consumers. 

How Quality Smart Solutions Can Help with FDA Compliance
We offer solutions to meet the 3 requirements to sell your food in the United States. We will review your food label, register your manufacturing site and act as your US Agent, if applicable, and act as your FSVP agent.  With a former FDA inspector acting as your FSVP agent you have the assurance, trust and reliability to enter the US market. 

 

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Blog

Health Canada 2024 Changes for Nicotine Replacement Therapies (NRT)

Health Canada 2024 Changes for Nicotine Replacement Therapies (NRT) 

On August 22, 2024, the Honourable Mark Holland, Minister of Health, announced new measures aimed at preventing youth from being harmed by nicotine replacement therapies (NRTs). The following outlines the recent updates from Health Canada concerning NRTs. 

There is increasing concern that NRTs, particularly newer formats like nicotine pouches, are being used recreationally by youth under 18. To address these concerns, Health Canada has introduced new regulatory measures. Businesses involved with NRTs must comply with these updated requirements. 

What Are the New Measures? 

The Ministerial Order introduces the following changes: 

  • Prohibition on Advertising: Any advertising or promotion that could appeal to youth is now prohibited. 
  • Pharmacist Supervision: New and emerging NRTs can only be sold by pharmacists or under their supervision. 
  • Flavor Restrictions: Flavors other than mint or menthol are prohibited for new and emerging NRTs. 
  • Mandatory Warnings: Clear nicotine addiction warnings and indications of intended use as a smoking cessation aid are required. 
  • Label and Packaging Review: Manufacturers must submit label and package mock-ups for Health Canada’s review.  
Implications for Your Business 

Adults trying to quit smoking will continue to have access to smoking cessation aids like nicotine gums, lozenges, sprays, and inhalers at various retail locations in approved flavors. However, if you are a manufacturer or retailer of NRTs, it is essential to comply with these new measures to avoid appealing to youth and ensure adherence to Health Canada’s regulations. Non-compliance can result in your product/s becoming illegal to sell in Canada. 

Legal Sale of NRTs in Canada 

To legally sell NRTs in Canada, a natural health product (NHP) must have a Natural Product Number (NPN) license and bilingual labeling. If the NHP is manufactured outside of Canada, it requires a Health Canada licensed importer of record. The licensing timeline for NRTs, classified as Class 3 NHPs, typically takes approximately 210 days, although this is non-binding. 

How We Can Help 

At Quality Smart Solutions, we have prepared over 9,000 NPNs and possess the expertise needed to ensure compliance with Health Canada’s regulations. Navigating the complexities of NRT product licensing and preparing a comprehensive safety and efficacy report can be challenging. Our experienced and highly qualified team is here to help you achieve the best outcome for your product registration and market access strategy. Contact us today to discuss how we can support your business! 

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Blog

How to Create Health Canada Compliant Food Labels

How to Create Health Canada Compliant Food Labels 

When entering the Canadian market, designing your food labels correctly is not just important—it’s critical. The Canadian food labelling landscape is complex and unforgiving, with stringent requirements that can make or break your product’s success. Quality Smart Solutions (QSS) can get your labels compliant so you can successfully start selling in Canada effortlessly. 

4 Things You Need To Know  

Before you start designing your packaging, there are four key Canadian food labelling requirements that you need to understand: bilingual labelling, nutrition and health claims, location and legibility requirements, and the new front-of-pack nutrition symbol. Ignoring or misunderstanding these can lead to costly redesigns and delays in bringing your product to market.

1. Canadian Bilingual Requirements

In Canada, all mandatory information on a food label must be presented in both official languages—French and English. This is not a mere formality; it’s a legal requirement that applies across the country. If you plan to sell your product in Quebec or through Canada’s national retailers, every piece of information on your packaging must be in French, with French given equal prominence to English. 

For many U.S. brands, this requirement can come as a shock, often necessitating a significant increase in label text. Without careful planning and design, this can clutter your packaging and disrupt your brand’s communication hierarchy, potentially harming your product’s appeal. 

2. Nutrition and Health Claims

Canada’s health and nutrition claims are subject to meticulous and aggressive standards set by Health Canada and the Canadian Food Inspection Agency (CFIA). Claims about your product’s origin, content, quality, and the absence of allergens must be carefully vetted against Canadian regulations. 

Common claims like “Source of Protein” or “No Sugar Added” that are widely used in the U.S. may not be permitted on Canadian food labels. Failing to comply with these standards can lead to your product being pulled from shelves or, worse, legal action.

3. Location and Legibility

Canadian regulations prescribe exactly where information must appear on your packaging and how legible it must be. This includes specific minimum type sizes for mandatory information such as net weight, ingredients, common name, dealer name and address, and any claims. 

These requirements are not merely suggestions—they are enforced rigorously. Getting this wrong could lead to costly reprints or delays in your product launch.

4. New Canadian Front-of-Pack (FOP) Nutrition Labelling

Starting January 1, 2026, Canada will require a new front-of-pack nutrition symbol on products containing 15% DV or more of saturated fat, sugar, or sodium. This is a significant new requirement that could impact your product’s shelf appeal and consumer perception. 

Understanding and correctly applying this new symbol will be crucial for any brand looking to enter or expand in the Canadian market. 

QSS is Your Essential Partner in Canadian Food Labelling Compliance 

Canadian food labelling laws can feel like a non-tariff barrier for many U.S. companies, particularly small and medium-sized businesses. However, when executed correctly, these regulations can become a competitive advantage, showcasing your brand’s commitment to transparency and consumer trust. 

QSS brings decades of experience in helping brands navigate these complexities. We ensure that your packaging not only meets Canadian regulatory requirements but also resonates with Canadian consumers. Our expertise in both compliance and design means that your product will stand out for all the right reasons. 

If you have questions about Canadian food labelling, package design, or navigating the Canadian market, QSS is here to help

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News

New Update on FDA Sodium Reduction Efforts

The FDA has taken a significant step forward in its ongoing sodium reduction initiative by issuing new, voluntary sodium reduction targets in a draft guidance, marking the launch of Phase II in their efforts. This follows Phase I, aimed at decreasing diet-related diseases associated with high sodium intake, where final voluntary sodium reduction goals were established in 2021. 

The Journey Towards a Healthier Food Environment  

Excessive sodium consumption is a major public health concern in Canada and worldwide. The average Canadian consumes over 3,400 milligrams of sodium per day, exceeding the recommended daily limit of 2,300 milligrams. High sodium intake can lead to high blood pressure, heart disease, stroke, and kidney disease, resulting in significant healthcare costs and early mortality. 

FDA’s Sodium Reduction Initiative 

In 2021, the FDA set voluntary sodium reduction targets for food manufacturers, aiming to reduce sodium levels in processed and restaurant foods. The agency established two-year and four-year targets, encouraging industry-wide sodium reduction. The next phase of this initiative involves: 

  1. Revised targets: The FDA has revised its sodium reduction targets, setting more stringent goals for certain food categories. 
  2. Expanded scope: The initiative now includes additional food products, such as canned vegetables, soups, and sauces. 
  3. Monitoring progress: The FDA will track industry progress towards meeting the targets, providing guidance and support where needed. 

The industry has been working towards meeting the Phase I targets by April 2024. The newly proposed Phase II targets set the next milestone for industry to achieve within three years after the finalization of this guidance. These targets are designed to address the excessive sodium intake in the U.S., which currently averages nearly 50% above the recommended limits. 

Impact on Public Health and Benefits of Sodium Reduction  

Reducing sodium in food products can have numerous benefits, including: 

  • Improved public health: Lower sodium intake can lead to reduced blood pressure, cardiovascular disease risk, and stroke incidence. 
  • Increased consumer choice: As manufacturers reformulate products, consumers will have access to a wider range of lower-sodium options. 
  • Economic benefits: Reducing sodium can help alleviate healthcare costs associated with diet-related diseases. 

Excess sodium intake is a major contributor to high blood pressure, which is a leading risk factor for heart disease and stroke—conditions that disproportionately affect racial and ethnic minority groups in the United States. The FDA’s efforts are grounded in strong scientific evidence that reducing sodium intake can significantly lower the risk of these health issues, potentially preventing hundreds of thousands of premature deaths and illnesses in the coming years. 

Impact on Businesses 

The new sodium reduction targets set by the FDA could have significant implications for various businesses, particularly those involved in the food manufacturing and food service industries. Companies may need to reformulate their products to meet the new sodium reduction goals, which could involve altering recipes, sourcing new ingredients, or adjusting production processes. This may lead to increased costs and require changes in marketing strategies to communicate these adjustments to consumers. 

Small and medium-sized enterprises (SMEs) might face additional challenges due to limited resources for research and development. However, staying compliant with the FDA’s voluntary targets is crucial not only to avoid potential scrutiny but also to align with consumer demand for healthier food options. 

Challenges and Opportunities 

While the FDA’s initiative is a crucial step towards reducing sodium in food products, challenges remain: 

  • Industry compliance: Encouraging industry-wide adoption of sodium reduction targets may require ongoing support and monitoring. 
  • Consumer education: Raising consumer awareness about the importance of sodium reduction and providing guidance on healthier choices is essential. 
  • Innovation and reformulation: Manufacturers must innovate and reformulate products to meet sodium reduction targets while maintaining taste and quality. 

Andrew Parshad, CEO of Quality Smart Solutions, commented on the FDA’s new draft guidance: 

“The FDA’s continued efforts to reduce sodium levels in the U.S. food supply reflect an important public health initiative that we fully support. However, we recognize that these new targets present significant challenges for businesses, especially smaller companies with limited resources. At Quality Smart Solutions, we are committed to helping our clients navigate these changes efficiently and effectively, ensuring that their products remain compliant while also meeting consumer expectations for healthier options.” 

Progress and Future Assessments 

Preliminary data from 2022 indicates that about 40% of food categories have already reached or are close to the Phase I targets. The FDA plans to continue assessing progress on sodium reduction every three years, with more comprehensive data expected in the future to evaluate the full impact of Phase I. 

How to Get Involved 

The FDA is welcoming comments on the draft guidance through November 14, 2024. Stakeholders can submit their feedback electronically via regulations.gov 

If you have any feedback or concerns regarding the new sodium reduction targets, connect with us today to ensure your voice is heard in this important regulatory process. Quality Smart Solutions is here to assist you in this process. We can help consolidate your responses and submit a comprehensive, industry-relevant submission to the FDA on your behalf. 

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Blog

Health Canada plans to share document about health products containing CBD this fall

This fall, Health Canada is anticipating sharing a policy consultation document about health products containing (CBD). This proposal has been in the works since 2019.

In 2022, Health Canada  released  a report on health products containing cannabis.

Released earlier this year, The Forward Regulatory Plan for 2024 to 2026 details regulatory initiatives that Health Canada will be proposing or finalizing in the next 2 years.

New regulatory initiatives underway

According to the Food and Drugs Act of this plan, Health Canada plans to amend the Food and Drug RegulationsNatural Health Products Regulations and Pest Control Products Regulations ensuring a consistent and flexible approach to the regulation of biocides (surface disinfectants and surface sanitizers).

Are biocides affected?

At present, biocides are regulated under separate regimes. This causes heavy difficulties for many industry regulators as they continue to work with biocides. This became clear throughout the COVID-19 pandemic.

The proposed amendments will:

  • form 1 comprehensive framework for regulating biocides
  • allow regulatory oversight based on risk and evolving evidence
  • present a use of foreign decisions pathway

Note: The Biocides Regulations were formerly termed Regulations Amending the Food and Drug Regulations, Part C (Biocides, use of foreign decisions for disinfectants and surface sanitizers).

All of these initiatives form part of a larger spectrum of work on contemporary regulations all related to Health and Biosciences Sector Regulatory Review Roadmap.

What is Health Canada’s goal?

The intention of Health Canada is to fashion regulatory pathway for health products containing cannabidiol that would not require practitioner oversight.

How do you proceed? Get assisted by Quality Smart Solutions 

For detailed insights into these regulatory changes and ongoing consultations, reach out to our team of former Health Canada experts at Quality Smart Solutions. We help ensure compliance with modernized regulations governing natural health products (NHPs) and non-prescription drugs, enhancing safety and quality standards across Canada while facilitating business growth and innovation.  Fill in the form below and let’s get started!

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Understanding MoCRA and Safety Substantiation Requirements for Cosmetics

The Modernization of Cosmetics Regulation Act (MoCRA) brings significant changes for everyone in the cosmetics industry, from manufacturers to distributors. Its main goal is to make sure that cosmetic products are safe and comply with regulations before they reach consumers.
The main objective of MoCRA was to improve the safety and transparency of cosmetic products. It sets stricter rules for businesses, requiring them to prove their products are safe before they can be sold.
If you’re in the cosmetics business, it’s crucial to understand and follow these new regulations to stay in the market and keep consumers’ trust. Click here if you want to comply with the updated MoCRA cosmetic regulations by FDA. Let’s break down the key parts of MoCRA and the guidelines for proving product safety, so you can easily meet these new requirements.
What is MoCRA?
MoCRA, or the Modernization of Cosmetics Regulation Act, is designed to update and improve the regulatory framework for cosmetics in the U.S. It mandates that cosmetic manufacturers ensure their products are safe for use, substantiated through rigorous testing and documentation. This act aligns the U.S. more closely with international standards, aiming to protect consumers and ensure product safety.
Benefits of MoCRA for businesses
  • Future-Proofs Your Business: MoCRA sets the new standard for cosmetic safety. By complying now, you avoid scrambling to catch up later and ensure your products can stay on shelves.
  • Builds Brand Trust & Loyalty: Consumers are increasingly concerned about safety.
    • MoCRA compliance demonstrates your commitment to safe ingredients and high-quality products, fostering trust and loyalty from customers.
  • Reduces Risk & Saves Money: Recalls, lawsuits and bad publicity due to safety concerns can be financially devastating.
    • MoCRA compliance minimizes these risks, saving you money and protecting your brand reputation.
  • Competitive Advantage: As consumers become more aware of MOCRA, businesses that can clearly communicate their compliance will gain a competitive edge.
Key requirements of MoCRA
  1. Product Registration: As a cosmetic manufacturer, you must register your facilities and products with the FDA under MoCRA . This registration includes detailed information about the ingredients and formulations used in each product. Click to learn about the registration and listing of cosmetic product facilities and products.
  2. Adverse Event Reporting: If your products cause any serious health issues or reactions, you need to report these events to the FDA. This proactive approach helps the FDA monitor product safety and take necessary actions, showing consumers that their well-being is their priority.
  3. Labeling Requirements: MoCRA enforces strict labeling requirements, ensuring that all cosmetic products have accurate and clear ingredient lists. This helps consumers make informed decisions and avoids misleading claims, fostering trust and transparency. Learn here what is MoCRA label compliance.
  4. Good Manufacturing Practices (GMP): According to the act, you must adhere to Good Manufacturing Practices. This means making cosmetics in a clean, controlled, and consistent environment.
    • By sticking to these practices, you reduce the chance of contamination, making your products safer for customers.
    • Consistent manufacturing ensures that every product meets high standards, showing your commitment to quality.
    • Following GMP shows that you care about providing safe and reliable products, and building trust and loyalty with your customers.
Safety Substantiation Guidelines
Safety substantiation is a crucial aspect of MOCRA, requiring you to provide evidence that your products are safe for use. Here are the key steps, explained simply:
1. Assess Ingredient Safety:
  • Scientific Literature Review: Search for published studies on individual ingredients and their safety profiles. Look for reputable sources like peer-reviewed journals and safety data sheets (SDS) provided by suppliers.
  • Testing Options: Consider various testing methods beyond traditional animal testing, which MoCRA doesn’t mandate. Explore alternative methods like:
    • In Vitro (cell-based) testing: Evaluate ingredient effects on cultured cells.
    • Human Volunteer Patch Testing: Assess potential skin irritation or allergic reactions on a small group of volunteers under controlled conditions.
    • Computer Modeling: Utilize computer simulations to predict ingredient behavior and potential risks.
  • Concentration Matters: Evaluate safety based on the specific concentration of each ingredient in the final product. Lower concentrations may pose less risk.
2. Test the Product:
  • Stability Testing: Conduct studies to ensure the product maintains its physical and chemical properties over its shelf life. This includes factors like:
    • Separation
    • Color changes
    • Potential degradation of ingredients.
  • Microbial Testing: Test for potential contamination by bacteria, fungi, or other microorganisms. Implement good manufacturing practices (GMPs) to minimize contamination risk.
  • Clinical Testing: While not always mandatory, consider human volunteer studies to assess the product’s safety and potential for irritation or allergic reactions. Patch tests are a common option for this.
3. Document Everything:
  • Maintain Detailed Records: Create a comprehensive safety substantiation dossier for each cosmetic product. This should include:
    • Ingredient lists with CAS numbers (unique identifiers) and sources.
    • Scientific literature review summaries.
    • Testing protocols and results for all conducted tests.
    • Risk assessments and mitigation strategies.
  • Accessibility for Review: Ensure all documentation is readily available for inspection by the FDA upon request. This demonstrates your commitment to transparent safety practices.
4. Perform Risk Assessments:
  • Hazard Identification: Identify all potential hazards associated with the product, including:
    • Individual ingredient risks.
    • Potential for allergic reactions or skin irritation.
    • Microbiological contamination risks.
    • Improper use or misuse of the product.
  • Evaluate Likelihood and Severity: Assess the probability of each hazard occurring and the potential severity of any adverse effects.
  • Risk Mitigation Strategies: Implement measures to minimize identified risks. This may involve adjusting ingredient concentrations, adding preservatives, or including clear warnings and usage instructions on the label.
Additional Tips:
  • Stay Updated: Keep abreast of evolving scientific data and regulations regarding cosmetic safety.
  • Seek Expert Advice: Consider consulting with cosmetic scientists or regulatory specialists to ensure your safety substantiation practices are robust and compliant.
  • Transparency is Key: Clearly communicate safety information to consumers through product labels and readily accessible safety data sheets.
By following these detailed guidelines, businesses can ensure they meet MoCRA requirements and demonstrate their commitment to providing safe and effective cosmetic products.
Bottom Line
Complying with MoCRA not only ensures regulatory adherence but also enhances consumer trust and product credibility. By demonstrating a commitment to safety and transparency, you can build a loyal customer base and minimize the risk of legal and reputational issues.
Are MoCRA and Safety Substantiation Requirements complex for your cosmetic business? Do not worry !
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Health Canada’s Regulatory Plan 2024-26: Proposed Amendments to NHP and Non-Prescription Drugs

Health Canada has unveiled its Forward Regulatory Plan for 2024-2026, outlining significant amendments to the Natural Health Products Regulations and the Food and Drug Regulations under the Food and Drugs Act.  

These amendments are designed to align the regulatory approach for self-care products, ensuring a streamlined and risk-based framework that reflects contemporary standards. 

To better understand the proposed amendment, it’s essential to first understand Natural Health Products (NHPs) and Non-Prescription Drugs. 

What is NHP? 

Natural Health Products (NHPs) are a category of health products regulated by Health Canada. These products include a variety of items that support health and wellness through natural means. The category of health products include: 

  • Essential nutrients that support overall health and wellness. 
  • Herbal remedies or plant-based products used for their medicinal properties. 
  • Products based on homeopathy, a system of alternative medicine. 
  • Medicines used traditionally, such as those from traditional Chinese medicine or Ayurvedic medicine. 

Click to learn how you can get an NHP Licence for Nicotine Pouches in Canada? 

What is non-prescription drug? 

Non-Prescription Drugs are medications that can be purchased without a prescription from a healthcare professional. These drugs are also known as Over-the-Counter Drugs or OTC drugs. These drugs are made to treat common, self-diagnosed conditions and symptoms such as pain, fever, coughs, colds, and allergies.  

Examples of OTC drugs are Pain Relievers and Fever Reducers, Cough and Cold Remedies, Allergy Medications and Antacids and Acid Reducers.  

Click this link to learn more about non-prescription drugs, how you can sell it in Canada, and more facts about it.  

Now, let’s explore Health Canada’s Forward Regulatory Plan 2024-26 and outline significant amendments to the Natural Health Products Regulations and the Food and Drug Regulations under the Food and Drugs Act.    

Health Canada forward regulatory plan: key changes proposed 
  1. Simplified Pathways and Alignment:

Health Canada proposes a new system to fast-track approval for lower-risk non-prescription drugs. This system will align these OTC drugs with natural health products that have similar uses. The goal is to streamline the process while still ensuring that safety standards remain high. 

  1. Modernization of Natural Health Products Regulations:

The amendments also target the Natural Health Products Regulations, introducing a structured risk-based categorization system and enhanced quality oversight measures. 

Key proposals include: 
  • Annual Notification Requirement: Businesses will be required to annually notify Health Canada of marketed natural health products, enhancing transparency and regulatory oversight. 
  • Good Manufacturing Practices (GMP): Strengthening requirements for GMP will ensure that natural health products meet high standards of quality throughout the manufacturing process. 
  • Risk-Based Site Licensing: Introducing a risk-based site licensing program will enhance oversight of production facilities, further safeguarding product quality and consistency. 

These amendments are in response to recommendations from the Commissioner of the Environment and Sustainable Development’s 2021 audit, underscoring Health Canada’s commitment to addressing regulatory gaps and enhancing consumer confidence in natural health products. 

International alignment and impact 

While these changes aren’t part of a formal international cooperation plan, they will bring Canada’s regulations closer to those of the U.S., EU, and Australia. This alignment should make it easier for Canadian businesses to compete globally and ensure imported products meet Canadian standards. 

What it means for businesses and consumers 

The proposed amendments are expected to impact businesses involved in the sale and manufacture of natural health products and non-prescription drugs in Canada.  

  • For natural health products, the amendments promise strengthened oversight and improved assurance of product quality, aligning with global best practices.  
  • Meanwhile, amendments to the Food and Drug Regulations aim to maintain robust regulatory oversight while reducing administrative burdens and enhancing operational efficiencies for businesses. 
Consultations and stakeholder engagement 

Health Canada has engaged stakeholders extensively since 2016 and will continue to do so throughout 2024. The recent publication of regulatory amendments in the Canada Gazette, Part II on July 6, 2022, marked a significant milestone in this ongoing consultation process. These consultations are crucial for gathering feedback from industry stakeholders, healthcare professionals, and the public to ensure that the regulatory framework remains responsive and effective. 

Get assisted by Quality Smart Solutions 

For detailed insights into these regulatory changes and ongoing consultations, reach out to our team of former Health Canada experts at Quality Smart Solutions. We help ensure compliance with modernized regulations governing natural health products (NHPs) and non-prescription drugs, enhancing safety and quality standards across Canada while facilitating business growth and innovation.   

  

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Health Canada 2024 Drug Establishment Licensing (DEL) Update

Health Canada is introducing a new plan to modernize the Drug Establishment Licensing (DEL) framework over the coming years. This plan, divided into two phases, focuses on strengthening regulatory oversight, aligning with international standards, and easing administrative burdens. 

Before going into details of the update, let’s throw light on what DEL is and who needs it. 

What is Drug Establishment Licensing (DEL)?  

Health Canada’s Drug Establishment Licensing (DEL) is a regulatory framework that governs the licensing of establishments involved in the drug manufacturing and distribution process in Canada. The DEL program is designed to ensure that drugs and related products meet high standards of quality, safety, and efficacy before they are available on the Canadian market. 

Click here to learn more about DEL. 

Who Needs DEL?  

  • Manufacturers: Facilities that produce, package, or label drugs must obtain a DEL to ensure compliance with Good Manufacturing Practices (GMP). 
  • Distributors: Establishments involved in the import, export, and distribution of drugs also require a DEL. 
  • Importers/Exporters: Entities involved in importing or exporting drugs must hold a DEL to ensure adherence to regulatory requirements. 

Want to know why Drug Establishment Registration (DEL) is important for you? Read this blog 

2024 DEL Updates 

Here’s a breakdown of what DEL updates in 2024 by Health Canada mean and how they will impact your businesses and consultants involved in drug establishment licensing in Canada. 

What is the Drug Establishment Licensing Framework? 

The DEL framework governs the licensing of businesses that manufacture, package, label, import, distribute, and wholesale drugs in Canada. This framework ensures that drugs available to Canadians are safe, effective, and of high quality. 

Phase 1: Enhancing Drug Recall and Testing Regulations 

The first phase of Health Canada’s plan includes several important updates: 

  1. New Drug Recall Framework: A structured regulatory framework will be established for recalls ordered by the Minister of Health. This will streamline the recall process, ensuring faster and more efficient action to protect public health. 
  1. Clear Reporting for Voluntary Recalls: Businesses will have clear guidelines on their obligations for reporting voluntary recalls, aligning with current policies to improve transparency and accountability. 
  1. Updated Mutual Recognition Agreements (MRAs): Outdated references to regulatory authorities in mutual recognition agreements will be replaced with a dynamic list accessible on the Government of Canada website. This makes it easier for businesses to stay up-to-date with recognized authorities. 
  1. Testing Exemptions for Advanced Therapies: Conditional exemptions will be introduced for certain biologics (like gene and cell therapies) and radiopharmaceuticals from some finished product testing requirements. This will apply where alternative safety controls are in place, supporting the development and accessibility of these advanced treatments. 
  1. Direct Shipment Provisions: Clarification that certain biologics and radiopharmaceuticals can be directly shipped to healthcare practitioners or facilities. This helps ensure timely access to critical treatments. 
Phase 2: Streamlining Licensing and Compliance 

The second phase will focus on reducing the regulatory burden and modernizing compliance measures: 

  1. Simplified Annual Licence Review: The annual review process for establishment licences will be simplified, reducing the administrative workload for businesses and Health Canada. 
  1. Modern Compliance Tools: Provisions related to compliance and enforcement will be updated, including the use of terms and conditions and suspensions. This will provide a more flexible and effective regulatory framework. 
  1. Flexible Oversight: Less prescriptive regulations will be introduced, maintaining appropriate oversight while allowing more flexibility in regulated activities. This approach aligns with a risk-based regulatory philosophy, focusing resources where they are most needed. 
Benefits 2024 DEL Updates for Businesses and Consultants 

Enhanced Efficiency: The updated recall framework and clear reporting obligations will help businesses manage recalls more efficiently, minimizing disruptions and protecting their reputations. 

Simplified Compliance: By updating MRAs and introducing conditional exemptions, Health Canada is making it easier for businesses to navigate regulatory requirements, particularly for advanced therapies. 

You should know that MRAs are formal agreements between countries or regions to accept each other’s regulatory evaluations and certifications for certain products, services, or processes. 

Reduced Administrative Burden: The streamlined annual licence review and modern compliance tools will significantly reduce the time and effort businesses need to spend on regulatory processes. 

International Alignment: Aligning Canada’s regulations with those of major international partners like the U.S., EU, UK, Australia, and Switzerland will facilitate smoother trade and regulatory processes, benefiting Canadian businesses operating globally. 

What’s Next? 

Health Canada has been actively engaging with stakeholders throughout this process: 

  • Initial Consultations: Between April and June 2019, Health Canada consulted with DEL and Medical Device Establishment Licensing (MDEL) holders. 
  • Notice of Intent: In December 2021, a notice of intent was published in the Canada Gazette, Part I, followed by a 60-day comment period. 
  • Public Comments: Proposed changes for Phase 1 were pre-published in the Canada Gazette, Part I on April 15, 2023. During the 75-day comment period, Health Canada received feedback from 46 respondents, including individuals, businesses, and associations. 
Publication Timeline: 
  • The final regulations for Phase 1 are expected to be published in the Canada Gazette, Part II in spring 2024. 
  • Proposed amendments for Phase 2 will be pre-published in the Canada Gazette, Part I in winter/spring 2025, followed by another 75-day comment period. 

By modernizing the DEL framework, Health Canada aims to enhance drug safety, streamline regulatory processes, and support the growth of the pharmaceutical industry in Canada 

Businesses and consultants should prepare for these changes, which promise to bring greater clarity, efficiency, and international alignment to the regulatory landscape. 

How Quality Smart Solutions can help you 

At Quality Smart Solutions, we’re dedicated to helping you stay ahead of regulatory changes. Our team of experts is ready to guide you through the new DEL framework, ensuring your drug establishment practices meet the latest standards. Contact us today to learn how we can support your regulatory needs! 

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How to get an NHP Licence for Nicotine Pouches in Canada?

Remember the days of gumming patches, sucking lozenges, and hiding bulky vaporizers? Nicotine pouches, those discreet little packets promising rapid release and sleek satisfaction, are rewriting the playbook. But for NHP manufacturers, the thrill of this pocket-sized revolution comes with a hefty stack of regulatory paperwork.

Before you get lost in the regulatory labyrinth, let’s take a deep breath and unpack the stats. The global nicotine pouch market is expected to surge past $3 billion by 2027, propelled by a 21% annual growth rate. In Canada alone, nearly 2 million adults have embraced the pouch, proving they’re more than just a passing fad.

This booming market, however, is met with a regulatory hurdles, with Health Canada’s NHP regulations and the FDA’s premarket pathways posing a significant challenge for NHP manufacturers.

Navigating the Compliance Maze

  • Understanding the Landscape:
    • Health Canada’s NHP regs dictate labeling, ingredients, and safety claims.
    • The FDA requires premarket clearance or submission of Tobacco Product Applications (TPAs).
  • Common Pitfalls:
    • Misidentifying ingredients as NHP-compliant.
    • Making unsubstantiated health claims.
    • Omitting mandatory labeling elements.
  • The Perils of Non-Compliance:
    • Product seizure and market withdrawal.
    • Hefty fines and legal repercussions.
    • Damage to brand reputation and consumer trust.

Building Your Compliance Compass

  • Partnering with NHP Compliance Specialists:
    • Leverage their expertise in navigating regulations.
    • Ensure accurate ingredient verification and labeling.
    • Streamline the premarket approval process.
  • Investing in the Right Tools:
    • Utilize compliance software for ingredient databases and labeling templates.
    • Stay updated on regulatory changes and industry best practices.
    • Seek guidance from reputable sources like the Canadian NHP Network.

Compliance is Your Key to Business Success

Complying with regulations isn’t just about avoiding penalties; it’s your passport to success:

  • Market Access and Trust: Compliant products secure distribution channels and consumer confidence.
  • Sustainable Growth: Compliance safeguards your business from costly setbacks and builds a solid foundation for future expansion.
  • Building a Responsible Industry: Responsible compliance paves the way for a thriving and ethical nicotine pouch market.

Charting Your Journey

The path to nicotine pouch NHP success is paved with knowledge, preparation, and collaboration. With the right tools and partners, you can confidently navigate the compliance landscape and unlock the full potential of this dynamic market.

For inquiries about NHP Nicotine Pouch regulations or assistance with compliance and business growth, book a free consultation with our NHP experts at Quality Smart Solutions by filling out the form below.

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FDA Updates Yogurt Standard: Key Changes for Manufacturers

Attention all yogurt makers, big and small! The U.S. Food and Drug Administration (FDA) has finalized changes to the standard of identity for yogurt, effective January 1, 2024. These updates aim to modernize regulations while maintaining the core characteristics of this beloved food.

Here’s the scoop:

  • Yogurt’s getting a modern makeover. The FDA is updating its definition of yogurt to reflect newer ingredients and production methods, while still keeping it, well, yogurt-y. This means saying goodbye to separate standards for “lowfat” and “nonfat” yogurt.
  • Small businesses, listen up! The FDA knows complying with new rules can be tricky, especially for smaller yogurt producers. That’s why they released a Small Entity Compliance Guide (SECG). Think of it as a roadmap to understand the changes and how to adapt your labels and products.
  • What does this mean for me? If you’re a small yogurt maker, check out the SECG! It explains what you need to do to comply with the new rule by the January 1, 2024 deadline. It also has handy resources and answers to common questions.

So, what exactly are the changes?

  • Modernized Definition: Gone are separate categories for “low-fat” and “non-fat” yogurt. The new definition focuses on core elements: live and active cultures, smooth texture, and a characteristic tangy flavor. This allows for diverse milk bases, sweeteners, and thickeners. Almond milk yogurt with agave nectar? Plant-based yogurt packed with protein? All fall under the revised definition.
  • Ingredient Expansion: The permissible ingredient list grows, opening doors for exciting possibilities. Lactose-free yogurt with berries? Greek yogurt fortified with essential vitamins? Manufacturers can cater to various dietary needs and preferences, offering guilt-free indulgences and nutrient-rich options.
  • Transparency Tweak: While “low-fat” and “non-fat” labels disappear from the main label, fat content remains easily accessible. Manufacturers can voluntarily declare fat content alongside nutritional information, ensuring transparency for health-conscious consumers.

Implications for Manufacturers:

  • New Product Potential: The revised definition empowers developing novel yogurt creations, pushing the boundaries of flavor and functionality. Imagine unique offerings like plant-based yogurt with matcha or Greek yogurt infused with exotic spices.
  • Ingredient Sourcing: Collaboration with new suppliers of alternative milks, natural sweeteners, and plant-based thickeners becomes crucial. Diversifying ingredient palettes unlocks endless possibilities and caters to evolving consumer demands.
  • Labeling Revamp: Adapt labeling strategies to comply with new regulations. This involves revising ingredient lists, clarifying nutritional information, and exploring creative ways to highlight new ingredients and formulations.
  • Regulatory Navigation: Partnering with FDA compliance experts can smooth the transition and minimize potential risks. Navigating the updated standard can be complex, and expert guidance ensures a seamless adaptation process.

Adapting to the Change:

  • Review the FDA Final Rule and Small Entity Compliance Guide for detailed specifics and implementation timelines.
  • Assess existing products and identify opportunities for reformulation or new development under the revised definition.
  • Embrace innovation and experiment with new ingredients and formulations, pushing the boundaries of what yogurt can be.
  • Delight your customers with unique and exciting yogurt creations that cater to modern preferences.

The 2023 FDA Yogurt Standard Update marks a significant shift in the industry, paving the way for a more diverse and dynamic yogurt landscape. Manufacturers who stay informed, embrace change, and adapt to the new requirements stand to thrive and continue offering delicious and nutritious options for all to enjoy.

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Navigating GRAS Panels: A Guide to Best Practices

When it comes to introducing new substances into the world of food and dietary supplements, ensuring safety is paramount. The GRAS (Generally Recognized as Safe) designation plays a critical role in this process. The U.S. Food and Drug Administration (FDA) provides guidance on how to convene a GRAS panel effectively and responsibly, ensuring that the substances used are indeed safe for human and animal consumption. In this summary blog, we’ll explore the key takeaways from the FDA’s guidance on “Best Practices for Convening a GRAS Panel.

Understanding the GRAS Provision

GRAS, or “Generally Recognized as Safe,” is a designation that signifies that a substance is deemed safe for its intended use in food. However, obtaining this status is no small feat. The FDA offers valuable insights into this process, specifically when a GRAS panel’s input may be needed.

When Is a GRAS Panel Necessary?

In many cases, a proponent, the entity seeking GRAS status for a substance, may not require a GRAS panel to determine the safety of a new ingredient. The proponent can evaluate existing data and information independently. However, there are instances where the proponent might opt to consult a GRAS panel. This decision depends on the complexity of the substance or the potential need for expert opinions.

The Role of a GRAS Panel

A GRAS panel serves as a valuable resource, offering an expert assessment of the safety and suitability of a substance for its intended use. Importantly, the panel’s conclusion does not inherently establish general recognition of the substance’s safety. Instead, it serves as evidence that there is general acceptance within relevant scientific communities based on generally available information.

Choosing the Right GRAS Panel

The FDA emphasizes the importance of assembling a qualified and balanced panel. Members should possess subject matter expertise relevant to the scientific considerations associated with the intended conditions of use of the food substance. Only when a panel adequately represents a larger scientific community can its conclusions be considered “generally accepted.”

The Need for Expertise

A “GRAS panel” opinion carries weight only if its members have the expertise appropriate to address the safety questions specific to the substance in question. A panel consisting of scientists without the requisite expertise cannot establish “generally accepted” conclusions.

When a GRAS Panel May Not Be Necessary

In most cases, a robust GRAS conclusion can be reached without the input of a GRAS panel. Therefore, proponents should carefully assess whether the resources and efforts required to convene such a panel are warranted for their specific case.

FDA’s Guidance Recommendations

The FDA’s guidance offers recommendations for those considering GRAS panels:

  1. Identifying Panel Members: Ensure that GRAS panel members have appropriate expertise in the relevant field.
  2. Mitigating Bias: Take steps to reduce any potential bias or conflicts of interest among panel members to maintain the credibility of the panel’s output.
  3. Limiting Data and Information: Only provide GRAS panels with public information, avoiding trade secret data.

Conclusion

In summary, the FDA’s guidance on convening GRAS panels provides essential insights into the complex process of establishing the safety of food substances. The right choice between seeking a GRAS panel’s input or relying on independent evaluation depends on the circumstances. Ensuring that the panel is composed of qualified experts and that potential biases are minimized is crucial. Ultimately, the GRAS process plays a pivotal role in protecting the safety of consumers and maintaining the quality of the food supply.

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Navigating the Regulatory Landscape: Understanding FDA FURLS, FDA Approved, and FDA Registered Medical Devices

Navigating the Regulatory Landscape: Understanding FDA FURLS, FDA Approved, and FDA Registered Medical Devices

Introduction

The process of bringing a medical device to market in the United States involves stringent regulations imposed by the Food and Drug Administration (FDA). Understanding the distinction between FDA FURLS (FDA Unified Registration and Listing System), FDA Approved, and FDA Registered is crucial for manufacturers and distributors seeking to comply with these regulations. This article explores the differences between these designations and provides insights into how to obtain the necessary licenses for medical devices.

Device Registration and Listing Requirements

Since October 1, 2012, specific medical device listing requirements have been in effect. It is imperative for all stakeholders to adhere to these regulations:

  • All proprietary names under which a device is marketed must be reported during initial listing and in the annual update of registration and listing information.
  • Combination products, which include devices and biological products or drugs, must be clearly identified, specifying the type of combination product, such as convenience kit or prefilled drug delivery device, through the FDA Unified Registration and Listing System (FURLS).
  • Regardless of commercial distribution, all contract manufacturers and sterilizers of finished devices are obligated to register and list their products.
  • Initial importers must identify the manufacturers of the devices they import.
  • Foreign establishments exporting devices to the United States must identify all known U.S. importers of their devices.
  • Devices must be listed by the manufacturer, specification developer, single-use device reprocessor, remanufacturer, or re-packer/re-labeler before a foreign exporter, contract manufacturer, or contract sterilizer can list them.
  • Establishments handling complaints, previously registered as manufacturers or specification developers, should update their establishment type to “Complaint File Establishment.”

FDA Approved: Ensuring Safety and Efficacy

FDA approval refers to the process by which a new medical device undergoes rigorous evaluation to ensure its safety and efficacy before it can be marketed in the United States. The approval process involves the submission of a premarket approval (PMA) application or a 510(k) premarket notification, depending on the device’s classification. PMA applications are required for Class III devices, which are high-risk devices such as implantable pacemakers and certain diagnostic imaging devices. 510(k) premarket notifications are for devices that are equivalent to a legally marketed device (predicate device) and are typically lower risk.

FDA Registered: Establishment Compliance

FDA registration is a mandatory requirement for all medical device establishments. It involves providing detailed information about the facility, its operations, and the devices it manufactures, processes, packs, or holds. FDA-registered establishments are subject to inspections to ensure compliance with FDA regulations, including good manufacturing practices (GMP). Registration is a prerequisite for selling medical devices in the U.S. market, and failure to register can lead to serious consequences, including legal actions and fines.

How to Obtain Licenses? Step-by-Step Guide

  1. Determine Device Classification: Identify the correct classification of your medical device according to the FDA’s classification system (Class I, II, or III).
  2. Prepare Necessary Documentation: Depending on the device classification, prepare the required documentation, such as a 510(k) premarket notification or a PMA application. Work closely with regulatory experts and consultants to ensure the accuracy and completeness of the submission.
  3. Submit Application: Submit the application to the FDA along with the required fees. The FDA will review the submission and provide feedback or request additional information if necessary.
  4. Facility Registration: Concurrently, ensure that your establishment is registered in the FDA FURLS database. Update registration information annually to maintain compliance.
  5. Quality System Requirements: Implement a quality management system compliant with FDA regulations, including GMP. Prepare for FDA inspections to demonstrate compliance with quality system requirements.
  6. Post-Market Surveillance: Establish a post-market surveillance system to monitor the performance and safety of your device after it enters the market. Report adverse events and product issues promptly to the FDA.

Conclusion

Navigating the intricate regulatory landscape of medical device approval and registration demands a deep understanding of FDA FURLS, FDA Approved, and FDA Registered designations. By aligning with expert consultants and regulatory professionals, manufacturers and distributors can successfully obtain the necessary licenses, providing safe and effective medical devices to enhance healthcare outcomes for patients across the United States.

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device Registration, Facility Registration & FURLS, IVD Device Registration, and SaMD Classification.

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What is a CCP in HACCP? Understanding Critical Control Points and Regulatory Compliance

What is a CCP in HACCPIntroduction

In food safety management, Hazard Analysis and Critical Control Points (HACCP) is a systematic approach that ensures the production of safe food products.

At the heart of HACCP lies the identification and management of Critical Control Points (CCPs). This article delves into the significance of CCPs in HACCP, exploring their definition, importance, and the regulatory standards governing their implementation.

Defining Critical Control Points (CCPs)

A Critical Control Point (CCP) in HACCP refers to a step in the food production process where control can be applied to prevent, eliminate, or reduce food safety hazards to acceptable levels. These hazards include biological, chemical, or physical factors that can lead to contamination if not properly managed.

Importance of CCPs in HACCP

  1. Risk Reduction: CCPs are pivotal in reducing the risks associated with foodborne illnesses. Identifying and controlling these points significantly diminishes the likelihood of hazardous contamination.
  2. Quality Assurance: Implementing CCPs ensures consistency in product quality. Businesses can offer consumers reliable and safe food products by maintaining strict control at critical points.
  3. Compliance with Regulations: Regulatory bodies worldwide mandate the adoption of HACCP principles in the food industry. Identifying and managing CCPs not only ensures safety but also aids in complying with international food safety standards.

Regulatory Standards Governing CCPs

  1. FDA Food Safety Modernization Act (FSMA): Enforced in the United States, the FSMA emphasizes preventive measures. Businesses must implement HACCP-based food safety plans, including CCP identification and management.
  2. European Food Safety Authority (EFSA): The EFSA sets guidelines for CCP identification within the European Union, ensuring that food businesses adhere to rigorous safety standards.
  3. Codex Alimentarius Commission: This international body establishes food standards and guidelines. Codex HACCP principles, including CCP identification, serve as a benchmark for global food safety practices.

CCP Implementation Process

  1. Conducting a Hazard Analysis: The first step involves identifying and assessing potential hazards in the production process. These can include biological risks like pathogens, chemical hazards, or physical contaminants.
  2. Determining Critical Control Points: Based on the hazard analysis, businesses identify CCPs. These are specific points in the production process where control measures are applied to mitigate the identified risks.
  3. Establishing Critical Limits: CCPs must operate within specific limits to ensure safety. Establishing critical limitations involves setting boundaries for factors such as temperature, time, pH levels, and microbial counts.
  4. Implementing Monitoring Procedures: Continuous monitoring of CCPs is essential. This involves regular checks, measurements, and observations to maintain critical limits.
  5. Corrective Actions: Protocols are established to address deviations from critical limits. When a CCP falls out of the acceptable range, disciplinary actions are taken to bring the process back under control.
  6. Verification and Record-Keeping: The effectiveness of CCPs is regularly verified through methods like testing and audits. Detailed records of monitoring, corrective actions, and verification activities are maintained as proof of compliance.

Conclusion

Understanding Critical Control Points (CCPs) in the context of HACCP is paramount for ensuring food safety, quality, and regulatory compliance. By systematically identifying, monitoring, and controlling CCPs, food businesses can uphold the highest standards, safeguard consumers, and thrive in an industry where safety is paramount. Compliance with established regulations is a legal requirement and a commitment to consumers’ well-being, making CCPs a cornerstone in the global food industry.

Resources:

HACCP Process and CCP

The evolution of food safety standards

Why are HACCP consultants important?

7 principles of HACCP and how they impact food safety

HACCP to CCPs Food Standards Evolution

How can Quality Smart Solutions serve you?

Firstly, QSS can help with formula review, product labeling, and nutrition facts creation (for Canada and the USA).

Secondly, we can also help with registering supplemented foods with TMALs (Temporary Market Authorization License) or reviewing when the new Supplemented Food Regulations are published. 

Thirdly, we help with Safe Foods for Canadians Regulations (HACCP, PCP, Import Licensing, and GRAS Notifications). 

Help with facility registration, FSVP agent, and US Agent. 

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Expert guide to GRAS Pathways: GRAS Notice vs. Self-Affirmed

A Comprehensive Guide to GRAS Pathways: GRAS Notice vs. Self-AffirmedNavigating the intricate landscape of food and food additive regulation in the United States involves understanding the GRAS concept – “Generally Recognized as Safe.” GRAS status is a pivotal determinant of whether a substance can be used in food without requiring formal approval from the U.S. Food and Drug Administration (FDA). This status relies on two primary pathways: the GRAS Notice and Self-Affirmed GRAS. In this article, we’ll explore these pathways in-depth, highlighting their differences, processes, and significance for businesses in the food industry.

Deciphering GRAS: What It Means

Before delving into the two GRAS pathways, it’s essential to grasp the essence of “Generally Recognized as Safe.” When a substance achieves GRAS status, qualified experts have reached a consensus that it is safe for its intended use in food based on rigorous scientific evaluations of its safety profile.

GRAS Notice: The Regulatory Route

1. Definition: The GRAS Notice pathway necessitates the submission of a formal notification to the FDA, accompanied by comprehensive scientific evidence and data substantiating the substance’s safety. The FDA meticulously reviews the compliance and affirms or disputes the GRAS status.

2. Scientific Evidence: Crafting a GRAS Notice mandates compiling substantial scientific evidence. This evidence encompasses toxicological studies, clinical trials, and historical data demonstrating the substance’s safety.

3. Independent Panel Review: A distinctive aspect of the GRAS Notice process is the engagement of an independent panel of experts. This panel meticulously evaluates the safety data and provides an impartial opinion on whether the substance qualifies as GRAS.

4. FDA’s Verdict: Following the company’s submission and the independent panel’s evaluation, the FDA conducts its independent review. If the FDA concurs with the GRAS determination, it issues a “no questions” letter, effectively confirming the substance’s GRAS status. Should the FDA have inquiries or concerns, it may release a response outlining the need for additional data or clarifications.

Self-Affirmed GRAS: The Internal Affirmation

1. Definition: The Self-Affirmed GRAS pathway empowers a company to establish a substance’s GRAS status without submitting a formal notification to the FDA. This method hinges on the company’s self-assessment and the consensus of qualified experts.

2. Scientific Evidence: In the Self-Affirmed GRAS route, companies must still compile extensive scientific evidence attesting to the substance’s safety. Experts within the company or external consultants usually evaluate and assess this evidence.

3. Internal Expert Consensus: A crucial distinction in Self-Affirmed GRAS is that the determination resides within the company. It is paramount that the company can provide evidence of consensus among qualified experts regarding the substance’s safety.

Key Differences and Strategic Insights

  • FDA Involvement: The most notable distinction between the two pathways lies in the level of FDA engagement. GRAS Notice mandates formal FDA review and approval, imparting a higher degree of FDA endorsement. In contrast, Self-Affirmed GRAS relies on the company’s internal evaluation.
  • Independent Panel: The GRAS Notice’s requirement for an independent expert panel can bolster the credibility of the GRAS determination. Self-affirmed GRAS does not require an independent panel but may involve external experts.
  • Transparency: GRAS Notice offers a more transparent process, which entails public access to information submitted to the FDA. Self-affirmed GRAS determinations are not compelled to be made public, though many companies voluntarily do so.
  • Legal Liability: Both pathways come with legal responsibility. Suppose a substance is later found to be unsafe. In that case, the FDA can take action against the company that made the GRAS determination, irrespective of the chosen pathway.

Conclusion

In summary, the GRAS pathways, GRAS Notice and Self-Affirmed GRAS, provide flexibility for companies seeking to establish the safety of substances in food products. Choosing the correct path hinges on several factors, including available resources, desired FDA involvement, and transparency preferences. Regardless of the pathway selected, ensuring the safety of food additives and substances’ safety is paramount, as it directly influences consumer health and trust in the food industry. Navigating these pathways with care and consideration is essential for the success of food businesses in the United States.

We hope this post helped you understand food additives and preservatives a little better. There are many different kinds, and they can have a big impact on your health and the environment. If you want to learn even more about GRAS, reach out to us today about GFSI certification requirements, GRAS Notifications, or GRAS self-affirmation!

Gras License Process

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From A to Z: Everything You Need to Understand About GRAS Substances

Gras License ProcessAre you curious about GRAS substances? Look no further! This comprehensive guide takes you from A to Z, covering everything you need to know about GRAS substances. Whether you’re a novice or an expert, this article will provide a solid understanding of GRAS substances and their importance.

GRAS substances, also known as Generally Recognized as Safe Substances, have been tested and approved by regulatory authorities for their safety when used in food, drugs, cosmetics, or other applications. Understanding GRAS substances is crucial to ensuring the safety of the products we consume daily.

This article will explore the history and regulations surrounding GRAS substances, their uses and applications, and discuss the latest research and controversies. This article will equip you with the knowledge you need to navigate the world of GRAS substances. Let’s dive in!

What are the types of GRAS substances?

GRAS, also known as Generally Recognized as Safe Substances, encompasses a wide range of compounds thoroughly tested and approved for their safety. These substances are commonly used in various industries, including food, drugs, cosmetics, etc. There are several categories of GRAS substances, each serving a specific purpose.

1. Food Additives: Food additives are GRAS substances added to food products to enhance flavor, texture, appearance, or shelf life. These can include preservatives, sweeteners, coloring agents, and emulsifiers. Food additives are regulated to ensure they do not pose health risks when consumed within acceptable limits.
2. Pharmaceutical Excipients: Pharmaceutical excipients are GRAS substances that are used in the manufacturing of medications. These substances play a crucial role in drug formulation, helping to improve stability, solubility, and absorption. Examples of pharmaceutical excipients include fillers, binders, disintegrants, and lubricants.
3. Cosmetic Ingredients: Many cosmetic ingredients fall under the category of GRAS substances. These can include moisturizers, emollients, surfactants, and preservatives. The safety of these ingredients is carefully evaluated to ensure they do not cause any harm to the skin or overall health when used as directed.

Uses and applications of GRAS substances

Everything You Need to Understand About GRAS Substances

GRAS substances have a wide range of uses and applications across various industries. Let’s explore some of the most common areas where GRAS substances play a vital role.

1. Food Industry: In the food industry, GRAS substances are used to improve the taste, appearance, and safety of food products. Food additives, such as preservatives and antioxidants, help extend the shelf life of perishable items and prevent spoilage. Flavor enhancers and color additives enhance the sensory experience of food.
2. Pharmaceutical Industry: GRAS substances are essential in the pharmaceutical industry, where they are used as excipients to aid in the manufacturing and formulating medications. These substances ensure that drugs are stable, effective, and safe for consumption. Without GRAS substances, the production of many medications would not be possible.
3. Cosmetics Industry: In the cosmetics industry, GRAS substances are used to create safe products for the skin and hair. Moisturizers, emollients, and humectants help hydrate and nourish the skin, while preservatives prevent the growth of harmful bacteria and fungi. With GRAS substances, the cosmetic industry could create products that meet safety standards.

Research and studies on GRAS substances

GRAS substances have been extensively researched to ensure their safety and efficacy. Regulatory authorities, scientific organizations, and independent researchers continually evaluate GRAS substances’ potential risks and benefits. Here are a few notable research findings:

1. Long-Term Safety Studies: Many GRAS substances have undergone long-term safety studies to assess their potential risks when used over an extended period. These studies help ensure that GRAS implications remain safe for consumption or use.
2. Allergenicity Testing: Researchers have tested allergenicity on various GRAS substances to identify potential allergens and sensitizing agents. This research helps individuals with known allergies or sensitivities avoid exposure to GRAS substances that may trigger adverse reactions.
3. Efficacy Studies: Some GRAS substances, particularly those used in medications, have been subject to efficacy studies to determine their effectiveness in treating specific conditions. These studies help healthcare professionals make informed decisions when prescribing medications.

Are GRAS substances regulated?

GRAS substances are regulated by various regulatory authorities, such as the Food and Drug Administration (FDA) in the United States. These authorities evaluate the safety and efficacy of GRAS substances before they can be used in food, drugs, or cosmetics.

Additional Reading about GRAS:

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Everything businesses should know about the Supplemented Foods Facts Table (SFFT)

Supplemented Foods Facts TableIntroducing the Supplemented Foods Facts Table (SFFT), your go-to guide for navigating the ever-changing world of supplemented foods. With consumer demand skyrocketing for these products, grasping the SFFT is vital for businesses looking to excel in this booming market.

In this article, we’ll unravel everything you need to know about the SFFT, from its purpose to its must-follow rules. We’ll also explore how it can empower your business to effectively convey your supplemented food products’ benefits and nutritional value to consumers. Whether you’re a fresh-faced startup or a seasoned brand, consider this article your trusty companion for mastering the Supplemented Foods Facts Table.

Whether you’re a small startup or an established brand, this article is your go-to resource for understanding and complying with the SFFT. Stay ahead of the competition and enhance consumer trust by mastering the ins and outs of the Supplemented Foods Facts Table.

Why is the SFFT important for businesses?

The Supplemented Foods Facts Table (SFFT) is an essential tool for businesses operating in the supplemented foods industry. This table gives businesses a standardized format to communicate important product information to consumers. By including the SFFT on product labels, companies can ensure that consumers can access accurate and transparent information about their supplemented food products’ nutritional content and benefits.

The SFFT is crucial in building consumer trust and confidence in supplemented foods. With the increasing interest in health and wellness, consumers are becoming more conscious about the nutritional value of their products. By providing clear and comprehensive information through the SFFT, businesses can meet this demand and differentiate themselves in the market.

Furthermore, the SFFT helps businesses comply with regulatory requirements. Many countries have specific regulations that mandate the use of SFFT on product labels. By adhering to these regulations, companies can avoid potential legal issues and ensure that their products comply with industry standards.

In summary, the SFFT is essential for businesses because it allows them to communicate vital information to consumers, build trust, comply with regulations, and differentiate themselves in the competitive supplemented foods market.

What are the components of the Supplemented Foods Facts Table SFFT?

To effectively create a compliant SFFT for your products, it is essential to understand the critical components of the table. The SFFT consists of several sections, each providing specific information about the supplemented food product. Let’s take a closer look at these components:

1. Serving Size: This section indicates the recommended serving size of the product. Determining an appropriate serving size that accurately reflects how consumers typically consume the product is vital.
2. Calories: The product’s calorie content is displayed in this section. It provides consumers with an understanding of the energy value of the product.
3. Total Fat: This section includes information about the total fat content of the product, including the amount of saturated and trans fats. It is essential to disclose this information as it helps consumers make informed choices about their dietary intake.
4. Cholesterol: The cholesterol content of the product is displayed in this section. High cholesterol levels can have adverse health effects, so providing this information to consumers is essential.
5. Sodium: This section indicates the sodium content of the product. High sodium intake can harm health, so disclosing this information allows consumers to manage their sodium intake effectively.
6. Total Carbohydrates: This section provides information about the total carbohydrate content of the product, including dietary fiber and sugars. It helps consumers understand the carbohydrate composition of the product, which is particularly important for individuals following specific diets.
7. Protein: The product’s protein content is displayed in this section. Protein is an essential nutrient, and disclosing this information helps consumers decide based on their dietary needs.
8. Vitamins and Minerals: This section lists the vitamins and minerals present in the product and their respective quantities. It is crucial to provide this information as it allows consumers to assess the product’s nutritional value.

By understanding these components, businesses can create a comprehensive and accurate SFFT for their supplemented food products.

How do you create a compliant SFFT for your products?

Creating a compliant SFFT for your products involves following specific guidelines and regulations. Here are the steps to ensure your SFFT meets the requirements:

1. Research Regulatory Requirements: Research the specific regulatory requirements for SFFT in your target market. Different countries may have varying guidelines and regulations, so it is crucial to understand and comply with the relevant standards.
2. Gather Accurate Nutritional Data: Collect accurate and up-to-date nutritional data for your supplemented food products. This includes information on serving sizes, calories, fats, cholesterol, sodium, carbohydrates, protein, vitamins, and minerals. Ensure that a reputable source or laboratory verifies the data.
3. Organize the SFFT: Use a standardized format to organize the SFFT. The table should be clear, readable, and prominently displayed on the product label. Use bold headings, appropriate font size, and spacing to enhance readability.
4. Calculate Percent Daily Values: The percent daily values (%DV) for each nutrient listed in the SFFT. %DV indicates the proportion of a specific nutrient in the product relative to the recommended daily intake. This information helps consumers understand the nutritional significance of the product.
5. Review for Accuracy and Compliance: Double-check the SFFT for accuracy and compliance with regulatory requirements. Ensure that all information is correctly displayed and that there are no misleading or false claims. It is advisable to consult with experts or regulatory bodies to verify the compliance of your SFFT.

By following these steps, businesses can create a compliant SFFT that provides accurate and transparent information to consumers.

Tips for optimizing your SFFT for consumer understanding

Creating a compliant SFFT is essential, but optimizing the table for consumer understanding is equally important. Here are some tips to help you achieve this:

1. Use Simple Language: Avoid technical jargon and use simple language that is easy for consumers to understand. Break down complex terms and provide explanations where necessary.
2. Provide Context: Supplement the SFFT with additional information or context to help consumers make informed decisions. For example, you can briefly describe the product’s benefits or usage instructions.
3. Consider Visual Aids: Incorporate visual aids, such as icons or symbols, to enhance the readability of the SFFT. These visual cues can help consumers quickly identify essential information, such as allergen warnings or nutritional highlights.
4. Highlight Key Nutrients: Use formatting techniques, such as bold or colored text, to highlight critical nutrients or beneficial ingredients. This can draw consumers’ attention to the nutritional value of the product.
5. Include Additional Information: Consider including additional information, such as allergen statements, dietary claims, or certifications, to further enhance consumer understanding and trust.
By optimizing the SFFT for consumer understanding, businesses can effectively communicate their supplemented food products’ benefits and nutritional value.

What are the common mistakes to avoid when creating an SFFT?

While creating an SFFT, businesses should be aware of common mistakes that can compromise the accuracy and compliance of the table. Here are some errors to avoid:

1. Inaccurate Nutritional Data: Ensure that the nutritional data used in the SFFT is accurate and current. Refrain from relying on outdated or incorrect information to mislead consumers and result in non-compliance with regulations.
2. Misleading Serving Sizes: Provide serving sizes that accurately reflect how consumers consume the product. Misleading serving sizes can misrepresent the product’s nutritional content and confuse consumers.
3. Omitting Key Nutrients: Include all relevant nutrients in the SFFT. Omitting vital nutrients can mislead consumers and result in non-compliance with regulations.
4. False or Misleading Claims: Avoid making false or misleading claims in the SFFT. All information should be accurate, transparent, and supported by scientific evidence.
5. Non-compliance with Regulations: Stay updated with the latest regulations and guidelines for SFFT. Non-compliance can lead to legal issues and damage the reputation of your business.

By avoiding these common mistakes, businesses can ensure the accuracy, compliance, and effectiveness of their SFFT.

What is the role of the SFFT in product labeling and marketing?

The Supplemented Foods Facts Table (SFFT) is vital in product labeling and marketing. Here’s how the SFFT contributes to these aspects:

1. Transparency and Consumer Trust: By including the SFFT on product labels, businesses demonstrate transparency and provide consumers with accurate and comprehensive information about their supplemented food products’ nutritional content and benefits. This builds trust and confidence in the brand.
2. Differentiation and Competitive Advantage: The SFFT allows businesses to differentiate by highlighting their products’ nutritional value and benefits. Companies can attract health-conscious consumers and gain a competitive advantage by effectively communicating this information.
3. Educating Consumers: The SFFT is an educational tool that helps consumers make informed choices about their dietary intake. By providing clear and understandable information, businesses empower consumers to make healthier and more conscious decisions.
4. Compliance with Regulations: The SFFT ensures compliance with regulations set by governing bodies. By adhering to these regulations, businesses avoid legal issues and maintain the integrity of their product labeling.

The SFFT is crucial in product labeling and marketing by promoting transparency, differentiation, consumer education, and regulation compliance.

What are the regulatory considerations for the SFFT?

When creating an SFFT, businesses must consider the specific regulatory requirements in their target market. Here are some regulatory considerations to keep in mind:

1. Country-specific Guidelines: Different countries may have specific guidelines and regulations for SFFT. Research and understand the requirements of your target market to ensure compliance.
2. Language Requirements: Some countries may have language requirements for the SFFT. Ensure that the table is presented in the appropriate language(s) for your target market.
3. Formatting and Placement: Regulatory bodies may have specific requirements for the formatting and placement of the SFFT on product labels. Familiarize yourself with these guidelines to ensure compliance.
4. Health Claims and Disclaimers: Some countries have strict regulations regarding health claims and disclaimers on product labels. Ensure that any claims made in the SFFT are supported by scientific evidence and comply with these regulations.
5. Updates and Changes: Stay updated with any changes or updates to the regulatory requirements for SFFT in your target market. Regularly review and revise your SFFT to ensure continued compliance.
By considering these regulatory aspects, businesses can create an SFFT that meets the specific requirements of their target market.

Resources for businesses to learn more about the SFFT

As businesses navigate the world of supplemented foods and the requirements of the Supplemented Foods Facts Table (SFFT), it is essential to have access to reliable resources. Here are some valuable resources to learn more about the SFFT:

1. Regulatory Bodies: Consult the websites and publications of regulatory bodies in your target market. These organizations often provide detailed guidelines and resources related to SFFT.
2. Industry Associations: Join industry associations or organizations specializing in the supplemented foods sector. These associations often provide resources, webinars, and workshops to help businesses understand and comply with SFFT requirements.
3. Professional Consultants like Quality Smart Solutions: Seek guidance from professional consultants who specialize in food labeling and compliance. These experts can provide personalized advice and assistance tailored to your business needs.
4. Online Research: Conduct online research to access articles, studies, and publications related to the SFFT. Many reputable sources provide free information and resources to help businesses better understand the topic.

Remember to verify the credibility and relevance of the resources you consult to ensure accurate and up-to-date information.

Conclusion: The future of the SFFT in the food industry.

The Supplemented Foods Facts Table (SFFT) is an essential tool for businesses operating in the supplemented foods industry. As consumer demand for transparent and nutritious products continues to rise, the SFFT plays a crucial role in providing accurate and comprehensive information to consumers. By understanding the components of the SFFT, following regulatory guidelines, and optimizing the table for consumer understanding, businesses can effectively communicate the benefits and nutritional value of their supplemented food products. Compliance with regulations ensures transparency, builds consumer trust, and enhances the competitiveness of businesses in the market.

As the food industry evolves, the SFFT will likely play a significant role in product labeling and marketing. By staying updated with regulatory changes and industry trends, businesses can adapt and thrive in the dynamic landscape of supplemented foods. Remember, the Supplemented Foods Facts Table is not just a regulatory requirement but an opportunity for businesses to showcase their commitment to transparency, health, and consumer satisfaction. Mastering the ins and outs of the SFFT will position your business for success in the ever-growing market of supplemented foods.

Click here to learn about the Supplemented Facts Table Regulations.

Quality Smart Solutions has a team of professionals to offer support from day one of starting your business, including formulation and label reviews, Veterinary Health Product notifications and more.

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Medical Device Compliance in Canada: A Guide for Manufacturers


So, you’re a medical device manufacturer eyeing the Canadian market? Great choice! But before you dive in, let’s talk about the regulatory hoops you’ll need to jump through. Selling medical devices in Canada comes with its own set of rules, and trust me, you want to be on the right side of these regulations. This article will discuss the key steps and considerations for ensuring your medical devices meet Canadian compliance standards.

1. Who’s the regulatory boss in Canada?

First, Health Canada is the big cheese, specifically the Medical Devices Directorate (MDD). They’re the folks overseeing all things medical devices. Their rulebook is called the Canadian Medical Devices Regulations (CMDR) and is your go-to guide.

2. Know your device

Before anything else, you must determine where your device fits into Canada’s risk-based classification system. There are four classes (Class I to IV), each with its own rules. Knowing where your device falls is like the North Star guiding you through the compliance maze.

3. Get yourself a partner in Canada

You’ll need a friend there if you’re not based in Canada. Specifically, a Canadian Medical Device License (MDL) holder or agent. This person or entity will be your point person for Canadian regulations and keep you in the loop with Health Canada.

4. Register your Facility

Your manufacturing facilities must be registered with Health Canada through the Establishment Licensing and Medical Device Establishment Registration (MDEL) system. Expect questions about your facility, its activities, and other nitty-gritty details.

5. Quality is Key

Implement a Quality Management System (QMS) that follows the ISO 13485 standard. It’s the international gold standard for medical devices. Your QMS should cover everything from the design phase to distribution.

6. License to Thrill

You’ll need a Medical Device License (MDL) from Health Canada for most medical devices. Think of it as your golden ticket to sell legally in Canada. Your application should be detailed and backed up with proof of CMDR compliance.

7. Labeling Love

Make sure your device’s labeling and packaging are up to snuff with Canadian requirements. It’s bilingual, baby! English and French, please. You must include device details, manufacturing info, and usage instructions.

8. Watch and Learn

Please set up a system for keeping tabs on your devices after they hit the market. If anything goes south, you need to be ready to report it to Health Canada. Safety first, always!

9. Money Talks

Remember fees. There are application fees for licensing and annual fees for keeping that MDL shining. Approval times vary, so budget and plan accordingly.

10. Stay in the Know

Canadian regulations can change, just like anywhere else. Keep your ear to the ground for updates because compliance is a journey, not a destination.

Medical device manufacturers relying on Regulatory Experts

Making your mark in the Canadian medical device market can be daunting. The labyrinth of regulations, registrations, and quality standards can leave even the savviest manufacturers scratching their heads. That’s where regulatory consultants come to the rescue. 

The case of swift Registration

Imagine this: You’re a medical device manufacturer based outside Canada and eager to tap into the lucrative Canadian market. You’ve done your homework, but the paperwork for registering your manufacturing facility with Health Canada is overwhelming. Enter the regulatory consultant. They help you understand the complex requirements and streamline the process. With their guidance, your facility gets registered swiftly, giving you the green light to start the licensing process.

The license to sell

Once your manufacturing facility is cleared, the next hurdle is obtaining a Medical Device License (MDL). Here’s where another manufacturer’s story comes into play. They had tried navigating the application process independently. Still, they were met with delays and confusion. Frustrated, they turned to a regulatory consultant with in-depth knowledge of the Canadian system. With their expert guidance, the application was error-free and supported by a robust quality management system (QMS), significantly expediting the license approval.

Acing the labelling game

Picture this: You’ve secured your MDL and are all set to launch your medical device in Canada. But wait, have you got the bilingual labelling right? This is where another manufacturer found itself in a bind. Their labelling didn’t meet Canadian requirements, risking their entire launch. Thankfully, their regulatory consultant was quick to spot the issue. They helped redesign the labeling and ensure it complied with Canadian regulations, saving the day and their product launch.

4. The long-term partnership

These success stories aren’t just about one-off solutions. They highlight the lasting partnerships manufacturers develop with regulatory consultants. These experts assist with immediate compliance needs and keep a watchful eye on regulatory updates. This vigilance ensures that manufacturers stay ahead of the curve, making necessary adjustments to their processes and products to remain compliant.

Why do Medical Device Manufacturers trust experts like Quality Smart Solutions?

So, why do medical device manufacturers rely so heavily on regulatory consultants? It’s simple: expertise and peace of mind. Professionals like ours bring years of experience and an in-depth understanding of the ever-evolving medical device regulations. We’ve seen it all and know how to navigate the complexities.

Our consultants are proactive. They anticipate changes in regulations, helping manufacturers adapt before issues arise. This forward-thinking approach saves time and resources in the long run. Having an expert by your side is a strategic advantage in medical device compliance, where the stakes are high. It’s not just about meeting regulations; it’s about ensuring your products are safe, effective, and ready to serve the Canadian market without hiccups. Manufacturers trust experts like ours to forge partnerships that lead to success stories and smooth market entry.

In Conclusion

Getting your medical devices into the Canadian market is brilliant but challenging. Registering your facilities, securing the correct licenses, and maintaining quality standards are all part of the game. Consider teaming up with a regulatory consultant who knows the Canadian ropes—they’ll be your best friend through this process. With a bit of patience and diligence, you can conquer the world of medical device compliance in Canada and offer your products to a whole new audience, all while ensuring they’re safe and effective.

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice in Canada and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device Registration, Facility Registration & FURLS, IVD Device Registration, and SaMD Classification

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Selling Food in Canada: Navigating the Requirements for Conventional and Supplemented Products

This article will explore what it takes to sell food in Canada, from staple products to those with added supplements.Canada is known for its diverse culinary landscape. If you’re considering selling food products in this country, you’re in for a rewarding venture. However, it’s essential to understand the specific requirements and regulations governing the sale of conventional and supplemented food items. This article will explore what it takes to sell food in Canada, from staple products to those with added supplements.

1. Regulatory Framework: Understanding the Basics

First, let’s delve into the regulatory framework shaping the Canadian food industry. The Canadian Food Inspection Agency (CFIA) and Health Canada jointly oversee food regulations, with the CFIA primarily responsible for enforcing these rules. This agency ensures that food products meet safety and labeling standards, regardless of type.

2. Conventional Food Products: Compliance Essentials

Selling conventional food items in Canada comes with specific requirements. Here are some key aspects to consider:

  • Labeling and Packaging: Food labels must display essential information such as the product name, ingredient list, nutrition facts, allergen declarations, and the manufacturer’s contact details. Ensuring accuracy and compliance with labeling regulations is paramount.
  • Safety Standards: Conventional foods must meet safety standards to prevent contamination and ensure they are fit for consumption. This includes adherence to good manufacturing practices (GMPs) and maintaining sanitary conditions throughout production.
  • Product Classification: Different categories of food may be subject to distinct regulations. Understanding how your product is classified is crucial in ensuring compliance.

3. Supplemented Food Products: Extra Considerations

When it comes to selling supplemented food products in Canada, additional requirements come into play:

  • Health Claims: If your product makes health claims related to supplements or functional ingredients, you must ensure these claims are substantiated by scientific evidence and approved by Health Canada. Unverified claims can lead to regulatory issues.
  • Natural Health Products: If your supplemented food product falls into the category of natural health products, it may be subject to separate regulations. Compliance with the Natural Health Products Regulations is necessary in such cases.
  • Ingredient Approval: Ingredients added to supplemented foods must be approved in Canada. Health Canada maintains a list of permitted food additives and supplements; any new ingredients must undergo a rigorous assessment.

4. Licensing and Registration: The Basics

Whether you’re selling conventional or supplemented food products, certain businesses may need to register or obtain a license with the CFIA. Factors such as the type of product and its intended use can impact whether these requirements apply to your operation.

5. Import and Export Considerations

If you’re importing food into Canada or exporting Canadian food products abroad, additional regulations and documentation may come into play. This includes compliance with international standards and trade agreements.

6. Staying Informed and Compliant

The regulatory landscape for selling food in Canada is dynamic, and it’s crucial to stay informed about updates and changes. Engaging with regulatory experts, conducting thorough research, and seeking guidance from the CFIA and Health Canada can help you navigate the requirements successfully.

In conclusion, selling food in Canada involves adherence to specific regulations and standards, whether conventional or supplemented. Understanding and complying with these requirements ensures your products are safe, accurately labeled, and ready to delight Canadian consumers and meet their dietary needs.

Check out our 10 tips for preparing for the SFCR License Application process.

Our Experts at Quality Smart Solutions offer support with understanding the Safe Foods for Canadians Regulations and applying for the SFCR License.

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FDA 510(k) Clearance: Unveiling the Medical Device Regulations.

This article will break down the regulatory complexities of FDA 510(k) clearance, including submission requirements, classification, and more.

Navigating the intricate world of medical devices can be daunting, especially when it comes to ensuring their safety and effectiveness. In the United States, the FDA 510(k) clearance process is the critical checkpoint manufacturers must pass before introducing medical devices. This article will break down the regulatory complexities of FDA 510(k) clearance, including submission requirements, classification, and more.

1. Decoding the FDA 510(k) Clearance: What Does It Mean?

At its core, FDA 510(k) clearance is the pathway through which manufacturers gain approval to sell their medical devices in the U.S. This regulatory process is named after Section 510(k) of the Food, Drug, and Cosmetic Act, which outlines the requirements that must be met to obtain this clearance. Essentially, it’s the FDA’s way of ensuring that new or modified medical devices are safe and effective.

2. What’s Needed for Submission?

Manufacturers must embark on a detailed journey when submitting a 510(k) premarket notification to the FDA. This submission is a comprehensive dossier that provides evidence that the device is substantially similar to an already legally marketed device, known as a “predicate device.” The submission includes information about the device, labeling, and any proposed changes.

3. Understanding Device Classification: How Risk Plays a Role

One of the first crucial steps in this process is determining the classification of the medical device. The FDA classifies devices into three categories—Class I, II, and III—based on their complexity and level of risk. This classification dictates the level of regulatory scrutiny and the type of evidence required for clearance.

4. Substantial Equivalence: The Heart of the Matter

Substantial equivalence is the linchpin of the 510(k) clearance process. Manufacturers must present compelling evidence showcasing how their device is akin to the predicate device, including aspects like safety, performance, and technological distinctions.

5. Quality Matters: Embracing Quality System Regulations (QSR)

Ensuring the quality of medical devices is paramount. The FDA’s Quality System Regulations (QSR), outlined in 21 CFR Part 820, dictate manufacturers’ standards. These standards encompass everything from design and manufacturing practices to labeling and post-market surveillance.

6. Clinical Data and Testing: Ensuring Safety and Effectiveness

Clinical data may be required depending on the device’s classification and any variances from the predicate device. This data includes bench testing, animal studies, or clinical trials. It’s the bedrock upon which safety and effectiveness claims are built.

7. The FDA Review Journey: A Dialogue with Experts

After the submission, the FDA performs a thorough review, examining the device’s scientific, technical, and clinical aspects. This is also when manufacturers discuss with the FDA to address any questions or concerns.

8. Beyond Clearance: Your Health in Focus

When the FDA issues a 510(k) clearance letter, it signifies the device’s green light for the U.S. market. However, the story doesn’t end there. Manufacturers uphold post-market surveillance and reporting requirements to ensure your safety and the device’s ongoing effectiveness. Manufacturers should know the steps or partner with a regulatory consultant to provide medical devices that have a real and positive impact on their target consumers.

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device Registration, Facility Registration & FURLS, IVD Device Registration, and SaMD Classification

To learn when and how to file your 510k submissions click here:

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Everything to know about Drug Registration & NDC drug number

drug registration, NDC number

The pharmaceutical industry ensures public health by developing, manufacturing, and distributing safe and effective medications. For any drug to be legally marketed in the United States, it must undergo a rigorous drug registration process and receive a National Drug Code (NDC) number. This article will delve into the essential aspects of drug registration and the significance of the NDC drug number in healthcare.

Understanding Drug Registration

Drug registration is a crucial step in the pharmaceutical industry that involves obtaining regulatory approval from government agencies to market a drug product. This process ensures that all medications meet strict safety and efficacy standards before making them available. Here’s a breakdown of critical components and steps involved in drug registration:

1. Preclinical Development: Before a drug can even be considered for registration, extensive preclinical research is conducted. This requires laboratory testing and animal studies to assess the drug’s safety, toxicity, and potential effectiveness.

2. Investigational New Drug (IND) Application: If the preclinical data is promising, the manufacturer submits an IND application to the U.S. Food and Drug Administration (FDA) or the relevant regulatory agency in other countries. The IND application includes information about the drug’s composition, manufacturing process, proposed clinical trials, and preclinical data.

3. Clinical Trials: Clinical trials are conducted in multiple phases to evaluate the drug’s safety and efficacy in humans. Phase I focuses on security and dosage, and Phase II involves larger groups to assess effectiveness and side effects. Phase III confirms effectiveness and monitors side effects in a larger population.

4. New Drug Application (NDA) or Biologics License Application (BLA): The drug manufacturer submits an NDA or BLA to the FDA after successful clinical trials. This application contains comprehensive data on the drug’s safety, efficacy, manufacturing processes, labeling, and proposed use.

5. FDA Review: The FDA reviews the NDA or BLA to determine whether the drug should be approved for marketing. This review process includes evaluating data from clinical trials, chemistry, manufacturing, labeling, and inspections of manufacturing facilities.

6. Approval: If the FDA approves the drug, it can be marketed and sold in the United States. The approval process may include labeling requirements, warnings, and restrictions.

7. Post-Marketing Surveillance: After approval, the drug continues to be monitored for safety and efficacy through post-marketing surveillance. Adverse events are reported and investigated, and the drug’s label may be updated.

The Role of the National Drug Code (NDC)

The National Drug Code (NDC) is a unique identifier assigned to each medication product in the United States. It plays a pivotal role in drug registration, distribution, and billing. The NDC number consists of three segments: the labeler code, product code, and package code, each separated by hyphens. Let’s break down the significance of each segment:

1. Labeler Code: The first segment, also known as the manufacturer code, is assigned by the FDA to the drug manufacturer, repackager, or distributor. It identifies the entity responsible for bringing the drug to market.

2. Product Code: The product code segment identifies the specific drug, strength, and dosage form. It differentiates between various drug formulations made by the same manufacturer.

3. Package Code: The package code segment indicates the packaging size and type, such as bottle, box, or vial. It helps differentiate between different package configurations of the same drug product.

The NDC number serves several critical purposes:

A. Drug Identification: The NDC number uniquely identifies and tracks drugs in the marketplace, facilitating accurate record-keeping and drug recalls when necessary.

B. Billing and Reimbursement: Healthcare providers use the NDC number when submitting claims to insurance companies and government programs like Medicare and Medicaid. It ensures that medications are accurately billed and reimbursed.

C. Drug Listing and Registration: Manufacturers and distributors use the NDC number to list their drug products with the FDA and meet regulatory requirements. This is an essential step in the drug registration process.

D. Drug Labeling: The NDC number is typically printed on a drug’s packaging and label. It provides essential information for healthcare professionals, pharmacists, and patients, helping them verify the correct medication.

The NDC Drug Number Format

The NDC number is structured in a 10-digit format, divided into three segments. Here’s a breakdown of the format:

  • The first segment contains 4 or 5 digits, representing the labeler code.
  • The second segment includes 3 or 4 numbers indicating the product code.
  • The third segment has two digits, meaning the package code.

For example, let’s consider the NDC number for a hypothetical medication:

  • Labeler Code: 12345
  • Product Code: 6789
  • Package Code: 01

The NDC number would be written as 12345-6789-01

This format allows for many unique combinations, accommodating various medications available.

The Role of the Labeler Code

The labeler code, the first segment of the NDC number, is assigned by the FDA to drug manufacturers, repackagers, or distributors. This code is a critical identifier; each entity involved in drug production or distribution must have a unique labeler code. Here’s how it functions:

1. Manufacturer Identification: The labeler code identifies the entity responsible for manufacturing or distributing the drug. This ensures transparency and accountability in the pharmaceutical supply chain.

2. Drug Listing: Manufacturers, re-packagers, and distributors use their assigned labeler code when listing their drug products with the FDA. This step is essential for regulatory compliance.

3. Billing and Reimbursement: The labeler code is used in the billing and reimbursement. When healthcare providers submit medication claims, the labeler code helps ensure that the correct entity is billed.

4. Tracking and Traceability: The labeler code is crucial in tracking and tracing drugs throughout the supply chain. It helps identify the source of medication and facilitates recalls when necessary.

The Role of the Product Code

The product code, the second segment of the NDC number, is a numeric identifier that specifies the specific drug product, its strength, and its dosage form. The labeler assigns this code and serves the following purposes:

1. Product Differentiation: Manufacturers use the product code to differentiate between various formulations of the same drug. For example, different medication strengths or separate dosage forms (tablets, capsules, liquid, etc.) will have unique product codes.

2. Accurate Identification: Healthcare professionals, pharmacists, and patients rely on the product code to accurately identify and prescribe the correct medication. It ensures that the right drug product is dispensed.

3. Regulatory Compliance: The product code is essential for regulatory compliance. When manufacturers list their drug products with the FDA, they include the product code to provide detailed information about the specific medications they offer.

4. Drug Labeling: The product code is typically printed on the drug’s packaging and label. It assists with accurately identifying the drug, its strength, and its dosage form.

The Role of the Package Code

The package code, the third and final segment of the NDC number, is a two-digit identifier that specifies a drug product’s packaging configuration and size. This code is crucial for several reasons:

1. Package Differentiation: The package code allows manufacturers to differentiate between various package sizes and types for the same drug product. For example, a medication may be available in different quantities, such as 30 tablets, 60 tablets, or 100 tablets, and each package size will have a unique package code.

2. Inventory Management: Pharmaceutical manufacturers, distributors, and pharmacies use the package code to manage inventory effectively. It helps them keep track of the quantity of each package size in stock and reorder as needed.

3. Dispensing Accuracy: Pharmacists and healthcare providers rely on the package code to ensure they dispense the correct quantity of medication to patients. This helps prevent errors and ensures that patients receive the prescribed dosage.

4. Regulatory Compliance: When listing a drug product with the FDA, manufacturers include the package code as part of the NDC number. This step is essential for regulatory compliance and provides detailed information about the various packaging options available for the medication.

5. Prescription Labeling: The package code is often included on prescription labels to help patients and healthcare professionals verify that they receive the correct medication quantity. It adds an extra layer of accuracy to the prescription and dispensing process.

6. Reordering and Procurement: Hospitals, pharmacies, and healthcare facilities use the package code when reordering medications from wholesalers or manufacturers. It ensures that the correct package size is ordered to meet patient needs.

7. Supply Chain Efficiency: The package code is crucial in maintaining efficiency in the pharmaceutical supply chain. It helps with tracking and traceability, allowing for the rapid identification of specific package sizes during distribution and delivery.

8. Patient Education: The package code can also serve as a reference for patient education. It helps patients understand the quantity of medication they should take and facilitates communication with healthcare providers about prescription refills and dosing instructions.

In summary, the package code is a vital component of the NDC number, providing essential information about the packaging configuration of a drug product. It serves multiple purposes, from accurate dispensing to inventory management and regulatory compliance. Healthcare professionals, pharmaceutical manufacturers, and regulatory authorities rely on the NDC number, with its package code segment, to ensure the safe and efficient distribution of medications to patients across the United States.

Is there anything else I should know as a drug manufacturer?

Yes, there are several additional essential considerations and aspects that drug manufacturers should be aware of regarding drug registration and the National Drug Code (NDC) system:

  1. NDC Variations: While the standard NDC format consists of 10 digits (in a 5-4-2 layout), there are variations, such as the 11-digit format (5-4-2 with a check digit) and the 5-3-2 format for over-the-counter (OTC) drugs. Manufacturers must be aware of the specific form applicable to their products.
  2. Unique NDCs for Different Dosage Forms: If a manufacturer produces the same drug in multiple dosage forms (e.g., tablets, capsules, and liquid), each dosage form typically requires a unique NDC. This allows for precise identification of each form.
  3. NDC for Private Labeling: Manufacturers who produce drugs for private labels (generic or store-brand medications) must assign NDCs to these products. Private-label NDCs should be distinguishable from the NDCs of the original manufacturer.
  4. Repackaging and Relabeling: Manufacturers involved in repackaging or relabeling activities, where drugs are removed from their original packaging and placed into new containers, must assign new NDCs for the repackaged products. These NDCs should reflect the new packaging configuration.
  5. NDC Updates: Manufacturers should keep their NDC information updated with the FDA. Any labeler, product, or package code changes, including discontinuations or updates, should be reported to the FDA.
  6. International Considerations: For manufacturers exporting drugs to global markets, it’s essential to understand that the NDC system is specific to the United States. Other countries may have unique product identification systems, and compliance with international regulatory requirements is crucial.
  7. FDA Registration and Listings: Drug manufacturers must register their facilities with the FDA and list their drug products and corresponding NDCs with the FDA’s National Drug Code Directory. This information should be kept accurate and updated regularly.
  8. Supply Chain Traceability: The NDC system facilitates traceability throughout the pharmaceutical supply chain. Manufacturers, distributors, and pharmacies rely on NDCs to track products, verify authenticity, and ensure accurate dispensing.
  9. Regulatory Compliance: Compliance with NDC requirements is a legal obligation. Manufacturers must adhere to FDA regulations governing drug registration, labeling, and reporting. Failure to comply can result in regulatory actions and legal consequences.
  10. Patient Safety: Accurate NDC labeling and tracking contribute to patient safety. Ensuring patients receive the correct medication, dosage form, and packaging configuration is critical in preventing medication errors.
  11. Serialization and Track-and-Trace: Besides NDCs, some jurisdictions and regulatory initiatives require drug serialization and track-and-trace systems for enhanced product security and supply chain transparency. Manufacturers should stay informed about relevant serialization requirements.
  12. Regulatory Changes: Regulations related to drug registration, labeling, and NDCs can change over time. Manufacturers should stay informed about updates and revisions to FDA requirements and adapt their processes accordingly.
  13. Consultation with Regulatory Experts: Given the complexity of drug registration and compliance with NDC requirements, manufacturers may benefit from consulting with regulatory experts or professionals experienced in pharmaceutical regulatory affairs to ensure full compliance and avoid potential pitfalls.

In summary, drug manufacturers must navigate the intricate drug registration process and the NDC system to bring safe and effective medications to the market. Staying informed about regulatory requirements, adhering to NDC standards, and maintaining accurate records are essential for regulatory compliance and ensuring the well-being of patients.

Are you looking to have your drug product registered with Health Canada? Quality Smart Solutions has a team of experts who are skilled with DIN applications. If you need help with your Drug Establishment License (DEL) Registration we can help with that as well. 

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Navigating the Regulatory Seas: How Experts Ensure Your Medical Devices Set Sail Smoothly

medical device regulation requirements

Introduction 

In the ever-changing world of medical device manufacturing, ensuring your product complies with regulations is akin to navigating stormy seas. The safety of patients, the assurance of quality, and the complexities of compliance weigh heavily on manufacturers. This article sheds light on the challenges faced and how expert navigators—regulatory consultants—play a pivotal role in ensuring your medical device not only sails through but sets a course for success.

Here are the key points regarding medical device regulations in Canada:

  1. Medical Device Licensing: Health Canada requires all medical devices to be licensed before they can be sold in the country. There are different classes of medical devices, and the requirements for licensing vary depending on the class. Class I devices, which pose the lowest risk, generally require a Medical Device Establishment License (MDEL), while Class II, III, and IV devices require a device license.

  2. Device Classification: Medical devices are classified into four classes (Class I, II, III, and IV) based on their potential risk. Class I devices have the lowest risk, while Class IV devices pose the highest risk. The classification of a device determines the level of scrutiny and requirements for licensing.

  3. Quality Management Systems: Manufacturers are often required to have a certified Quality Management System (QMS) in place, such as ISO 13485, which demonstrates their ability to produce medical devices consistently and meet regulatory requirements.

  4. Labeling and Language Requirements: Medical device labeling must be in both English and French, as Canada is a bilingual country. Labels must include essential information about the device, including its intended use, precautions, and directions for use.

  5. Post-Market Surveillance: Manufacturers are obligated to monitor the performance of their devices once they are on the market. This includes reporting adverse events, conducting recalls if necessary, and addressing safety concerns.

  6. Unique Device Identification (UDI): Health Canada introduced a UDI system to enhance the traceability of medical devices. Manufacturers are required to label their devices with a unique identifier, allowing for easier tracking and recall if safety issues arise.

Understanding the Regulatory Maze

Medical device requirements are like a vast, intricate map; understanding them is no small feat. Some standards and guidelines can make even the most seasoned manufacturer feel lost at sea from the design phase to production.

The challenges of medical device requirements and compliance

  1. Ever-Changing Tides: Regulatory requirements are not stagnant; they are constantly shifting and evolving. Keeping up with these changes and understanding how they apply to your specific device is a daunting challenge.
  2. Diverse Global Standards: To market your device internationally, you must navigate diverse regulations. Each country has its requirements, making compliance a multifaceted challenge.
  3. Complex Documentation: The paperwork required for regulatory submissions is not for the faint of heart. Ensuring every document is accurate, complete, and submitted on time adds another layer of complexity.

What role will our medical device regulatory consultants fill?

  1. Seasoned Seafarers: Regulatory consultants are like seasoned captains who have sailed these waters before. Their experience and expertise help manufacturers make sense of the maze of regulations, providing practical and invaluable guidance.
  2. Customized Navigation: Every medical device and its challenges regarding compliance are unique. Consultants tailor their strategies, ensuring your compliance journey is specifically designed for your product and preventing common pitfalls.
  3. Mitigating Compliance Challenges: Consultants don’t just help you navigate; they help you anticipate challenges. By identifying potential issues early on, they assist in making necessary course corrections, preventing refusals, and ensuring a smoother voyage.

How our Regulatory Consultants help us to prevent refusals

  1. Early Warning Systems: Consultants act as early warning systems, identifying compliance challenges in the initial stages of development. This proactive approach allows manufacturers to make necessary adjustments, preventing refusals before they become possible.
  2. Comprehensive Risk Assessment: Consultants conduct thorough risk assessments, mapping potential obstacles. By understanding these risks, manufacturers can take preventive measures, significantly reducing the chances of refusals.

Conclusion 

In the unpredictable seas of medical device regulations, having a seasoned navigator by your side can make all the difference. Regulatory consultants provide the expertise to navigate the challenges, ensuring your product sails smoothly through approval. By investing in their knowledge, manufacturers can meet compliance requirements and innovate confidently, ultimately bringing safe, high-quality medical devices to the market. Safe travels!

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device RegistrationFacility Registration & FURLSIVD Device Registration, and SaMD Classification

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510k Submission Guidance: Unpacking the 510k Requirements

510k Submissions

Introduction

In the world of medical devices, ensuring patient safety and efficacy is paramount. The 510(k) submission process is a critical step for manufacturers seeking clearance from the U.S. Food and Drug Administration (FDA) to market their devices. This process can be complex, but it plays a pivotal role in bringing innovative medical devices to market. In this article, we’ll unpack the 510(k) submission requirements, helping manufacturers navigate the regulatory landscape with confidence.

Understanding the 510(k) Submission

The 510(k) submission is named after Section 510(k) of the Federal Food, Drug, and Cosmetic Act, which requires device manufacturers to notify the FDA at least 90 days in advance before introducing a new medical device into commercial distribution. The purpose of this notification is to demonstrate that the device is “substantially equivalent” to a legally marketed device (often referred to as a predicate device) in terms of safety and effectiveness.

Here’s a step-by-step guide to help manufacturers understand and meet the 510(k) submission requirements:

  1. Identify the Appropriate Predicate Device: The first and most crucial step is identifying a suitable predicate device. This is a device already on the market that is similar to the one you want to submit for clearance. The FDA uses the predicate device as a benchmark to assess the substantial equivalence of your device.

  2. Determine Substantial Equivalence: Your device must be substantially equivalent to the predicate device in terms of intended use, technological characteristics, and performance data. Any differences must be justified and explained thoroughly in the submission.

  3. Compile a Comprehensive 510(k) Submission: Prepare a thorough submission that includes:

    • A cover letter: This summarizes the submission and states its purpose.
    • Device description: Provide detailed information about your device, including its intended use, design, materials, and manufacturing processes.
    • Comparison to the predicate device: Highlight the similarities and differences between your device and the predicate device.
    • Performance data: Include test results, clinical data, and any other relevant information demonstrating the safety and effectiveness of your device.
    • Proposed labeling: Submit labeling, including user manuals and package inserts.
    • Biocompatibility data: Detail how your device interacts with the human body and any biocompatibility testing results.
    • Risk analysis: Identify potential risks associated with your device and how you plan to mitigate them.
  4. Compile Quality System Information: Include documentation of your Quality System Regulation (QSR) compliance. This should cover your manufacturing processes, quality control procedures, and any relevant certifications.

  5. Prepare an FDA Application: Register your establishment with the FDA and submit your 510(k) application online through the FDA’s electronic submission gateway.

  6. Wait for FDA Feedback: Once submitted, the FDA will review your 510(k) submission. They may provide feedback or request additional information. Respond promptly and thoroughly to any requests to expedite the review process.

  7. FDA Clearance: If your submission is successful, the FDA will issue a clearance letter. This means you can market your device in the United States.

Conclusion

Navigating the 510(k) submission process can be challenging, but it’s a crucial step in bringing your medical device to market. Properly understanding and meeting the 510(k) requirements, from identifying a suitable predicate device to compiling a comprehensive submission, is essential for success. Collaboration with regulatory experts and consultants who are well-versed in the FDA’s processes can be invaluable during this journey. By following these guidelines and investing in due diligence, you can increase your chances of obtaining FDA clearance and contributing to the advancement of medical technology while ensuring patient safety.

To learn when and how to file your 510k submissions click here:

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device RegistrationFacility Registration & FURLSIVD Device Registration, and SaMD Classification

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Navigating French Language Labeling Requirements in Canada: A Guide for Food Manufacturers

Navigating French Language Labeling Requirements in Canada: A Guide for Food ManufacturersIntroduction:

As a food manufacturer in Canada, ensuring that your product labels comply with Health Canada’s regulations is crucial for successful market entry and consumer safety. For businesses looking to distribute food products in Canada, one essential aspect is adherence to bilingual labeling requirements, notably including French alongside English on product labels. In this blog, we’ll explore common questions about French label requirements in Canada and how food manufacturers can ensure compliance with Health Canada’s regulations.

Food Labeling Regulations and Food Label French Translation in Canada

  • Mandatory Bilingual Content:

In Canada, food labeling must be bilingual, meaning it should be in French and English to cater to the bilingual population. This includes provinces where French is the official language, such as Quebec and certain parts of New Brunswick.

  • Essential Information:

Labels must include essential information such as the product name, ingredient list, nutrition facts, allergens, and mandatory statements, where applicable. All this information must be available in both official languages.

Common food labeling mistakes to avoid in Canada

  • Incorrect Translation:

One of the most common mistakes is the incorrect translation of labeling information. It’s crucial to ensure that translations into French are accurate and compliant with Canadian standards.

  • Inadequate Font Size:

The font size used for French information must be large enough to be legible. Errors occur when the font size is too small to meet readability requirements.

  • Omission of Allergens:

It is a severe error to mention common allergens in French. Consumers must be clearly and comprehensibly informed about allergens in products.

  • Failure to Comply with Standards:

Non-compliance with French labeling regulations can lead to penalties, product recalls, and financial losses. Staying informed about constantly evolving regulatory requirements is essential.

FAQs on French Labeling Requirements in Canada

 

1. Do I need to provide French labeling for my food products in Canada?

  • Yes, if you’re a food manufacturer selling products in Canada, it’s mandatory to have bilingual labels. French labeling is required alongside English to cater to the country’s bilingual population.

2. What information should be included in the French portion of the label?

  • The French portion of the label should contain all the necessary information, such as product names, ingredient lists, nutrition facts, allergen information, and any mandatory statements, all presented accurately in French.

3. Can I use a bilingual label with English and French side by side?

  • Yes, bilingual labels with both English and French text are acceptable. However, ensuring that all required information is present in both languages and meets legibility requirements is essential.

Product Name and Ingredient List

1. Do I need to translate the product name into French?

  • Absolutely. If your product name is in English, it should be accurately translated into French. This translation should reflect the product’s nature.

2. Should I provide the ingredient list in French as well?

  • Yes, the ingredient list must be provided in French, including accurate translations of ingredient names to ensure clarity for French-speaking consumers.

Nutrition Facts and Allergen Information

1. How do I present nutrition facts in French?

  • Nutrition facts should be presented in English and French, with the French text close to English and designed for easy readability.

2. What about allergen information in French?

  • Any allergen information, including “Contains” statements, must be presented in French if it appears in English on the label. Ensure that these translations are accurate and prominently displayed.

Font Size and Legibility

1. Are there specific font size and legibility requirements for the French text?

  • Yes, Health Canada mandates that the French text be easily readable. Font size requirements vary based on the size of your packaging. Additionally, ensure that the text contrasts sufficiently with the background for clear visibility.

Conclusion

Compliance with French label requirements in Canada is a regulatory necessity and an essential step in building consumer trust. Non-compliance can lead to consequences such as product recalls and legal issues. To ensure your food labels align with Health Canada’s regulations, consult their guidance and consider seeking legal advice when needed. By adhering to these bilingual labeling requirements, you can confidently introduce your food products to the Canadian market and cater to its diverse, bilingual population.

At Quality Smart Solutions, we have a team of experts who are skilled in both Canadian and USA food labelling compliance. We offer several solutions to meet your needs and understand the importance of french translation food labelling. 

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Why is it crucial to avoid FDA Warning Letters for dietary supplements and health products?

The Implications of FDA Warning Letters

 

As a business owner operating in dietary supplements and health products, you are undoubtedly aware of the ever-evolving regulatory landscape. Ensuring that your products meet the stringent requirements set forth by the U.S. Food and Drug Administration (FDA) is not merely a matter of legal obligation; it’s imperative for your brand’s success and consumer safety. This article will explore the importance of steering clear of FDA Warning Letters and what they signify for your business.

The FDA’s Role in Ensuring Product Safety

The FDA plays a pivotal role in safeguarding public health by overseeing the safety and efficacy of various products, including dietary supplements and health products. These regulatory guidelines are designed to protect consumers from potential health hazards and misleading claims. For business owners, compliance with these guidelines is a legal requirement and a responsibility towards their customers.

FDA Warning Letters: A Red Flag

Receiving an FDA Warning Letter indicates that your business needs to comply with federal regulations. It serves as an official communication from the FDA to notify you of significant violations that require immediate attention. Warning Letters are issued when the FDA finds misbranded products, unapproved health claims, adulteration, or non-compliance with Current Good Manufacturing Practices (cGMPs).

The Implications of FDA Warning Letters

  1. Reputation Damage: Perhaps the most immediate and damaging consequence of receiving a Warning Letter is the negative impact on your brand’s reputation. Consumers often view these letters as red flags, leading to decreased trust in your products and company.
  2. Market Access Challenges: Non-compliance can limit your product’s market access or lead to development recalls, resulting in significant financial losses.
  3. Legal Consequences: Ignoring or inadequately addressing Warning Letters can escalate the situation, potentially leading to legal actions, including product seizures, injunctions, and fines.
  4. Resource Drain: Rectifying compliance issues can be time-consuming and costly, diverting resources from business growth and development.
  5. SEO: Resources and FDA pages always appear on the first page of Google due to their high domain authority. Therefore, if you are given a warning letter whenever someone Google your company’s name, they’ll see you failed to be compliant at some time and hurt your image.

The Path to Compliance

To avoid the pitfalls associated with FDA Warning Letters, proactive measures are paramount:

  1. Stay Informed: Regularly monitor FDA guidance and regulations related to your products. The FDA frequently updates guidelines, and staying informed is critical.
  2. Invest in Quality Control: Adhering to cGMPs is essential for ensuring the quality and safety of your products. Implement robust quality control measures to maintain compliance.
  3. Labeling and Marketing Claims: Ensure your product labels and marketing materials adhere to FDA guidelines. Avoid making unapproved health claims or using misleading language.
  4. Documentation: Maintain meticulous records of your products’ formulation, testing, and distribution to demonstrate compliance in case of an audit.
  5. Seek Expert Guidance: Engage regulatory experts or consultants specializing in FDA compliance. Their expertise can help you navigate the complexities of regulatory requirements effectively.

Conclusion

Maintaining FDA compliance in the competitive landscape of dietary supplements and health products is not just about legal obligations; it’s a strategic imperative. Avoiding FDA Warning Letters is vital for preserving your brand’s reputation, ensuring consumer safety, and securing your market presence. By prioritizing compliance, you protect your business and contribute to enhancing public health through safe and effective products.

Our Regulatory experts can help you ensure compliance with your medical devicesfood/beveragedietary supplements, cosmetics with MoCRA Regulations, and drug products including all FDA Facility Registration

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Everything businesses should know about submitting a 30-Day Pre-Market Notification and Structure-Function Claims

Title: Everything Businesses Should Know About Submitting a 30-Day Pre-Market Notification and Structure-Function Claim for Dietary SupplementsIn dietary supplements, navigating the intricate regulatory landscape is a challenging yet indispensable aspect of launching your product. Submitting a 30-day Pre-Market Notification and Structure-Function Claim to the U.S. Food and Drug Administration (FDA) is a pivotal regulatory requirement. This notification must be submitted at least 30 days before introducing your dietary supplement to the market. This article delves into this process’s essential facets, including steps awaiting FDA confirmation and regulatory solutions for label review, facility registration, and compliance with the Foreign Supplier Verification Program (FSVP) Import Agent requirement.

Understanding the 30-Day Pre-Market Notification

The 30-Day Pre-Market Notification is a regulatory mandate meticulously enforced by the FDA for all novel dietary supplement products entering the market. This notification serves as a conduit for the FDA to scrutinize and assess the product’s safety and adherence to labeling requirements. The primary objective is to guarantee the security of these products for consumers, coupled with the veracity of the labeling regarding ingredients and intended use.

Steps for Submitting a 30-Day Pre-Market Notification

  1. Determining Product Eligibility: Not all dietary supplements necessitate a 30-day pre-market notification. In specific cases, exemptions are available for products containing ingredients marketed in the United States before October 15, 1994, or products meeting particular criteria. Engaging regulatory experts for definitive clarification concerning your product’s eligibility is imperative.
  2. Compilation of Essential Information: Before initiation, assemble all requisite data, encompassing a comprehensive ingredient list, dosage instructions, intended use, and any structure-function claims you intend to assert.
  3. Preparation of the Notification: Utilize the FDA’s Dietary Supplement Registration and Notification System (DSN) to prepare and submit your notification. This online platform streamlines the process, ensuring the provision of all necessary details.
  4. Payment of Applicable Fees: The FDA typically charges a notification submission fee. Scrutinize the current fee schedule and proceed with the requisite amount.
  5. Submission of the Notification: Submit your notification via the DSN portal after the preparation. Expect an acknowledgment from the FDA confirming receipt of your request.

Waiting for FDA Confirmation

Upon submitting your 30-day pre-market notification, the FDA will engage in an extensive review process to ascertain compliance with safety and labeling requirements. This procedure may extend to 75 days, encompassing the obligatory 30-day waiting period. During this interval, the FDA might request supplementary information or clarifications regarding your product. It is imperative to exercise patience while awaiting the FDA’s confirmation before embarking on marketing and distribution endeavors for your dietary supplement. A premature product launch can culminate in regulatory complications and potentially tarnish the reputation of your business.

Regulatory Solutions for Label Review, Facility Registration, and FSVP Import Agent

  1. Label Review: Ensuring strict adherence to FDA labeling regulations for dietary supplements is imperative. Consider engaging regulatory experts or consultants with specialized knowledge of dietary supplements to review your labels for compliance. This prudent step serves as a bulwark against costly label-related issues in the future.
  2. Facility Registration: Manufacturers and distributors of dietary supplements must meticulously register their facilities with the FDA. Ensure comprehensive facility registration to obviate regulatory hurdles. Continuously update your registration information to maintain compliance.
  3. FSVP Import Agent: If you’re involved in importing dietary supplements into the U.S., securing a proficient Foreign Supplier Verification Program (FSVP) Import Agent is paramount. The designated agent is tasked with ensuring foreign suppliers align with FDA requirements. Selecting a knowledgeable FSVP Import Agent is pivotal to complying with this crucial regulation.

In conclusion, submitting a 30-day pre-market notification and adhering to dietary supplement regulations are essential undertakings for businesses in this area. By comprehending the intricacies of the process, patiently awaiting FDA confirmation, and proactively addressing labeling, facility registration, and FSVP Import Agent prerequisites, businesses can navigate the regulatory terrain adeptly, thereby facilitating the introduction of safe and compliant products into the market. Compliance ensures consumer safety and contributes to dietary supplement enterprises’ enduring success and esteem.

Learn about the impact of the pre-market notification and structure-function claims on the 510k medical device process.

We can help you create the best structure-function claims to propel your business to new heights. Learn about the pre-market notification and structure-function claim process for food and dietary supplements.

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Health Canada’s Notice Enables the Use of L-alpha Glycerylphosphorylcholine in Supplemented Food

Health Canada Approves Alpha GPC in Foods

Discover Health Canada's latest approval of L-alpha-glycerylphosphorylcholine in supplemented foods. Learn about regulatory changes, safety assessments, and conditions for use.On September 20, 2023, Health Canada approved the use of L-alpha-glycerylphosphorylcholine (alpha GPC) as a supplement in foods. This decision followed a thorough safety review by Health Canada’s Food Directorate.

How Health Canada Administers Foods and Food Supplements

Health Canada ensures food and drug safety is maintained in Canada. They set the rules for food safety under the Food and Drugs Act. In July 2022, they introduced regulations specifically for foods with supplements. These regulations outline the requirements for adding supplements to foods.

Alpha GPC Safety Assessment

Health Canada conducted a detailed safety review of alpha GPC, looking at its chemistry, nutrition, and potential health risks. The review confirmed that alpha GPC is safe to use as a choline supplement in foods as long as it meets labeling and maximum usage guidelines.

Public Feedback

Health Canada opened a public comment period from April 17 to July 1, 2023, on its proposal to allow alpha GPC in foods. No new scientific information or objections were submitted, so the original safety conclusions remained unchanged.

Enforcement and Implementation

The change allowing alpha GPC in foods took effect on September 20, 2023. The Canadian Food Inspection Agency will enforce these new regulations to ensure compliance.

Access to Supplemental Ingredient Information

Health Canada provides a list of all approved supplemental ingredients, including alpha GPC, on their website. This list outlines which foods can contain these ingredients, the maximum allowed amounts, and any required safety labels.

Guidance for Food Manufacturers

Health Canada has also published a guidance document for food manufacturers. This document explains how to comply with the regulations, including labeling and safety standards for supplemented foods.

Background on the Health Canada Regulatory Authority

Under the Food and Drugs Act, Health Canada is authorized to establish requirements and conditions for foods available in the Canadian market. To facilitate this, the “Supplemented Foods Regulations,” which amended the Food and Drug Regulations and the Cannabis Regulations, were introduced on July 21, 2022. These regulations define the specific regulatory requirements applicable to supplemented foods, outlined within the Food and Drug Regulations (Part B, Division 29, and other relevant provisions). Additionally, Subsection 102(2) of the Cannabis Regulations plays a role in overseeing these regulations.

The permitted categories of supplemented foods and the supplemental ingredients, along with their conditions of use, are detailed in the “List of Permitted Supplemented Food Categories” and the “List of Permitted Supplemental Ingredients,” respectively. These lists are incorporated by reference into the Food and Drug Regulations and are regularly updated on the Canada.ca website.

Safety Assessment of L-alpha Glycerylphosphorylcholine

The decision to enable the use of L-alpha-glycerylphosphorylcholine in supplemented foods was grounded in a rigorous safety assessment conducted by Health Canada’s Food Directorate. This assessment encompassed various aspects, including chemistry, nutrition, microbiology, toxicology, and allergenicity. The evaluation concluded that the available information unequivocally supports the safe use of L-alpha-glycerylphosphorylcholine as a source of supplemental choline in supplemented foods, provided that its usage levels do not exceed the previously established maximum levels for choline and that all labeling requirements are met.

Notification: Summary of Comments and Health Canada’s Responses

As mentioned earlier, Health Canada received no comments or objections regarding the proposal. This lack of feedback reaffirms the department’s confidence in the safety assessment of L-alpha-glycerylphosphorylcholine.

Implementation and Enforcement

As of September 20, 2023, the modification allowing the use of L-alpha-glycerylphosphorylcholine in supplemented foods came into effect. This change was published in the “List of Permitted Supplemental Ingredients.” It is crucial to note that the Canadian Food Inspection Agency is responsible for enforcing the Food and Drugs Act and its associated regulations, particularly concerning foods.

Health Canada’s decision to use L-alpha-glycerylphosphorylcholine in supplemented foods underscores the department’s commitment to ensuring the safety and quality of food products available to Canadians.

This regulatory change aligns with Health Canada’s ongoing efforts to provide consumers access to safe and beneficial dietary supplements while maintaining stringent safety standards. As this modification takes effect, consumers and food manufacturers can expect to see L-alpha-glycerylphosphorylcholine as an approved source of supplemental choline in a range of supplemented food products across Canada.

Accessing the list of Supplemental Ingredients and their conditions

This document is a valuable resource for those interested in exploring the List of Permitted Supplemental Ingredients and understanding their use conditions. It provides detailed information about the supplemental ingredients authorized for addition to supplemented foods. It outlines the specific requirements governing their usage. These conditions encompass:

  1. Food Category: This indicates the type of food to which the supplemental ingredient may be added.
  2. Maximum Amount and Units per Serving: Specifies the highest quantity of the supplemental ingredient that can be included in a serving of food, along with the units of measurement applicable to the stated serving size.
  3. Cautionary Statements: Identifies any mandatory cautionary statements that must be included on the product label for each supplemental ingredient and establishes the threshold level at which these statements become obligatory.
  4. Additional Conditions of Use and Labeling Requirements: Outlines any other conditions or labeling requirements on using the supplemental ingredient.

It is essential to note that certain ingredients are strictly prohibited from being added to supplemented foods at any level. Furthermore, additional restrictions may apply to including specific supplemental ingredients in food products.

Guidance Document for Supplemented Foods Regulations

For those seeking comprehensive guidance on supplemented foods regulations, including detailed information on permitted supplemental ingredients and their conditions of use, Health Canada has provided a dedicated resource known as the “Guidance Document for Supplemented Foods Regulations.”

This guidance document offers a wealth of information, encompassing:

  1. Supplemental Ingredient Details: Comprehensive information on all permitted supplemental ingredients, their respective conditions of use, and other essential details.
  2. Regulatory Compliance: Guidance on ensuring compliance with the regulations governing supplemented foods, including labeling requirements and safety standards.
  3. Amendment Process: An explanation of the procedures and requirements for proposing and adding new supplemental ingredients to the List of Permitted Supplemental Ingredients.

Accessing the list of Supplemental Ingredients and their conditions

Discover Health Canada's latest approval of L-alpha-glycerylphosphorylcholine in supplemented foods. Learn about regulatory changes, safety assessments, and conditions for use.This document is valuable for those interested in exploring the List of Permitted Supplemental Ingredients and understanding their use conditions. It provides detailed information about the supplemental ingredients authorized for addition to supplemented foods. It outlines the specific requirements governing their usage. These conditions encompass:

  1. Food Category: This indicates the type of food to which the supplemental ingredient may be added.
  2. Maximum Amount and Units per Serving: Specifies the highest quantity of the supplemental ingredient that can be included in a serving of food, along with the units of measurement applicable to the stated serving size.
  3. Cautionary Statements: Identifies any mandatory cautionary statements that must be included on the product label for each supplemental ingredient and establishes the threshold level at which these statements become obligatory.
  4. Additional Conditions of Use and Labeling Requirements: Outlines any other conditions or labeling requirements on using the supplemental ingredient.

It is essential to note that certain ingredients are strictly prohibited from being added to supplemented foods at any level. Furthermore, additional restrictions may apply to including specific supplemental ingredients in food products.

Guidance Document for Supplemented Foods Regulations

For those seeking comprehensive guidance on supplemented foods regulations, including detailed information on permitted supplemental ingredients and their conditions of use, Health Canada has provided a dedicated resource known as the “Guidance Document for Supplemented Foods Regulations.”

This guidance document offers a wealth of information, encompassing

  1. Supplemental Ingredient Details: Comprehensive information on all permitted supplemental ingredients, their respective conditions of use, and other essential details
  2. Regulatory Compliance: Guidance on ensuring compliance with the regulations governing supplemented foods, including labeling requirements and safety standards
  3. Amendment Process: An explanation of the procedures and requirements for proposing and adding new supplemental ingredients to the List of Permitted Supplemental Ingredients

By consulting this guidance document, stakeholders, including food manufacturers, can better understand the regulatory landscape for supplemented foods in Canada. It serves as a valuable reference for newcomers and experienced industry professionals, facilitating compliance with Health Canada’s stringent standards and ensuring the safety and quality of supplemented food products in the Canadian market.

Health Canada’s commitment to transparency and safety in supplemented foods is underscored by the availability of these resources. Accessing the List of Permitted Supplemental Ingredients and the Guidance Document for Supplemented Foods Regulations empowers industry players and consumers with the knowledge and tools to navigate the regulatory landscape effectively and make informed decisions regarding supplemented food products.

Click here to learn about the Supplemented Facts Table Regulations.

How We Can Help 

At Quality Smart Solutions, we have the expertise needed to ensure your foods or food supplements comply with Health Canada. Navigating the complexities of this process can be challenging so our experienced and highly qualified team is here to help you achieve the best outcome for your success. Contact us today to discuss how we can support your business!

 

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Navigating Cosmetic Product Regulations through FDA Recent MoCRA Update

Navigating Cosmetic Product Regulations through FDA Recent MoCRA UpdateIntroduction:

In response to the FDA’s recent draft guidance on the Registration and Listing of Cosmetic Product Facilities and Products, we’ve got some updates and insights that might interest you, especially if you’re in the cosmetic business.

First, nearly 50 public comments were submitted to the FDA regarding this draft guidance by the September 5, 2023 deadline. These comments covered various aspects, from concerns about the burden estimates to suggestions for making the whole process smoother and more transparent.

Let’s break down some of the key takeaways:

1. Burden Estimates: The FDA noted the public’s feedback and increased its burden estimates for certain reporting activities related to product listings. However, they didn’t tweak the estimates for tasks such as updating product labels or reporting severe adverse events. So, some things remain unchanged.

2. Confidentiality: If you were concerned about the confidentiality of the data you’d be submitting, the FDA referred to existing regulations. They pointed out that privacy and protection of trade secrets and commercially confidential information are covered by the Privacy Act of 1974 and FDA regulations (21 CFR part 20).

3. Deadlines: Unfortunately, if you were hoping for an extension of the December 29, 2023, deadlines for product listing and facility registration, there won’t be one. The FDA emphasized that these deadlines are mandated by law, so they’re set in stone.

Here’s a new term for FEI: Facility Establishment Identifier. This nifty little number is generated by the FDA and is used to identify your firm. You’ll need it when you’re submitting product listings and facility registrations.

If you’re wondering whether your company already has an FEI, here’s how to find out:

  • Request access to the FEI portal [link].
  • You’ll get an email with a password for the portal.
  • Log in and search for your company using its name and address.
  • If you need help finding an FEI for your company, you can request one by emailing feiportal@fda.hhs.gov. Just make sure you provide all the required information listed in the article.

Getting an FEI ensures your cosmetic business complies with the FDA’s regulations. So, if you still need one, we suggest getting on that pronto.

We hope this update helps you navigate the regulatory landscape more smoothly. If you have any more questions or need assistance, please reach out. Your compliance is essential, and we’re here to support your cosmetic business every step of the way.

Need help ensuring your cosmetic ingredients are safe for use? Get assistance with your U.S.A cosmetic product compliance from our consultants. 

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Selling Your Food Products in the USA: A Guide for Food Business Owners

Selling Your Food Products in the USA: A Guide for Food Business OwnersIf you’re selling food products in the United States, understanding and complying with FDA regulations is non-negotiable. The Food and Drug Administration (FDA) has established rigorous requirements to ensure the safety and transparency of food products available to consumers. Here’s a practical guide tailored to food business owners on ensuring your food products meet the requirements for successful sales in the U.S.

1. Complying with FDA Food Label Requirements

Your food product’s label is more than just branding; it’s the first point of contact with your consumers. To ensure compliance with FDA food label requirements, here are some key considerations:

  • Nutrition Facts Panel: Your product label must feature a Nutrition Facts Panel prominently. This panel provides crucial information about the nutritional content of your product, empowering consumers to make informed choices.
  • Allergen Declaration: Clearly state any significant food allergens present in your product. This is essential for consumers with food allergies; non-compliance can have serious consequences.
  • Ingredient List: Provide a comprehensive ingredient list, arranging ingredients in descending order of predominance. Transparency here is vital for consumers with dietary restrictions or preferences.
  • Net Quantity Declaration: Accurately state the net quantity of your product. This helps consumers understand the amount they’re purchasing.

2. FDA Facility Registration and U.S. Agent

FDA facility registration is obligatory if your operations involve manufacturing, processing, packing, or storing food products. Here’s what you need to know:

  • Registration Requirement: Your food facility must be registered with the FDA. This legal requirement applies to domestic and foreign facilities involved in food-related activities.
  • U.S. Agent: For foreign facilities, designating a U.S. Agent is essential. Your U.S. Agent is a vital communication link between your facility and the FDA. They’ll receive FDA communications, inspection notices, and other official correspondence on your behalf.

3. Navigating the FSVP Import Agent Requirement Compliance

The Foreign Supplier Verification Program (FSVP) is a critical component if your business involves importing food into the United States. Here’s how to ensure your compliance:

  • Mandatory Program: FSVP is not optional; it’s compulsory for importers of food products. Its primary goal is to ensure that your foreign suppliers adhere to U.S. food safety standards.
  • Qualified FSVP Import Agent: Appoint a qualified FSVP Import Agent. This individual or entity is responsible for developing and implementing your FSVP plan. They’ll make sure the food you import aligns with FDA regulations.
  • Documentation and Verification: Keep meticulous records of your verification activities. This includes supplier assessments, food testing results, and audit reports. These records serve as tangible proof of your compliance with FSVP requirements.

Conclusion

Navigating the labyrinth of requirements for selling food products in the United States is a complex but essential task for food business owners. From meticulous food labeling to facility registration and FSVP compliance, your attention to detail ensures both the safety of consumers and the success of your business. Remember, consumers trust that the food they buy is safe and accurately labeled, making compliance with these regulations a cornerstone of your business’s reputation and prosperity.

We can provide FDA food label compliance, Nutrition Facts Panel creation and act as your FSVP Import Agent. We can also guide you through the entire FDA Facility Registration or FDA Facility Renewal process for domestic and foreign Food facilities.

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Navigating Health Canada’s NPN Application Process: A Comprehensive Guide

NPN Application ProcessIntroduction: 

Health Canada’s Natural Products Number (NPN) application process is vital for manufacturers and distributors of natural health products (NHPs) in Canada. Obtaining an NPN is not only a regulatory requirement but also a testament to the safety and quality of your product. In this comprehensive guide, we will walk you through the NPN application process from start to finish, ensuring that you understand the steps, requirements, and critical considerations for a successful application. Let’s embark on this journey to compliance and consumer confidence.

Understanding the NPN: What is it? 

The Natural Product Number (NPN) is a unique identifier issued by Health Canada. It signifies that a natural health product has been reviewed and approved for sale in Canada. This approval indicates that the product meets specific safety, efficacy, and quality standards established by Health Canada.

Step 1: Determine Eligibility Before diving into the application process, it’s essential to determine whether your product qualifies as a natural health product (NHP) under Health Canada’s definition. NHPs include vitamins, minerals, herbal remedies, homeopathic and traditional medicines. Ensure your product fits this category before proceeding.

Step 2: Compile Essential Documentation. Gather all the necessary documentation to support your NPN application. This includes product labels, safety and efficacy data, ingredient information, and relevant research studies. Accuracy and completeness in this phase are crucial.

Step 3: Conduct a Thorough Product Classification. Classify your product under one of the following categories: non-prescription drugs, NHPs, or cosmetics. This step helps determine the regulatory pathway for your development.

Step 4: Determine the Appropriate Regulatory Path. Depending on the classification, you will follow either the NHP or Food and Drug Regulations. Ensure you choose the correct pathway, as each has unique requirements and guidelines.

Step 5: Prepare Your NPN Application. Compose your NPN application using Health Canada’s templates and guidelines. Include detailed information about the product’s formulation, medicinal ingredients, recommended use, and safety information. Remember to provide evidence supporting your product’s claims and efficacy.

Step 6: Submit Your Application Carefully review your application for accuracy and completeness before submitting it to Health Canada. Pay the required application fee and ensure your submission meets the regulatory requirements.

Step 7: Wait for Review and Approval. Health Canada will review your NPN application, which can take several weeks or months, depending on the complexity of your product. During this process, be prepared for questions or requests for additional information from Health Canada.

Step 8: NPN Issuance Upon successful review and approval, Health Canada will issue your Natural Product Number (NPN). This number must appear on your product label, confirming that it meets Health Canada’s safety and quality standards.

Conclusion: 

Navigating Health Canada’s NPN application process requires meticulous attention to detail and adherence to regulatory standards. By understanding the steps involved and meeting the requirements, you can secure an NPN for your natural health product, gain consumer trust, and contribute to a safer and healthier marketplace for all Canadians. Always stay updated with Health Canada’s regulatory changes to maintain compliance and continue offering your customers safe and effective natural health products.

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How to prepare and submit an eStar 510k Submission as of October 1st

Navigating FDA Registration and the 510(k) Process: Your Guide to Getting Your Medical Device to Market

Introduction: 

Staying up-to-date with the latest regulations and tools is crucial in medical device submissions. As of June 9, 2023, the FDA introduced the electronic Submission Template and Resource (eSTAR) for Pre-Submissions, revolutionizing the process for medical device applicants. Starting October 1, 2023, all 510(k) submissions, unless exempted, must be submitted electronically using the eSTAR template. Given this impact on the medical device industry, we’ll answer all your questions about eSTAR in this blog. This article is simply a high-level analysis of the guidance document simplified to give you the most important information broken down but is not a substitute for the full FDA guidance document. 

What Is the eSTAR Template? 

The eSTAR template is your go-to tool for preparing electronic submissions of medical devices, simplifying the process significantly. It’s an interactive PDF form designed to guide applicants through creating a comprehensive submission. With automation features, alignment with FDA review templates, integration of resources, guided section construction, and automatic verification, the eSTAR template streamlines the submission process.

Why Choose eSTAR? 

Aside from it being a requirement eSTAR is available for voluntary use by all medical device applicants, whether you’re submitting 510(k)s, De Novo requests, or Pre-Submissions to the Center for Devices and Radiological Health (CDRH). It’s also applicable for those offering 510(k)s to the Center for Biologics Evaluation and Research (CBER) and combination products.

What Are the Benefits? 

The eSTAR template aims to enhance submission quality by facilitating comprehensive data submission in a standardized format. This ensures completeness, helping the FDA conduct premarket reviews more efficiently. The best part? It reduces the likelihood of your submission undergoing a refuse-to-accept (RTA) process.

How to Get Started with eSTAR:

  • Download the eSTAR PDF template following simple steps.
  • Familiarize yourself with the template’s instructions.
  • Use the template to construct your submission.

Important Tips:

  • Be cautious of file sizes to ensure smooth submission.
  • Combine similar attachments for better organization.
  • You don’t need to include additional forms if you’re using eSTAR.

eSTAR Application Review Process:

  • The FDA conducts a virus scanning and technical screening process for eSTAR submissions.
  • Incomplete eSTAR submissions will be held until completed.
  • Subsequent review processes follow FDA guidelines for substantial equivalence and De Novo classification requests.

How to Submit your eSTAR 510k application: 

Choose from various submission methods, including online through the Electronic Submission Gateway, the CDRH portal, or by mail. Stay updated and make your medical device submissions more efficient with the eSTAR template – your gateway to smoother FDA interactions.

Our experts at Quality Smart Solutions are here to help and offer medical device-related regulatory advice and support on successfully securing your medical device license.  We can help you by responding to potential information requests, keeping your license updated, and reviewing your device labels (510k Medical Device Registration, Facility Registration & FURLS, IVD Device Registration, and SaMD Classification

Frequently Asked Questions about eSTAR

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