Andrew Parshad is President, CEO and founder of Quality Smart Solutions, a North American compliance solutions provider offering regulatory and quality assurance services to comply with FDA & Health Canada brands and ingredients regulations in the categories of dietary supplements, foods, cosmetics, OTC drugs and medical devices. Andrew started Quality Smart Solutions in 2007. Since that time he and his firm has served thousands of clients worldwide . Andrew's affiliate company, Quality IMPORT Solutions that offers import agent services into the Canadian market as a government licensed importer for foods, dietary supplements and medical devices.
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.
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.
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:
Identifying Panel Members: Ensure that GRAS panel members have appropriate expertise in the relevant field.
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.
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.
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
Determine Device Classification: Identify the correct classification of your medical device according to the FDA’s classification system (Class I, II, or III).
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.
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.
Facility Registration: Concurrently, ensure that your establishment is registered in the FDA FURLS database. Update registration information annually to maintain compliance.
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.
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.
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
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.
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.
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
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.
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.
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
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.
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.
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.
Implementing Monitoring Procedures: Continuous monitoring of CCPs is essential. This involves regular checks, measurements, and observations to maintain critical limits.
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.
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.
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.
Navigating 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!
Are 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
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.
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!
Introducing 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.
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.
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.
Examples of 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.
1. 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.
2. 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.
3. Acing the labeling 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 labeling right? This is where another manufacturer found itself in a bind. Their labeling 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.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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:
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.
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.
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.
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.
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.
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
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.
Diverse Global Standards: To market your device internationally, you must navigate diverse regulations. Each country has its requirements, making compliance a multifaceted challenge.
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?
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.
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.
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
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.
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!
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:
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.
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.
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.
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.
Prepare an FDA Application: Register your establishment with the FDA and submit your 510(k) application online through the FDA’s electronic submission gateway.
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.
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.
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.
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
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.
Market Access Challenges: Non-compliance can limit your product’s market access or lead to development recalls, resulting in significant financial losses.
Legal Consequences: Ignoring or inadequately addressing Warning Letters can escalate the situation, potentially leading to legal actions, including product seizures, injunctions, and fines.
Resource Drain: Rectifying compliance issues can be time-consuming and costly, diverting resources from business growth and development.
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:
Stay Informed: Regularly monitor FDA guidance and regulations related to your products. The FDA frequently updates guidelines, and staying informed is critical.
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.
Labeling and Marketing Claims: Ensure your product labels and marketing materials adhere to FDA guidelines. Avoid making unapproved health claims or using misleading language.
Documentation: Maintain meticulous records of your products’ formulation, testing, and distribution to demonstrate compliance in case of an audit.
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.
In 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
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.
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.
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.
Payment of Applicable Fees: The FDA typically charges a notification submission fee. Scrutinize the current fee schedule and proceed with the requisite amount.
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
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.
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.
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.
Health Canada, the regulatory authority overseeing food and drug safety in Canada, has recently taken a significant step toward food supplements. On September 20, 2023, Health Canada implemented a crucial modification, permitting the use of L-alpha-glycerylphosphorylcholine, also known as alpha GPC or choline alfoscerate, as a supplemental ingredient in foods. This decision was made based on a comprehensive safety assessment conducted by Health Canada’s Food Directorate.
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.
Public Consultation and Feedback
In recognition of the significance of this regulatory change, Health Canada initiated a public consultation process by publishing a “Notice of proposal to enable the use of L-alpha-glycerylphosphorylcholine as a supplemental ingredient in foods” on April 17, 2023. This notice was open for public comment for a period of 75 days. However, no new scientific information was submitted to the department in response to this notice. Consequently, the conclusions drawn during the initial assessment remained unchanged.
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.
In conclusion, 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:
Food Category: This indicates the type of food to which the supplemental ingredient may be added.
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.
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.
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.
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:
Supplemental Ingredient Details: Comprehensive information on all permitted supplemental ingredients, their respective conditions of use, and other essential details.
Regulatory Compliance: Guidance on ensuring compliance with the regulations governing supplemented foods, including labeling requirements and safety standards.
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
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:
Food Category: This indicates the type of food to which the supplemental ingredient may be added.
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.
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.
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
Supplemental Ingredient Details: Comprehensive information on all permitted supplemental ingredients, their respective conditions of use, and other essential details
Regulatory Compliance: Guidance on ensuring compliance with the regulations governing supplemented foods, including labeling requirements and safety standards
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.
In summary, 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.
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.
If 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.
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.
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.
You’re about to step into a regulated industry designed to ensure the safety and quality of products. To successfully navigate this space, it’s crucial to understand the requirements and regulations governing the sale of dietary supplements. This article will explore the essential steps and criteria for selling dietary supplement products in the U.S.
1. Understanding Dietary Supplements
Before delving into the requirements, let’s clarify what dietary supplements are. According to the Dietary Supplement Health and Education Act (DSHEA) of 1994, dietary supplements are products intended to supplement the diet. They can include vitamins, minerals, herbs, botanicals, amino acids, enzymes, and other substances.
2. Compliance with DSHEA
The DSHEA serves as the foundational regulatory framework for dietary supplements in the U.S. It sets forth essential requirements that manufacturers and distributors must adhere to:
Product Labeling: Dietary supplements must have accurate labeling, including a Supplement Facts panel that provides information about the product’s ingredients and serving size.
Ingredient Safety: Manufacturers are responsible for ensuring the safety of ingredients used in their products. They should not include ingredients that are unsafe or unapproved.
Claims and Statements: Claims made on dietary supplement labels must be truthful and not misleading. They cannot claim to treat or cure specific diseases.
3. Establishing Good Manufacturing Practices (GMPs)
Manufacturers must follow Good Manufacturing Practices (GMPs) outlined by the U.S. Food and Drug Administration (FDA). These practices ensure that dietary supplements are produced consistently and meet quality standards. GMPs cover various aspects, including facility cleanliness, equipment maintenance, and employee training.
4. Notification to the FDA
While dietary supplements don’t require FDA approval before entering the market, manufacturers must notify the FDA about their products. This notification includes information about the product’s ingredients and labeling. It’s essential to make this notification within 30 days of product launch.
5. Adherence to Dietary Supplement Labeling Requirements
Proper labeling is a cornerstone of dietary supplement compliance. Labels should accurately represent the product’s ingredients, serving size, and claims. It’s crucial to avoid labeling that implies the product is a drug or can cure specific ailments.
6. Avoiding Disease Claims
One critical requirement is the prohibition of disease claims. Dietary supplements cannot claim to diagnose, treat, cure, or prevent diseases. Such claims would categorize the product as a drug, subject to different regulations.
7. Quality Control and Testing
Manufacturers must establish robust quality control systems to ensure their dietary supplements’ identity, purity, strength, and composition. Testing and quality assurance are vital to meeting these requirements.
8. Adverse Event Reporting
Manufacturers and distributors must report serious adverse events associated with their dietary supplements to the FDA. This helps monitor the safety of these products.
9. Compliance with State Regulations
Some states have additional regulations regarding dietary supplements. Ensure compliance with both federal and state requirements.
10. Ongoing Monitoring and Updates
The dietary supplement industry is subject to evolving regulations and ingredient safety evaluations. Stay informed about updates to maintain compliance. Selling dietary supplements in the United States can be a lucrative endeavor. Still, it comes with a responsibility to meet rigorous regulatory standards. By understanding and adhering to these requirements, you can confidently enter the market and offer safe, high-quality products to consumers.
For importers in the global food trade, ensuring the safety and compliance of imported products is a top priority. The Foreign Supplier Verification Program (FSVP) is vital to this effort, requiring importers to adhere to specific rules and meticulously maintain accurate records. In this article, we’ll delve into everything importers need to know about FSVP rules and the crucial role of journals in demonstrating compliance and safeguarding consumer health. Click here to learn more about the FSVP Importer Requirements.
Understanding FSVP Rules
Hazard Analysis: Importers are required to perform a thorough hazard analysis for each imported food product. This involves identifying potential hazards, assessing their likelihood and severity, and determining appropriate preventive measures.
Verification Activities: FSVP rules mandate that importers conduct verification activities to ensure the safety of imported products. These activities include on-site audits, testing, supplier questionnaires, and reviewing supplier records.
Supplier Verification: Importers must verify that their foreign suppliers meet the same safety standards required for domestic food producers. This involves assessing the supplier’s compliance history, safety practices, and product testing.
Documentation and Records: Comprehensive documentation is essential for FSVP compliance. Importers must maintain records that demonstrate their adherence to FSVP rules. This includes hazard analysis documentation, verification results, communication with suppliers, and corrective action plans.
The Crucial Role of FSVP Records
Record-Keeping Requirements: FSVP regulations require importers to maintain records for a specific duration, typically two years. These records must be readily accessible for inspection by regulatory authorities, allowing them to verify compliance.
Transparency and Accountability: Accurate and well-organized records clarify your compliance efforts. In the event of an audit or inspection, thorough records demonstrate your commitment to safety and help build trust with regulatory authorities.
Evidence of Compliance: Records indicate that you have conducted hazard analyses, performed verification activities, and taken necessary corrective actions. This evidence showcases your dedication to product safety.
Corrective Actions: Records of disciplinary actions taken in response to identified hazards or non-compliance demonstrate your commitment to addressing issues promptly and effectively.
Maintaining Effective FSVP Records
Organized Documentation: Create a systematic approach to record-keeping. Maintain digital or physical folders for each imported product, including hazard analyses, verification reports, and supplier communication.
Timely Updates: Ensure records are updated in real-time as you conduct verification activities and identify hazards. Timely updates provide an accurate representation of your compliance efforts.
Regular Reviews: Periodically review your records to identify any gaps or areas for improvement. This proactive approach ensures that your documentation remains comprehensive and accurate.
Conclusion:
For importers, FSVP rules and records form the backbone of product safety and regulatory compliance. By understanding FSVP rules, diligently maintaining accurate records, and embracing transparency, importers contribute to a safer global food supply chain. Effective record-keeping demonstrates compliance, builds trust with regulatory authorities, and prioritizes consumer health. As importers continue to navigate the intricate landscape of FSVP regulations, comprehensive records are a powerful tool in upholding the highest standards in importing food products.
How Quality Smart Solutions can help
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 or reviewing when the new Supplemented Food rules.
*This summary of Health Canada’s guidance document provides compliance details for manufacturers submitting a new or amended application. Under the regulations, this applies to Class II, III, and IV for MLMD. It does not cover the non-ML information required in a medical device license application.*
Artificial intelligence (AI) encompasses algorithms and models that perform tasks like learning and decision-making. Machine learning (ML) is a subset of AI, where algorithms learn from data to create models. When ML is applied to medical devices, they are called machine learning-enabled medical devices (MLMD), subject to regulations.
“Transparency” means clear information about a device’s impact on risks and patient outcomes, which is crucial for safety and informed decisions.
A predetermined change control plan (PCCP) allows Health Canada to manage planned changes to ML systems addressing known risks. Terms and conditions (T&Cs) may be added to medical device licenses to enhance safety.
Health Canada follows the International Medical Device Regulators Forum (IMDRF) terms. An “ML training algorithm” establishes model parameters from data, the “ML model” makes predictions, and the “ML system” is a medical device with ML capabilities, all regulated by Section 1 of the regulations.
The policy objective of this guidance is to provide manufacturers with a framework for demonstrating the safety and effectiveness of Machine Learning-Enabled Medical Devices (MLMDs) in various contexts. This guidance applies when manufacturers seek Class II, III, or IV medical device licenses or amend such permits throughout the device lifecycle.
Policy Statements:
MLMD Definition: An MLMD can be standalone software meeting the medical device definition or a medical device incorporating software meeting the definition.
In Vitro Diagnostic Devices (IVDDs): MLMDs can be either IVDDs or non-IVDDs, with risk classifications ranging from Class I to Class IV.
Cover Letter Statements: Manufacturers must explicitly state in their cover letters for Class II, III, and IV MLMD applications that the device employs ML. For MLMDs with a Predetermined Change Control Plan (PCCP), manufacturers must mention the presence of a PCCP in the cover letter to prevent application delays.
Classification Justification: Manufacturers should justify the proposed medical device classification of the MLMD, referring to the classification rules in Schedule 1 of the regulations.
Regulatory Requirements: MLMDs must meet the applicable requirements outlined in sections 10 to 20 of the regulations. Manufacturers must ensure the availability of objective evidence supporting the device’s intended use, safety, effectiveness, and associated claims.
Safety and Effectiveness Assurance: Applications must demonstrate that the MLMD, including the PCCP, if applicable, adheres to safety and effectiveness requirements and maintains a favorable risk-benefit profile for patients.
Application Information: Class II, III, and IV applications must include the information in section 32 of the regulations. Health Canada may request additional information during the review process.
Evidence Consideration: Health Canada recognizes the diversity of information, methodologies, and evidence manufacturers use to establish MLMD safety and effectiveness. The guidance offers considerations rather than fixed requirements to accommodate different scenarios.
Representative Data: Data used by manufacturers should adequately represent the Canadian population and clinical practices, including factors like skin pigmentation, sex differences, and other identity-related variables.
Predetermined Change Control Plan (PCCP): Changes made under an authorized PCCP do not require a separate medical device license amendment application. Such changes remain subject to post-market regulatory oversight.
Amendments Outside PCCP: For modifications outside an authorized PCCP, manufacturers should consult the regulations and relevant guidance to determine if the change constitutes a significant change requiring a license amendment application.
PCCP Submission: Manufacturers may submit a PCCP with applications for new medical device licenses or amendments.
Policy Evolution: This guidance represents Health Canada’s current approach, subject to revision as technology advances and regulatory oversight matures. Health Canada remains adaptable to optimize regulatory practices.
Health Canada MLMD Product Lifecycle Components
Health Canada emphasizes the significance of product lifecycle information in establishing the safety and effectiveness of Machine Learning-Enabled Medical Devices (MLMDs). The MLMD lifecycle comprises several key components, including:
Design: The initial design phase is where the MLMD’s architecture, features, and functionalities are conceptualized and developed.
Risk Management: The assessment and management of risks associated with the MLMD throughout its lifecycle, ensuring patient safety.
Data Selection and Management: The careful selection and effective management of data used in MLMD development and operation is vital for accuracy and reliability.
Development and Training: The process of training ML algorithms, establishing parameters, and refining the ML model to enhance performance.
Testing and Evaluation: Rigorous testing and evaluation to verify the MLMD’s functionality, accuracy, and safety under various conditions.
Clinical Validation: Validation through clinical studies and real-world use to confirm that the MLMD meets its intended medical purpose.
Transparency: Ensuring clear and comprehensive information about the MLMD is available, contributing to informed decision-making.
Post-Market Performance Monitoring: Ongoing monitoring of the MLMD’s performance and safety once it is in the market, including detecting any adverse events or issues.
According to Health Canada’s perspective, these components collectively form the MLMD product lifecycle, which is critical in demonstrating its safety and effectiveness.
Good Machine Learning Practice (GMLP) for MLMDs
Implementing Good Machine Learning Practice (GMLP) is crucial in all Machine Learning-Enabled Medical Device (MLMD) development and maintenance phases. GMLP ensures the creation of safe, effective, and high-quality medical devices.
When applying for an MLMD license, manufacturers should provide evidence of adopting GMLP practices throughout their organization and the product’s lifecycle. This evidence should also include details about quality practices to support changes outlined in a Predetermined Change Control Plan (PCCP).
Predetermined Change Control Plan (PCCP): Concept
A PCCP is a documentation that characterizes the MLMD, its boundaries, intended ML system changes, change management protocols, and impacts. It is an integral part of the device’s design.
PCCPs should be risk-focused, evidence-supported, and provide transparency. They should consider the entire product lifecycle.
Changes listed in a PCCP must ensure the device remains within its intended use. Changes to medical conditions, purposes, or benefits require a separate medical device license amendment application before implementation.
Appropriate changes for inclusion in a PCCP require pre-authorization to address known risks while preserving patient benefits. For instance, changes may aim to maintain or enhance performance, countering the threat of ML performance decline due to environmental alterations or input data variations.
PCCPs facilitate proactive risk management while maintaining rigorous regulatory standards to ensure the safety and effectiveness of the device.
MLMD Risk Management Guidance
Manufacturers are crucial in managing Machine Learning-Enabled Medical Devices (MLMDs) risks. This involves providing descriptions of:
Identified Risks and Controls: Manufacturers should detail the risks linked to the MLMD and the measures to mitigate or eliminate these risks.
Risk Assessment Technique: The method employed for initial and ongoing risk assessments and the system for categorizing and evaluating risk levels.
Risk Assessment Outcomes: The results of the risk assessment process.
The risk analysis should also consider the following factors, where applicable:
Erroneous Outputs include instances of false positives, false negatives, or incorrect information used for diagnosis or treatment.
Bias: While SGBA Plus analysis may address some intolerance, manufacturers should consider and manage unwanted bias in MLMDs.
Overfitting: This issue occurs when a model is overly tailored to specific training examples, making it less applicable to broader problems.
Underfitting: When a model doesn’t capture all relevant properties of the training population, resulting in limited applicability.
Performance Degradation: ML system performance can decline due to various factors like demographic shifts, changes in clinical practice, or alterations in input data.
Automation Bias occurs when users overly rely on device outputs, potentially disregarding contradictory data or human decisions.
Alarm Fatigue: Users become desensitized to alarms due to excessive exposure, which can lead to missed alarms.
PCCP-Related Risks: Consider risks associated with Predetermined Change Control Plans (PCCPs) and their impacts on risk management.
For comprehensive risk management in MLMDs, manufacturers should refer to ISO 14971, which guides applying risk management to medical devices.
The Food Safety Modernization Act (FSMA) Made Simple
Imagine a world where preventing food-related illnesses is more important than dealing with them after they happen. That’s precisely what the FSMA, introduced in 2011, aims to achieve. The FSMA focuses on stopping contamination and illnesses before they occur, covering various stages of the food supply chain, like production, transportation, and imports. Its main goal is to find and eliminate risks before they become dangerous.
Key Parts of FSMA Safety
Preventive Controls for Human Food (PCHF): This is the heart of FSMA. It says that companies must create plans to keep food safe. These plans include finding possible problems, putting in actions to prevent issues, keeping a close watch, fixing problems, and checking to ensure the method works.
Preventive Controls for Animal Food: This part is like PCHF for animal food. It ensures the same safety principles, including finding hazards, putting controls in place, and watching suppliers.
Foreign Supplier Verification Program (FSVP): Since our food comes from all over the world, this ensures that the food brought into the US is safe. Importers must ensure that foreign suppliers follow the same safety rules as the US.
Meeting FSMA Rules
In a world where following rules keeps us safe, understanding and sticking to FSMA rules is super important. Follow these rules to avoid big problems like fines, recalling products, and hurting your reputation. Here’s how to make sure you’re doing the right thing:
Know What Applies to You: Figure out which FSMA rules matter for what you do. FSMA covers food-related issues, so knowing your role in the food chain is vital.
Plan for Safe Food: A solid plan to keep food safe is necessary. This plan involves looking at possible problems, using smart controls to avoid them, keeping a close eye on things, and ensuring the method works.
Trust Your Suppliers: If you work with suppliers, make sure they’re reliable. Checking them thoroughly helps ensure that what they give you is safe to use.
Teach Your Team: Your team is crucial to keeping food safe. Training them well in safety rules, cleanliness, and their roles in keeping things safe is a must.
How FSMA Consulting Helps
Experts can guide you through the FSMA maze. FSMA consulting services can help you make sense of the rules and give you tailored plans for food safety. They’re great at finding possible problems, making safety plans, and offering ongoing help for following the rules.
To Sum up,
FSMA is all about keeping us healthy. By preventing problems rather than dealing with them later, it makes sure our food is safe. Following FSMA rules isn’t just a formality; it’s about protecting public health and our food supply. Businesses that understand this and work with FSMA experts are leading the way in providing safe, top-quality food to all of us.
In the intricate world of global trade, ensuring the safety and compliance of imported and exported food products is a shared responsibility. The Foreign Supplier Verification Program (FSVP) stands as a cornerstone in this effort, safeguarding the well-being of consumers and the integrity of the food supply chain. When navigating the FSVP landscape, choosing the right FSVP agent is a pivotal decision for both importers and exporters. In this article, we’ll delve into the benefits of partnering with an FSVP agent and provide a list of essential FAQs to ask before making this significant choice. Click here to learn more about the FSVP Importer Requirements.
Benefits of Choosing an FSVP Agent:
Expertise and Compliance: An experienced FSVP agent possesses in-depth knowledge of FSVP regulations. By partnering with an agent, importers and exporters ensure full compliance with the requirements.
Tailored Solutions: Each business has unique operations and needs. An FSVP agent crafts personalized solutions that align with the specific nature of your imports or exports, streamlining the compliance process.
Navigating Complexities: FSVP regulations can be complex and subject to updates. An FSVP agent constantly monitors changes, keeping you informed and helping you adapt to evolving compliance standards.
Audit Readiness: Regular audits are part of FSVP compliance. A seasoned FSVP agent prepares your business for audits, ensuring all documentation and processes are audit-ready.
Risk Assessment: Identifying potential hazards and risks is vital. An FSVP agent conducts thorough risk assessments, guiding you in prioritizing mitigation efforts and enhancing product safety.
FAQs to Ask Before Choosing an FSVP Agent:
What is Your Experience with FSVP Compliance? Please inquire about the agent’s background and expertise in FSVP regulations to ensure a strong track record.
How Will You Tailor Compliance Strategies to My Business? Understanding how the agent customizes solutions to your unique needs ensures effective compliance.
What Tools and Resources Do You Provide for Record-Keeping? Comprehensive record-keeping is crucial. Ask about the tools and support they offer to maintain accurate records.
How Do You Stay Updated with Regulatory Changes? To keep your business compliant, an agent should have a straightforward process for staying informed about FSVP regulation updates.
Can You Provide References or Case Studies? Request references or case studies to gauge their success in assisting businesses like yours.
What Support Do You Offer During Audits? Ensuring the agent assists during audits provides a smoother experience when regulatory authorities review your operations.
What is Your Approach to Risk Assessment? Understanding their risk assessment process highlights their dedication to product safety.
Ten steps to creating an FSVP plan
Step 1: Understand FSVP Requirements: Before diving into implementation, familiarize yourself with the FSVP requirements outlined by the U.S. Food and Drug Administration (FDA). Gain a clear understanding of your responsibilities, including conducting hazard analyses, supplier verification, record-keeping, and corrective actions.
Step 2: Identify Applicable Foreign Suppliers: Compile a list of foreign suppliers who provide food products to your business. Prioritize suppliers based on the risk level associated with their products and ensure you have access to their necessary information.
Step 3: Conduct a Hazard Analysis: Evaluate potential hazards associated with each imported food product. Consider biological, chemical, and physical risks during production, transportation, and handling.
Step 4: Determine Verification Activities: Based on the hazard analysis, identify appropriate verification activities to ensure the safety of imported products. These activities may include on-site audits, sampling and testing, supplier questionnaires, and documentation reviews.
Step 5: Develop a Supplier Verification Program: Craft a comprehensive supplier verification program outlining each supplier’s specific verification activities. This program should detail the frequency of verifications, criteria for approval, and any corrective actions required.
Step 6: Establish Record-Keeping Procedures: Maintain meticulous records of your FSVP activities: document hazard analyses, verification results, corrective actions, and communication with suppliers. Ensure records are organized, easily accessible, and retained for the required timeframe.
Step 7: Implement Corrective Actions: In cases where hazards are identified, or verification activities uncover non-compliance, take prompt corrective actions. These actions should address the root cause of the issue and prevent its recurrence.
Step 8: Provide Supplier Training: Educate your foreign suppliers about FSVP requirements and the importance of compliance. Offer guidance on meeting safety standards and providing necessary documentation.
Step 9: Review and Update Your FSVP Plan: Regularly review and update your FSVP plan to ensure it remains effective and aligned with changing regulations. Conduct internal audits to assess the plan’s implementation and identify improvement areas.
Step 10: Seek Expert Assistance: Navigating the complexities of FSVP implementation can be daunting. Consider partnering with regulatory consultants who specialize in FSVP compliance. These experts provide invaluable guidance, ensuring your plan is comprehensive and compliant.
Conclusion:
Selecting the right FSVP agent is a pivotal choice for importers and exporters, impacting compliance, safety, and the success of their businesses. With the benefits of expertise, tailored solutions, and audit readiness, an FSVP agent becomes a trusted partner in navigating the regulatory landscape. By posing crucial questions about compliance strategies, resources, and support, businesses can make an informed decision, confident that their chosen FSVP agent will guide them toward maintaining the highest standards in the global food trade.
How Quality Smart Solutions can help
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 or reviewing when the new Supplemented Food rules.
From FDA guidelines to global regulatory standards, understanding the nuances of each requirement is essential to ensure a timely and successful drug submission. Our experts have analyzed the latest updates and compiled a comprehensive guide to help you stay ahead of the curve.
In the dynamic and highly regulated world of pharmaceuticals, staying ahead of the game is not just a competitive advantage; it’s a necessity. Understanding the latest requirements for new drug submissions is essential for pharmaceutical companies seeking to bring new drugs to market. This article delves into the key insights that can keep your drug development process on track and compliant with evolving regulations while highlighting the substantial benefits of investing in new drug submissions. Check out our dedicated page for ANDS and NDS submissions for more information.
The Evolving Landscape of New Drug Submissions
The landscape of new drug submissions is continuously evolving. Regulatory authorities such as the U.S. Food and Drug Administration (FDA), the European Medicines Agency (EMA), and others worldwide regularly update their guidelines and requirements. Staying informed about these changes is paramount, allowing pharmaceutical companies to adapt swiftly and ensure their submissions meet the latest standards.
Navigating the Regulatory Maze: A Worthwhile Investment
One of the first steps in preparing a new drug submission is identifying your product’s specific regulatory pathway. Different types of drugs (e.g., small molecules, biologics, generics) often follow distinct regulatory routes. Understanding which path your prescription falls under is crucial to meeting the correct submission requirements.
Investing in a well-versed regulatory affairs team or partnering with experts in the field can streamline this process. Pharmaceutical companies can confidently avoid costly delays and navigate the regulatory maze by doing so.
Quality Data Is King: Ensuring Successful Approvals
The quality of the data submitted is a cornerstone of a successful new drug submission. Rigorous testing and documentation of the drug’s safety, efficacy, and manufacturing processes are paramount. The FDA and other regulatory bodies emphasize the importance of comprehensive and well-organized data to support a submission.
Investing in robust data collection, analysis, and documentation processes is not just a regulatory requirement; it’s a strategic investment in the success of your drug. A well-prepared submission can increase the likelihood of timely approvals and market access.
Benefit-Risk Assessment: A Strategic Advantage
Assessing the benefit-risk profile of your drug is a central focus for regulatory authorities. It would be best to thoroughly analyze the drug’s benefits compared to its potential risks. A well-structured benefit-risk assessment can make a difference in the approval of your submission.
Investing in comprehensive benefit-risk assessments during drug development can enhance your product’s competitive edge. By proactively addressing potential risks and demonstrating superior benefits, your drug stands a better chance of receiving regulatory approval.
Patient-Centricity and Real-World Data: Gaining Market Advantage
Regulatory agencies increasingly value patient-centric approaches and real-world data in assessing drug submissions. Demonstrating how your drug meets patients’ needs and leveraging real-world evidence can strengthen your proposal.
Investing in patient engagement and real-world data collection aligns with regulatory expectations. It resonates with healthcare providers, payers, and patients. It can differentiate your product in the market and accelerate its adoption.
Global Harmonization: Expanding Market Reach
Global harmonization initiatives aim to align regulatory requirements across different regions. Understanding and navigating these harmonization efforts can simplify the submission process for drugs intended for multiple markets.
Investing in a global regulatory strategy can maximize market reach and profitability. By aligning submissions with international standards, pharmaceutical companies can reduce duplication of efforts and capitalize on larger patient populations.
Digital Submissions and eCTD: Efficiency and Compliance
The move toward electronic Common Technical Document (eCTD) submissions is becoming more prevalent. Familiarizing yourself with eCTD formats and requirements is crucial for a smooth submission process.
Investing in digital submission capabilities enhances efficiency and compliance. It streamlines document management, accelerates review processes, and reduces the risk of errors.
The interaction between the pharmaceutical company and regulatory authorities continues after submission. Engaging in a collaborative dialogue and promptly addressing questions and concerns raised during the review process can significantly impact the outcome.
Investing in effective communication and a responsive regulatory affairs team can lead to faster approvals and a more favorable regulatory relationship.
Conclusion: A Sound Investment in Patient Health and Market Success
In conclusion, new drug submissions are not just a regulatory requirement; they represent a sound investment in patient health and market success. By staying informed, prepared, and flexible, pharmaceutical companies can successfully navigate the complex world of drug submissions. The benefits include expedited market access, enhanced competitiveness, and, most importantly, the opportunity to bring life-changing therapies to needy patients. As the pharmaceutical landscape evolves, those who invest wisely in new drug submissions stand to reap the rewards of innovation and impact.
In the realm of food production and processing, safety is paramount. Ensuring our food is free from contaminants and meets stringent quality standards is a shared responsibility. This is where Good Hygiene Practices (GHP) and Good Manufacturing Practices (GMP) come into play. This comprehensive guide will explore the significance of GHP and GMP regulatory food safety audits. We’ll uncover why these audits are crucial and how they contribute to safeguarding the integrity of our food supply. We’ll help you unpack everything to do with food regulations.
Understanding GHP and GMP: The Foundation of Food Safety
GHP (Good Hygiene Practices): GHP focuses on the cleanliness and hygiene of facilities and personnel involved in food handling and production. It encompasses a wide range of practices, including proper handwashing, sanitation of equipment, safe food storage, and maintaining hygienic working conditions. GHP lays the foundation for safe food handling from farm to fork.
GHP includes practices such as:
Personal Hygiene: Ensuring that food handlers maintain cleanliness through proper handwashing, wearing suitable protective clothing, and minimizing the risk of contamination.
Sanitization: Regular cleaning and sanitizing of equipment, utensils, and food preparation surfaces to prevent the growth of harmful bacteria.
Safe Food Storage: Proper storage conditions to prevent spoilage and contamination of food products.
Waste Management: Proper disposal of food waste and other materials to prevent pests and cross-contamination.
Good Hygiene Practice, or GHP, is a critical element in managing food chain hygiene along the entire food supply chain and ensuring that the food is secure and fit for consumption. It deals with many facets of the food industry, such as physical and chemical pollution control, worker hygiene, sanitary facilities, and the food supply chain. It is frequently required for other food safety management programs, including HACCP, ISO 2200, GAP, etc.
The essential hygienic and sanitary procedures are covered by GHP compliance. It draws attention to problem areas and possible roadblocks to raising your standards for food safety. Your workplaces, equipment, and facilities will be examined throughout the audit to identify potential hazards and areas that need improvement. It will assess and ensure that the food being processed is suitable for human consumption and is the bare minimum required to comply with regulations in the industry for hotels and restaurants. Food contamination and disease should not be taken lightly; GHP compliance will aid in that consideration.
What is the purpose of GHP in Food Safety?
The purpose of GHP is to:
Minimize Health Risks: GHP practices reduce the risk of foodborne illnesses by preventing contamination at every stage of food production and handling.
Maintain Product Quality: By adhering to GHP, businesses ensure that their products meet quality standards and are safe for consumption.
Compliance: GHP helps businesses comply with food safety regulations and standards, avoiding legal issues and penalties.
GMP (Good Manufacturing Practices): GMP deals with the specific processes and procedures used to manufacture and process food products. It ensures that products are consistently produced and controlled to meet quality standards. GMP covers aspects like ingredient sourcing, equipment maintenance, and product testing.
What Are the Good Manufacturing Practices (GMP) in the Food Industry?
GMP in the food industry includes:
Quality Control: Implementing measures to maintain product quality throughout the production process.
Documentation: Keeping detailed records of production processes, ingredient sources, and quality control measures.
Employee Training: Ensuring that staff is adequately trained in GMP procedures.
What Are the 10 Principles of GMP?
Nevertheless, the GMP guidelines can change based on the area of the food processing industry.
They consist of ten fundamental GMP guidelines that all food producers must adhere to:
Standard Operating Procedures (SOPs) should be written in step-by-step format.
Apply the SOPs and procedures.
For the aim of traceability, promptly and precisely document processes and procedures.
Verify the efficiency of your SOPs and the efficacy of your procedures.
Integrate quality and safety into the equipment and facilities.
Regularly maintain the building, its systems, and its equipment, and keep records of it.
Internally establish job competency.
Encourage cleanliness by performing regular sanitization.
Implement a methodical quality control for both the components and the processes.
To maintain legal compliance and GMP efficacy, conduct routine audits.
Conclusion:
GHP and GMP regulatory food safety audits are not just routine procedures; they are the backbone of a safe and reliable food supply chain. By adhering to these practices and undergoing audits, businesses ensure that their food is of the highest quality and, most importantly, safe for consumers. The importance of these audits cannot be overstated, as they are instrumental in protecting public health and maintaining the integrity of the food industry.
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.
So you’ve got a game-changing medical device that could reshape healthcare as we know it. Amazing! But before making that impact, you must navigate the labyrinth of FDA regulations and registrations, specifically the 510(k) pathway. In this guide, we’ll break down the process in a relatable way, covering everything from FDA regulations to the nitty-gritty of 510(k) clearance. Let’s roll up our sleeves and dive into the world of FDA registration for your medical devices.
Understanding FDA Registration and the 510(k) Process:
Before your medical device hits the market, it needs an FDA seal of approval. Think of the FDA as the safety net, ensuring your medical device is effective and safe for users. FDA registration is your golden ticket to entering the healthcare market. The 510(k) process, named after the corresponding section of the law, is your roadmap to getting there.
Why Opt for 510(k) Clearance?
The 510(k) clearance isn’t just a bureaucratic hurdle; it’s your express pass to the market. Compared to the often-length premarket approval (PMA) process, the 510(k) pathway offers a quicker route. If your device resembles existing ones, this pathway could be your best bet to bring your innovation to those needing it swiftly.
Breaking Down the 510(k) Journey:
Getting Acquainted with Device Classification: Consider device classification, like assigning clothing categories. Your device falls into Class I, II, or III, each with its requirements. Knowing your class is the first step in the journey.
Meet the “Predicate Device”: Imagine this as finding your device’s kindred spirit. A predicate device is a similar device that has already received FDA clearance. Proving substantial equivalence to this device is a cornerstone of the 510(k) process.
Creating Your Device’s Showcase – 510(k) Submission: This is your device’s time to shine. Your submission package is like a comprehensive portfolio, including specs, performance data, comparisons to the predicate device, safety data, and what sets your device apart.
Lights, Camera, Action – FDA Review: Think of the FDA review process like a grand movie premiere. FDA experts meticulously review your submission, ensuring your device meets safety and effectiveness standards. They might request more info or give you a thumbs-up.
The Victory Lap – 510(k) Clearance: If your submission meets FDA expectations, you’ll receive a letter granting 510(k) clearance. It’s like your device’s graduation day, marking the moment it’s officially ready to hit the market.
Navigating Challenges with a Smile:
The journey can be challenging. Challenges like selecting the predicate device or collecting solid data can crop up. These hurdles are opportunities to fine-tune your submission and demonstrate your device’s value.
Deciphering the Jedi-Level – FDA 510(k) Regulations:
The FDA’s 510(k) regulations are like the rules of engagement for medical device clearance. They outline everything from what data you need to submit to how to address potential risks. It’s your playbook for a successful submission.
Consultants as Your Co-Pilots:
FDA-speak can feel like a foreign language, and that’s where consultants come in. These experts have navigated the FDA terrain numerous times. They’ll guide you through the process, translate the jargon, and ensure your submission is thorough and compliant.
Conclusion:
Securing FDA clearance through the 510(k) process isn’t just a milestone; it’s a testament to your commitment to healthcare innovation. Armed with knowledge and supported by experts, you’re well-equipped to bring your medical device to market. The journey might be filled with twists and turns, but each step brings you closer to impacting lives and improving healthcare outcomes.
In today’s fast-paced and diverse industries, pursuing safety and quality isn’t just a goal; it’s a non-negotiable commitment. This is where HACCP – Hazard Analysis and Critical Control Points – takes center stage. It’s not just a buzzword; it’s a systematic approach that safeguards products and instills consumer trust. Let’s delve into the depths of HACCP regulations, understanding their significance, implementation, and how they empower industries across the board.
Understanding HACCP Regulations: Laying the Foundation
Deciphering HACCP Regulations HACCP regulations are the compass that guides businesses toward producing safe and consistent products. By identifying potential hazards and critical control points, industries can create robust protocols to mitigate risks. These regulations form the backbone of product integrity and consumer confidence.
The Weight of HACCP Compliance HACCP compliance isn’t a mere checkbox; it’s a commitment to delivering products that won’t compromise consumer safety. Whether in the food, pharmaceutical, cosmetic, or any other industry, adherence to HACCP guidelines is a testament to your dedication to quality assurance.
Unraveling the HACCP Guidelines: Step by Step
1. Assessment of Hazards begins with identifying hazards that could lurk within your production process. These hazards can range from microbiological contaminants to physical hazards. This step equips you with the knowledge needed to address potential risks.
2. Determining Critical Control Points (CCPs) CCPs are pivotal stages in your process where risks can be controlled or eliminated. For instance, CCPs could include cooking, chilling, or packaging in the food industry. By pinpointing these points, you’re proactively taking charge of product safety.
3. Setting Critical Limits Critical limits are the boundaries that ensure hazards are managed effectively. Whether it’s temperature, time, pH levels, or any other factor, staying within these limits guarantees that your products remain safe and consistent.
4. Implementing Monitoring Procedures Once you’ve set your critical limits, it’s time for vigilant monitoring. Regular checks and inspections ensure that CCPs are operating as intended. Monitoring is your safety net, preventing potential issues from escalating.
5. Corrective Actions and Verification: Even with meticulous planning, deviations can occur. Robust corrective actions are your toolkit for addressing these deviations promptly. Verification steps ensure that your HACCP plan is effective and reliable.
6. Documentation and Record-Keeping Documenting each phase of your HACCP plan isn’t just a formality; it’s a testament to your commitment. These records prove your due diligence and can be invaluable during audits.
Mastering HACCP Certification: The ultimate stamp of excellence
Embarking on the HACCP Certification Journey HACCP certification isn’t just a recognition; it’s a validation of your dedication to safety and quality. Achieving certification involves a thorough evaluation of your HACCP plan by authorized bodies. It’s a badge that signifies your commitment to meeting the highest standards.
The Ripple of Benefits HACCP certification ripples across your operations. It’s not just about compliance; it’s about operational efficiency, enhanced reputation, and access to new markets. Consumers, stakeholders, and regulators recognize and value the seal of HACCP certification.
Conclusion: Elevating Industries Through HACCP
HACCP regulations are more than just rules; they’re a mindset. They foster a culture where safety, quality, and excellence are non-negotiables. From assessing hazards to achieving certification, the journey is a testament to your commitment to consumer well-being. By embracing HACCP, you’re not just complying with regulations but pioneering a new standard of excellence across industries.
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.
In a groundbreaking move, the Association of American Feed Control Officials (AAFCO) has given the green light to an extensive overhaul of pet food and specialty pet food regulations. This decision is set to transform the way pet owners perceive and choose pet food products, marking a significant shift after more than four decades. With an emphasis on clarity and transparency, these changes aim to offer consumers standardized nutritional information, unequivocal ingredient details, and clear storage instructions.
The revisions come as a result of collaborative efforts between feed regulatory professionals, industry experts, and engaged pet owners from across the United States and Canada. The goal was to create a unified set of guidelines that would guide pet food manufacturers and distributors, ensuring that packaging and labels provide a comprehensive understanding of the product in question.
Austin Therrell, the executive director of AAFCO, emphasized the importance of feedback received during the collaborative process. “We sought public comment to learn more about how pet food label changes would enhance transparency and provide clearer information in a consumer-friendly format. New packaging and labels will be well-defined and easy to understand. And that’s good news for all of us, from pet owners and manufacturers to pets themselves,” said Therrell.
The AAFCO has recommended a period of enforcement discretion for states to adopt and enforce the revised Model Regulations for Pet Food and Specialty Pet Food. This approach encourages uniform adoption across states, ensuring consistency in the implementation of the new regulations.
Key highlights of the label changes include:
Nutrition Facts Box: Resembling human-food labeling more closely for easier comprehension.
Intended Use Statement: Relocated to the lower third of the front display panel to assist consumers in quickly understanding the purpose of the pet food.
Ingredient Statement: Clarified with consistent terminology usage and the inclusion of parentheticals and common names for vitamins.
AAFCO’s Pet Food Committee will evaluate the enforcement discretion recommendation annually, addressing potential challenges that may arise during the transition. The ultimate goal is to ensure a seamless and uniform adoption process that benefits consumers, manufacturers, and pets.
The revisions are a result of the Pet Food Label Modernization (PFLM) initiative that began in 2015. The AAFCO collaborated with stakeholders and conducted multiple rounds of consumer research to create a set of regulations that better communicate essential information. This process highlights the power of collaboration between industry professionals and consumers, ultimately leading to improved pet food labels that empower pet owners to make informed decisions. For more information about PFLM, visit AAFCO’s official page.
Introduction: Navigating international trade regulations and the intricacies of Importer of Record (IOR) compliance and taxes can be complex. This comprehensive guide breaks down IOR compliance and its connection to tax obligations in the USA, offering a clear understanding for businesses engaged in global trade.
IOR Compliance USA: Connecting Regulations and Tax Responsibilities
What is IOR Compliance?
At the heart of successful international trade lies IOR compliance – the adherence to rules when bringing goods into the US. This guide demystifies IOR compliance and explains its crucial role in maintaining smooth import processes.
IOR Compliance and Taxes: A Balanced Approach
Import Duties and Taxes: Learn how IOR compliance extends beyond import duties to include accurate tax calculations and payments.
Customs Valuation and Tax Calculation: Discover how proper customs valuation impacts tax calculations and ensures accuracy in financial planning.
Harmonized System Codes and Tax Alignment: Find out how aligning Harmonized System codes with tax categories prevents confusion and ensures correct tax application.
Handling Tax Obligations in IOR Compliance
Understanding Tax Rates: Get insights into determining tax rates for various goods, ensuring accurate tax payments.
Effective Tax Documentation: Learn about the importance of thorough documentation for transparent transactions and easy audits.
Meeting Tax Deadlines: Explore the significance of timely tax payments to avoid penalties and disruptions in supply chains.
Strategic IOR Compliance and Tax Management
Strategic Tax Planning: Understand how strategic tax planning within IOR compliance can positively impact your business’s financial outcomes.
Managing Risks: Discover how adhering to tax obligations in IOR compliance reduces financial and legal risks, safeguarding your business’s reputation.
IOR Compliance for Different Business Models: Considering Taxes
IOR Compliance for eCommerce: Find out how eCommerce businesses can ensure IOR compliance aligns with tax considerations for seamless cross-border transactions.
IOR Compliance for International Shipping: Learn how IOR compliance simplifies tax challenges for businesses engaged in international shipping.
Conclusion: Navigating IOR Compliance and Tax Responsibilities
IOR compliance and tax obligations are essential aspects of thriving in international trade. This guide equips businesses with the knowledge to confidently handle IOR compliance, manage taxes, and operate seamlessly in the global marketplace.
Stay Tuned: In the ever-evolving world of regulations and taxes, staying informed and seeking professional advice ensures a positive business journey, navigating the complexities with confidence.
Introduction: Food labels are more than mere stickers on packages; they’re a vital conduit between consumers and the products they choose to bring into their lives. This comprehensive guide delves into the intricate world of food labeling regulations, shedding light on the common threads and distinctions among Health Canada, the US Food and Drug Administration (FDA), and the European Union’s (EU) mandates. From the essential elements that must grace labels to the significance of health claims and the intricate dance of country-of-origin labeling, we embark on an insightful journey through the labyrinth of regulations that shape our understanding and interaction with food choices.
Global Mandates Driving Food Label Requirements: Behind every food label is a profound purpose—to empower consumers, foster transparency, and guide informed choices. Across the globe, regulatory bodies enforce food label mandates for a variety of reasons: Empowering Consumers: Labels provide insight into ingredients, nutrition, and allergens, allowing individuals to tailor their diets. Safety Assurance: Allergen and hazard information helps individuals dodge products that might trigger health concerns. Encouraging Nutrition: Nutrient information aids healthier eating habits and assists in managing dietary objectives. Accommodating Preferences: Labels cater to a spectrum of dietary needs, from restrictions to preferences. Regulatory Adherence: Accurate labels mirror regulatory standards, nurturing consumer trust. Shielding Against Deception: Labels thwart misleading claims, promoting authenticity. Enabling Traceability: Clear labels facilitate traceability, easing recall processes in case of safety concerns. Promoting Uniformity: Consistent label standards empower easy product comparisons. Public Health Advocacy: Labels are integral to public health drives, fostering better dietary habits and curbing foodborne risks.
Key Elements Required on Food Labels: While nuances exist between regions, certain core elements universally grace food labels, regardless of the jurisdiction:
Product Identity: An accurate name that identifies the food product.
Ingredient Listing: A roster of ingredients ordered by weight, with allergens highlighted.
Nutrition Facts: Serving size, calories, macronutrients, vitamins, and minerals.
Allergen Alert: Clear notification of present allergens.
Net Quantity: Weight or volume of the product within the package.
Date Details: “Best before” or “use by” dates.
Country of Origin: Indication of where the product originated.
Usage Instructions: Guidelines for preparing or using the product.
Storage Suggestions: Recommendations for optimal storage.
Distributor Information: Contact details of manufacturer, packer, or distributor.
Food Additives: If applicable, a list of used additives.
Nutrition and Health Claims: Validated assertions about nutritional benefits.
Comprehending Health Claims: Health claims establish a connection between a food/ingredient and a health benefit. These claims fall into nutrient content claims, structure-function claims, and specific health claims. They demand accuracy, scientific backing, and adherence to strict regulatory guidelines to deter misinformation and safeguard consumers.
Here’s an overview of the different types of health claims and their requirements:
Nutrient Content Claims:
Nutrient content claims describe the level of a nutrient in a food, such as “low-fat,” “high-fiber,” or “good source of calcium.”
These claims must meet specific criteria defined by regulatory authorities, which can vary by country.
Nutrient content claims aim to inform consumers about the nutritional value of a product.
Structure-Function Claims:
Structure-function claims describe the role of a nutrient or dietary ingredient in maintaining the standard structure or function of the human body.
These claims are not intended to diagnose, treat, cure, or prevent any disease and should be accompanied by a disclaimer.
Structure-function claims may require substantiation of the claim’s accuracy.
Specific Health Claims:
Specific health claims directly link a food or food component to one particular health outcome, such as “calcium supports strong bones.”
These claims usually require more scientific evidence to demonstrate a cause-and-effect relationship.
Regulatory authorities often review and approve specific health claims before they can be used on labels.
What happens if health claims are unauthorized or misleading?
It’s important to note that using unauthorized or misleading health claims on food labels can lead to regulatory actions, fines, or legal consequences. Therefore, manufacturers and distributors must carefully review and follow the regulations established by their country’s regulatory authority when making health claims on food labels. When in doubt, seeking guidance from regulatory experts and legal professionals can help ensure compliance with health claim requirements.
What is not required on a food label?
While food labeling regulations vary by country and region, certain elements are generally not required on a food label. These non-mandatory elements might include additional information that is helpful to consumers but not essential for legal compliance. Here are some examples of what is typically not required on a food label:
Fancy or Brand Names:
While many products have creative or brand-specific names, these names are not legally required to be included on the label. The product’s identity should be clear, but the specific branding may vary.
Excessive Marketing Language:
While marketing claims can be included, extensive promotional language is not required. Claims like “delicious,” “tasty,” or “best” are not mandatory but are often used for marketing purposes.
Recipe or Serving Suggestions:
While some labels include recipe ideas or serving suggestions, they are not required. These can enhance the consumer’s experience but are not obligatory.
Retail Price:
The product’s retail price is typically not included on the label, as it can vary by location and over time.
Pictures or Graphics:
While product images or graphics can enhance the label’s visual appeal, they are not legally required in most cases.
Contact Information for Consumer Inquiries:
While providing contact information for consumer inquiries is beneficial, it’s only sometimes required by law. Some regulations may mandate it for certain types of products.
Manufacturer’s Signature:
A manufacturer’s signature is often optional on the label. However, the name and contact information of the manufacturer or distributor usually are.
QR Codes or Smart Labels:
QR codes or intelligent labels that provide additional information, such as sourcing details, sustainability information, or different recipes, are not mandatory on food labels.
Cultural or Ethical Labels:
Labels indicating cultural or ethical preferences (e.g., “vegan,” “kosher”) are not required unless they relate to a regulatory requirement or claim.
Environmental Labels:
Labels indicating eco-friendly or environmental attributes of the product are not required but can be used to convey sustainability information.
Non-GMO Labeling:
Non-GMO labeling is not universally required, but manufacturers often use it voluntarily to highlight that a product does not contain genetically modified organisms.
It’s important to remember that while these elements might not be required, they can still provide value to consumers and differentiate products in a competitive market. However, the priority should be providing accurate, truthful, and essential information that complies with your country or region’s relevant food labeling regulations. Always consult the rules established by your country’s regulatory authority to ensure your food labels comply.
Country-of-Origin Labeling and Its Nuances: The requirement to display a product’s origin hinges on jurisdiction. In the US, specific products like meat and fresh produce mandate this label. Meanwhile, the EU necessitates origin labeling for products such as fresh meat, fruits, and vegetables. While not universally obligatory, this label amplifies transparency regarding a product’s source. In Canada, country-of-origin labeling is not mandatory for all food products. However, certain foods, such as fish and seafood, fresh fruits and vegetables, and wine, must be labeled with their country of origin. The Safe Food for Canadians Regulations (SFCR) also outlines specific requirements for labeling and using origin-related terms.
Beyond Mandates: Non-Mandatory Label Elements: While some facets are obligatory, others—such as creative names, elaborate marketing language, and serving suggestions—are optional, enhancing the consumer experience. Retail prices, excessive graphics, cultural or ethical labels, and even environmental labels fall under the realm of non-mandatory elements.
Conclusion: A Holistic Outlook: The tapestry of food labeling regulations is a dynamic blend of requirements that serve to furnish consumers with precise information and nourish a transparent food industry. Abiding by these regulations, manufacturers ensure consumers are well-informed, safety is paramount, and trust in the market thrives. Understanding the shared principles and unique contours across regulatory bodies empowers both producers and consumers to navigate the intricate universe of food labels with confidence. As these labels persist as an emblem of transparency, accountability, and informed choice, they continue to uphold the essence of nourishing and safeguarding both individuals and the industry at large.
Del Health Canada is a crucial regulatory body responsible for ensuring the safety and effectiveness of drugs and medical devices in Canada. This organization plays a vital role in protecting the health and well-being of Canadians by setting standards, conducting research, and enforcing regulations. In this guide, we’ll explore the responsibilities and functions of Del Health Canada in more detail.
What is Del Health Canada?
Del Health Canada is a federal agency that operates under the umbrella of Health Canada. Its primary role is to regulate drugs and medical devices in Canada, ensuring they are safe, effective, and high-quality. Del Health Canada is responsible for reviewing and approving new drugs and medical devices before they can be sold in Canada and monitoring their safety and effectiveness once they are on the market. The agency also works to prevent and address potential risks associated with drugs and medical devices and takes action when necessary to protect the health and safety of Canadians.
What are DEL Health Canada’s responsibilities?
DEL Health Canada regulates drugs and medical devices in Canada, ensuring they are safe, effective, and high-quality. This includes reviewing and approving new drugs and medical devices before they can be sold in Canada and monitoring their safety and effectiveness once they are on the market. The agency also works to prevent and address potential risks associated with drugs and medical devices and takes action when necessary to protect the health and safety of Canadians. Also, DEL Health Canada is responsible for enforcing compliance with regulations and standards related to drugs and medical devices and providing information and guidance to healthcare professionals and the public.
How does the DEL ensure the safety and efficacy of drugs and medical devices?
DEL Health Canada uses a rigorous review process to ensure the safety and efficacy of drugs and medical devices. This process includes evaluating clinical trial data, assessing the benefits and risks of the product, and reviewing the manufacturing process to ensure quality and consistency. The agency also monitors the safety and effectiveness of drugs and medical devices once on the market and takes action if any safety concerns arise. Additionally, DEL Health Canada works closely with international regulatory agencies to share information and collaborate on regulatory issues.
What is the drug approval process in Canada?
The drug approval process in Canada is a rigorous and multi-step process overseen by DEL Health Canada. It involves several stages, including pre-clinical testing, clinical trials, and a review of the data by DEL Health Canada. The agency evaluates the safety and efficacy of the drug and its manufacturing process before approving it. Once a drug is approved, DEL Health Canada continues to monitor its safety and effectiveness through post-market surveillance. This process ensures that Canadians have access to safe and effective medicines.
How can Canadian consumers access information about approved drugs and medical devices?
Canadian consumers can access approved drug and medical device information through the DEL Health Canada website. The website provides a searchable database of approved drugs and medical devices and information on drug recalls and safety alerts. Consumers can also report adverse reactions to medications or medical devices through the website. Additionally, healthcare professionals can access information on drug interactions, dosing, and prescribing through the website. Overall, the DEL Health Canada website is a valuable resource for Canadians seeking information on the safety and efficacy of drugs and medical devices.
In Canada, controlled substances are classified under the Controlled Drugs and Substances Act (CDSA). The CDSA categorizes controlled substances into various schedules, each with its regulations and restrictions that we’ll discuss in this blog.
What is a controlled substance in Canada?
Schedule I: Substances listed in Schedule I are considered the most tightly regulated and have a high potential for abuse. They are often prohibited for general use and may only be used for specific medical or scientific purposes. Examples of substances in Schedule I include heroin, cocaine, and LSD.
Schedule II: Substances listed in Schedule II have a high potential for abuse but may also have recognized medical uses. They are subject to strict controls, and their production, distribution, and service are tightly regulated. Examples of substances in Schedule II include cannabis, methamphetamine, and certain opioids.
Schedule III: Substances listed in Schedule III have a lower potential for abuse and may have recognized medical uses. They are subject to fewer restrictions compared to Schedule I and II substances. Examples of substances in Schedule III include certain anabolic steroids and some prescription drugs.
Schedule IV: Substances listed in Schedule IV have a lower potential for abuse than those in previous schedules and are often prescription medications. They are subject to less stringent controls. Examples of substances in Schedule IV include benzodiazepines and certain sedatives.
Schedule V: Substances listed in Schedule V have the lowest potential for abuse and are generally available over the counter or with a prescription. They are subject to minimal controls. Examples of substances in Schedule V include certain cough preparations containing small amounts of codeine.
It’s important to understand that the classification of substances into these schedules can change based on new research, evidence, and evolving public health concerns. Health Canada oversees the regulation and enforcement of controlled substances in Canada to ensure they are used safely and appropriately.
Suppose you have questions about a particular substance, its classification, legal status, or related regulations. In that case, I recommend referring to Health Canada’s official resources or consulting with our regulatory experts knowledgeable about Canadian drug regulations.
How does Health Canada regulate controlled substances?
Health Canada regulates controlled substances in Canada through the Controlled Drugs and Substances Act (CDSA) and its associated regulations. The CDSA is the primary legislation that governs the legal framework for controlling and regulating drugs and substances with the potential for abuse, dependence, and harm to public health and safety.
Here’s an overview of how controlled Health Canada regulates substances:
1. Classification and Scheduling: Health Canada categorizes controlled substances into different schedules (I to V) based on their potential for abuse, medical use, and overall risk. The schedules determine the level of control, restrictions, and regulations that apply to each substance. Substances with a higher potential for abuse and harm are placed in higher schedules with stricter rules.
2. Licensing and Permits: Manufacturers, distributors, healthcare professionals, researchers, and other entities involved with controlled substances must obtain appropriate licenses, permits, or authorizations from Health Canada to handle, produce, distribute, prescribe, or research these substances. These licenses outline the specific permitted activities and the conditions that must be met.
3. Production and Distribution: Health Canada regulates controlled substances’ production, distribution, and import/export. Manufacturers and distributors of controlled substances must adhere to strict quality standards, record-keeping, and reporting requirements. They must also follow Good Manufacturing Practices (GMP) to produce controlled substances.
4. Prescription and Dispensing: Certain controlled substances are available only by prescription from authorized healthcare professionals. Prescribing, dispensing, and administering controlled substances must comply with specific regulations and guidelines to ensure patient safety and prevent misuse.
5. Monitoring and Reporting: Health Canada oversees the monitoring of controlled substances through various mechanisms, including collecting data on production, distribution, prescriptions, and adverse reactions. Manufacturers, distributors, healthcare professionals, and researchers must report certain activities and events related to controlled substances.
6. Inspections and Enforcement: Health Canada conducts inspections of facilities involved with controlled substances to ensure compliance with regulations, including Good Manufacturing Practices (GMP) and Good Distribution Practices (GDP). Non-compliance can result in enforcement actions, such as license suspension, revocation, or legal penalties.
7. Research and Clinical Trials: Researchers conducting studies involving controlled substances must obtain specific authorizations from Health Canada. These authorizations ensure the research is conducted ethically, safely, and in compliance with regulations.
8. Education and Public Awareness: Health Canada provides educational resources and information to healthcare professionals, patients, and the public about the risks, safe use, and regulations related to controlled substances. Public awareness campaigns help promote responsible use and prevent misuse.
It’s important to note that controlled substance regulations are subject to change. Health Canada may update or amend the rules based on new research, emerging trends, and public health considerations.
Other Frequently Asked Questions about Controlled Substances in Canada
1. What are controlled substances in Canada?
Controlled substances are drugs and substances regulated under the Controlled Drugs and Substances Act (CDSA). They include narcotics, controlled drugs, and precursor chemicals used to produce controlled substances.
2. Who regulates controlled substances in Canada?
The regulation of controlled substances in Canada falls under the jurisdiction of Health Canada and the Controlled Drugs and Substances Act (CDSA).
3. What is the purpose of regulating controlled substances in Canada?
The primary purpose is to ensure public safety and health by controlling the production, distribution, and use of substances with potential abuse and harm.
4. How are controlled substances classified in Canada?
Controlled substances are classified into schedules (Schedules I to IV) based on their potential for abuse, medical use, and safety. Schedule I substances are considered the most dangerous. In contrast, Schedule IV substances have the lowest potential for abuse.
5. What licenses or permits are required to handle controlled substances in Canada?
Depending on the activities involving controlled substances, individuals and organizations may require licenses, permits, or exemptions from Health Canada. These include charges for production, distribution, importation, and research.
6. How can I apply for a license to handle controlled substances in Canada?
The application process for controlled substance licenses involves submitting a detailed application to Health Canada, demonstrating compliance with regulatory requirements, security measures, and record-keeping protocols.
7. What security measures are required for handling controlled substances in Canada?
Security measures include physical security (e.g., secure storage), personnel security (background checks), and operational security (protocols to prevent theft or diversion).
8. Are there specific record-keeping requirements for controlled substances in Canada?
Individuals and organizations handling controlled substances must maintain detailed records of activities, including acquisitions, disposals, and inventories, as Health Canada outlines.
9. Can healthcare professionals prescribe controlled substances in Canada?
Healthcare professionals, such as physicians and dentists, can prescribe controlled substances in Canada. Still, they must follow strict guidelines and maintain accurate records.
10. What are the penalties for unauthorized possession or trafficking of controlled substances in Canada?
Penalties for unauthorized possession or trafficking of controlled substances can be severe, including fines, imprisonment, and criminal charges.
11. Can controlled substances be imported or exported in Canada
Controlled substances can be imported or exported for legitimate purposes. Still, individuals or organizations must have the appropriate licenses and permits from Health Canada.
12. Where can I find comprehensive guidance on regulatory compliance for controlled substances in Canada?
Health Canada provides comprehensive guidance documents and resources on regulating controlled substances in Canada. Additionally, legal and regulatory experts can offer guidance and support for compliance.
The Canadian Food Inspection Agency (CFIA) has regulated food products for many years, with a particular focus on the safety of Canadians. This includes ensuring products are packaged, labeled, and advertised by government regulations and guidelines that set standards to protect the health and safety of consumers.
In response to an increasing number of consumer inquiries, the Canadian Food Inspection Agency (CFIA) would like to inform Canadians about regulatory responsibilities concerning caffeinated alcoholic beverages. in this news article, we’ll review the CFIA recall warnings, the impact of this news on vulnerable populations, CFIA inspection activities, and how our Supplemented Foods service can help you.
CFIA recall warnings:
Several brands of caffeinated energy drinks have received recall alerts from the Canadian Food Inspection Agency (CFIA). We know that many importers, merchants, and internet vendors are offering customers caffeinated energy drinks (CEDs) that must comply. This serves as a reminder that it is your responsibility to ensure that the CEDs you produce, import, or distribute comply with Canadian regulations, including the need that they do not contain more than 180 mg of caffeine per single-serving container, and display the necessary warnings required for Supplemented Foods.. Supplemented Foods (SFs) are prepackaged foods with 1 or more supplemental ingredients. Supplemental ingredients include things such as vitamins, minerals, amino acids, or caffeine.
Impact on vulnerable populations:
Drinking CED products may negatively impact vulnerable groups, including children, women who are breastfeeding or pregnant, and adults who are caffeine sensitive. Negative health impacts are also anticipated if other people consume these goods excessively. These groups rely on and have faith in the industry not to offer them goods that do not adhere to Canadian food safety regulations. If you market a product that falls short of these requirements, it may be ingested by a vulnerable consumer and cause harm to them.
CFIA inspection activities to locate non-compliance:
The CFIA is conducting inspections to determine who needs to comply. The CFIA may take legal action when non-compliance is discovered, including product seizure and detention, license suspension, administrative fines, or criminal prosecution.
License holders under the Safe Food for Canadians Regulations will still be obligated to inform the CFIA if their food threatens human health.
If you import CEDs:
Ensure you meet the requirements set out in your Temporary Marketing Authorization Letter (TMAL) from Health Canada or under the newly implemented Supplemented Foods Regulations
Ensure your products meet the needs of the regulations at the time of import If you distribute CEDs :
Ensure your product meets the requirements before distributing further.
How can our Supplemented Foods Service help you?
Quality Smart Solutions can help ensure your Supplemented Food products, including CEDs, comply with the newly implemented Supplemented Food Regulations. We will review your product formulation to check that caffeine levels are below the 180 mg limit (if applicable) and that the rest of the formulation complies with Health Canada’s list of permitted supplemented food categories as well as the list of permitted supplemental ingredients. After tailoring your formulation to meet the regulations, we can help bring your product label into compliance by making sure all the required labeling elements are present, including the supplemented food caution identifier and high caffeine content declaration. Quality Smart Solutions has recently helped several brands bring their energy drinks into compliance! Reach out to us today.
HelpfulInformation
To assist the industry in the interpretation of the SFs requirements and to ensure their SFs are compliant, the following resources are available:
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.
Quality Management Systems (QMS) are an essential part of the life sciences healthcare industry, and many people need clarification on what a Quality Assurance person is. The FDA and ISO 9000 mandate quality processes, including quality assurance (QA) and quality control (QC) in medical devices, pharmaceuticals, and other sectors. They are crucial to regulated businesses since they guarantee the quality and efficacy of their goods.
Although quality assurance and quality control are two distinct activities that coincide, they are frequently used interchangeably. Each has a unique role to play in life sciences organizations that is essential for efficient quality control. Your organization can master each function by clearly understanding it and producing the finest goods possible.
In our blog, we’ll cover everything you should know about quality assurance (QA) and quality control (QC) in terms of their impact on Quality Management Systems, starting with what they are: For adverse reaction reporting assistance or non-conformance reports ask us.
Quality Assurance (QA) Definition: Prevention by having rules, principles, and guidelines in place
Quality assurance (QA) refers to a systematic process or set of activities and practices to ensure that products, services, or processes consistently meet or exceed established standards, specifications, and customer expectations. The primary goal of quality assurance is to prevent defects, errors, or issues from occurring and to ensure that a high level of quality is consistently maintained throughout the entire lifecycle of a product or service.
Quality Control (QC) Definition: Reacting to errors in products
Quality control (QC) refers to systematically monitoring, testing, and inspecting products, services, or processes to ensure they meet or exceed established quality standards, specifications, and requirements. The primary goal of quality control is to identify and correct any defects, errors, or deviations from the desired level of quality before the final product or service is delivered to customers or users.
What is a Quality Management System (QMS)?
A Quality Management System (QMS) is a structured and systematic framework that an organization establishes and implements to manage and ensure the quality of its products, services, processes, and operations. The primary goal of a QMS is to achieve consistent quality, meet customer requirements, and continuously improve the organization’s overall performance.
Key components and principles of a Quality Management System include:
Documentation and Procedures: QMS involves creating and maintaining comprehensive documentation that outlines standardized processes, procedures, work instructions, and guidelines. This documentation provides a clear roadmap for performing tasks to ensure consistency and quality.
Quality Policies and Objectives: Organizations establish quality policies that reflect their commitment to delivering high-quality products and services. Quality objectives are set to align with these policies and provide measurable targets for improvement.
Process Management: QMS focuses on the management and optimization of processes throughout the entire product lifecycle, from design and development to production, distribution, and customer support.
Risk Management: Identifying and assessing potential risks affecting product quality or customer satisfaction is essential to QMS. Strategies are developed to mitigate these risks.
Customer Focus: QMS strongly emphasizes understanding customer needs and expectations. By consistently meeting customer requirements, organizations can enhance customer satisfaction and loyalty.
Continuous Improvement: A core principle of QMS is continuous improvement. Organizations monitor performance, collect data, analyze trends, and implement changes to enhance processes and outcomes.
Measurement and Analysis: QMS involves collecting and analyzing data related to quality indicators, process performance, customer feedback, and other relevant metrics. This data-driven approach helps in making informed decisions and identifying areas for improvement.
Employee Involvement and Training: Engaged and well-trained employees are essential to successful QMS implementation. Training programs are developed to ensure employees understand their roles and responsibilities in maintaining quality.
Supplier and Partner Relationships: QMS extends to managing relationships with suppliers and partners. Effective communication and collaboration with external stakeholders contribute to the overall quality of products and services.
Audit and Compliance: Regular internal audits and assessments ensure that processes adhere to established standards and regulations. External audits may also be performed to ensure compliance with industry-specific requirements.
Certification and Recognition: Organizations can seek certification to internationally recognized QMS standards such as ISO 9001. Certification demonstrates a commitment to quality and can enhance credibility with customers and stakeholders.
A well-implemented Quality Management System helps organizations streamline operations, minimize defects, reduce waste, enhance customer satisfaction, and improve overall business performance. It is applicable across various industries and sectors, including manufacturing, healthcare, services, software development, and more.
What is the role of Quality Assurance and Quality Control within your quality management system (QMS)?
Quality Assurance (QA) and Quality Control (QC) play distinct but interconnected roles within a Quality Management System (QMS). They ensure that an organization’s products, services, and processes meet established quality standards, customer requirements, and regulatory compliance. Click here for the key similarities and differences between QA and QC by Cannabis License Experts. Let’s explore the roles of QA and QC within a QMS:
Quality Assurance (QA):
Process Management: QA focuses on establishing and maintaining standardized processes, procedures, and workflows throughout the organization. It involves developing a systematic task performance approach to ensure consistency and reliability.
Preventive Measures: QA is primarily concerned with preventing defects and issues from occurring in the first place. It involves identifying potential risks, vulnerabilities, and areas of improvement within processes and taking proactive measures to mitigate these risks.
Documentation and Policies: QA includes creating and maintaining detailed documentation that outlines quality policies, objectives, and guidelines for various processes. These documents serve as a reference for employees to ensure that tasks are performed consistently and under established standards.
Continuous Improvement: QA encourages a culture of continuous improvement by monitoring processes, analyzing data, and identifying opportunities for enhancement. QA teams work to optimize processes to achieve better outcomes and increased efficiency.
Training and Education: QA ensures employees are adequately trained and equipped to follow established processes and best practices. Regular training programs help maintain a skilled and knowledgeable workforce, contributing to quality.
Quality Control (QC):
Inspection and Testing: QC involves the systematic assessment, testing, and evaluation of products, services, and processes to identify defects, errors, or deviations from established standards. It is a reactive approach aimed at detecting and addressing issues after they occur.
Conformance Checking: QC ensures that products and services meet the specified requirements and standards. It involves comparing actual results against predetermined criteria and taking corrective action if discrepancies are found.
Data Collection and Analysis: QC relies on data collection and analysis to measure product and process performance. Statistical techniques are often used to assess variations and determine if the quality of products or services is within acceptable limits.
Sampling: QC often involves selecting a representative sample of products or components for inspection and testing. The results obtained from the selection provide insights into the overall quality of the entire batch.
Immediate Corrections: If defects or issues are identified during QC activities, quick corrective actions are taken to rectify the problems before products are released to customers.
In summary, QA focuses on establishing processes and practices that prevent quality issues from arising. At the same time, QC involves the active monitoring, testing, and inspection of products and services to identify and correct problems that have occurred. QA and QC are vital components of a comprehensive QMS, working together to ensure consistent quality, customer satisfaction, and continuous organizational improvement.
How do you determine if you have a great quality management system?
A superb Quality Management System (QMS) is characterized by its ability to consistently deliver high-quality products, services, and processes that meet or exceed customer expectations. While there isn’t a one-size-fits-all checklist to determine the quality of a QMS, several key elements and indicators can help you assess the effectiveness of your QMS. Here’s a list to consider:
1. Clearly Defined Quality Policies and Objectives:
Are your organization’s quality policies and objectives documented and communicated to all employees?
Do these policies align with your organization’s overall mission and customer expectations?
2. Comprehensive Documentation:
Do you have well-documented processes, procedures, work instructions, and guidelines that guide employees in performing their tasks consistently?
Is documentation easily accessible to employees who need it?
3. Risk Management:
Have potential risks impacting product quality, safety, or customer satisfaction been identified and assessed?
Are risk mitigation strategies in place to address identified risks?
4. Customer Focus:
Is your organization actively gathering and incorporating customer feedback and requirements into your processes and products?
Are you consistently meeting customer expectations and addressing any issues promptly?
5. Process Management:
Are your processes standardized and well-defined to ensure consistency and repeatability?
Do you regularly monitor and measure process performance to identify areas for improvement?
6. Continuous Improvement:
Is there a culture of continuous improvement within your organization?
Are you actively collecting and analyzing data to identify trends and opportunities for enhancement?
7. Training and Competence:
Do you have a structured training program to ensure that employees are knowledgeable and skilled in their roles?
Are employees empowered to take ownership of quality and contribute to improvement initiatives?
8. Quality Control:
Have you established quality control measures to identify and correct defects or issues, including inspection, testing, and monitoring?
Is the frequency and scope of quality control activities appropriate for your products and processes?
9. Root Cause Analysis and Corrective Actions:
Are processes in place to identify the root causes of defects or non-conformities?
Are corrective actions taken to prevent the recurrence of issues and improve operations?
10. Supplier and Partner Relationships:
Do you collaborate closely with suppliers and partners to ensure their products or services meet your quality requirements?
Are supplier audits conducted to ensure their adherence to quality standards?
11. Metrics and Performance Indicators:
Are you using key performance indicators (KPIs) to measure the effectiveness of your QMS and overall quality performance?
Do you regularly review these metrics and take action based on the insights gained?
12. External Certification and Recognition:
Have you sought external certification for your QMS, such as ISO 9001?
Have you received positive feedback or recognition from customers, regulatory bodies, or industry peers?
13. Regulatory Compliance:
Are you consistently meeting regulatory requirements and industry standards that pertain to your products or services?
Remember that the effectiveness of a QMS can vary based on the unique characteristics of your organization, industry, and products. Regular audits, assessments, and feedback from employees, customers, and stakeholders can provide valuable insights into the strengths and areas for improvement within your QMS.
Are you ready to take your business to new heights? Look no further. In this comprehensive guide, we will unlock the potential of GRAS applications to help you achieve peak efficiency and success. Whether you’re a small startup or an established enterprise, understanding the power of GRAS (Generally Recognized as Safe) applications is essential for reaching your business goals.
GRAS applications encompass various industries, from food and beverages to pharmaceuticals and cosmetics. By incorporating GRAS ingredients into your products, you can ensure consumer safety and gain a competitive edge in the market. This guide will provide a step-by-step approach to implementing GRAS applications, starting with a detailed overview of what GRAS means and how it is regulated. We’ll then dive into the different industries where GRAS applications are prevalent, exploring the benefits and challenges within each sector.
Understanding the importance of GRAS in various industries
GRAS applications encompass various industries, from food and beverages to pharmaceuticals and cosmetics. By incorporating GRAS ingredients into your products, you can ensure consumer safety and gain a competitive edge in the market. GRAS is crucial as it provides businesses with a framework to determine the ingredients’ safety in various applications. It allows manufacturers to use certain substances without seeking pre-market approval from regulatory bodies, saving time and resources.
In the food and beverage industry, GRAS applications are particularly significant. They ensure that the ingredients used in food products are safe for consumption and do not pose any health risks to consumers. By incorporating GRAS ingredients, food manufacturers can enhance their product offerings and meet the growing demand for safe and healthy food options. Furthermore, GRAS applications in the pharmaceutical, cosmetic, and personal care industries are equally important, as they ensure the safety and efficacy of products used by consumers.
The regulatory landscape for GRAS applications
To fully leverage the potential of GRAS applications, it is crucial to understand the regulatory landscape surrounding them. The United States Food and Drug Administration (FDA) is vital in regulating GRAS applications.
The FDA has established a rigorous process for determining the safety of GRAS ingredients, which involves evaluating scientific evidence and expert opinions. This process ensures that GRAS applications meet the highest security and quality standards. For businesses looking to incorporate GRAS ingredients into their products, navigating the regulatory requirements effectively is essential. Compliance with FDA regulations is crucial to avoid legal issues and maintain consumer trust. Working with regulatory experts and conducting thorough research can help businesses ensure that their GRAS applications are in full compliance with the FDA’s guidelines.
Typical GRAS applications in the food and beverage industry
The food and beverage industry is a prime example of the widespread use of GRAS applications. Many commonly consumed food products contain GRAS ingredients deemed safe for consumption by regulatory authorities. Some examples of GRAS applications in the food industry include natural sweeteners like stevia, preservatives like citric acid, and food colorings like beta-carotene.
GRAS applications in the food and beverage industry offer numerous benefits. Firstly, it allows manufacturers to create products that meet consumer demands for healthier and more natural options. Secondly, GRAS applications provide a level of assurance to consumers, assuring them that the products they consume have undergone rigorous safety evaluations. Finally, incorporating GRAS ingredients can enhance food and beverage products’ flavor, texture, and overall quality.
GRAS applications in the pharmaceutical and healthcare industry
GRAS applications are critical in ensuring the safety and efficacy of medications and healthcare products in the pharmaceutical and healthcare industries. Many active pharmaceutical ingredients (APIs) used in remedies are classified as GRAS, reassuring healthcare professionals and patients. This classification allows pharmaceutical companies to focus on the development and production of medications without the need for extensive safety testing.
The use of GRAS applications in the pharmaceutical industry offers several advantages. Firstly, it streamlines the drug development process, allowing for faster and more cost-effective production of medications. Secondly, it ensures that healthcare products are safe for consumption and do not pose unnecessary patient risks. Finally, GRAS applications in the pharmaceutical industry foster innovation, as researchers can focus on developing new treatments and therapies rather than repeating safety evaluations for existing ingredients.
GRAS applications in the cosmetics and personal care industry
The cosmetics and personal care industry heavily relies on GRAS applications to ensure the safety and effectiveness of their products. Many ingredients used in cosmetics and unique care products, such as moisturizers, shampoos, and makeup, are classified as GRAS. This classification gives manufacturers the confidence to use these ingredients in their formulations without compromising consumer safety. The use of GRAS applications in the cosmetics and personal care industry has several benefits.
Firstly, it allows manufacturers to create safe skin, hair, and body products. This reassures consumers that their products will not cause harm or adverse reactions. Secondly, GRAS applications in this industry enable the development of innovative and effective products that cater to various consumer needs and preferences. Lastly, incorporating GRAS ingredients can enhance the overall quality and performance of cosmetics and personal care products.
GRAS applications in the agricultural and farming industry
The agricultural and farming industries also benefit from GRAS applications, particularly crop protection and enhancement. Many substances used in agriculture, such as biopesticides and growth enhancers, are classified as GRAS. This classification ensures that these substances do not harm human health or the environment while helping farmers improve crop yields and protect their harvests.
GRAS applications in the agricultural industry offer several advantages. Firstly, they provide farmers with effective and environmentally friendly alternatives to traditional pesticides and fertilizers. This promotes sustainable farming practices and reduces the potential negative impact on ecosystems. Secondly, GRAS applications help farmers meet consumer demands for organic and pesticide-free produce, enhancing market competitiveness. Lastly, they contribute to agricultural products’ safety and quality, ensuring consumers enjoy safe and nutritious food.
Case studies of successful GRAS applications
To further understand the potential of GRAS applications, let’s explore some case studies of successful implementation. One notable example is the use of GRAS ingredients in plant-based meat alternatives. Companies like Beyond Meat and Impossible Foods have successfully developed meat substitutes that taste delicious and provide a safe and sustainable protein source. By using GRAS ingredients, these companies have gained widespread consumer acceptance and disrupted the traditional meat industry.
Another case study is the use of GRAS applications in skincare products. Brands like The Ordinary and Drunk Elephant have created highly effective, popular skincare formulations using GRAS ingredients. These products have garnered a loyal following due to their safety, affordability, and visible results. By leveraging GRAS applications, these brands have revolutionized the skincare industry and set new standards for quality and transparency.
Challenges and considerations in implementing GRAS applications
While the potential of GRAS applications is vast, there are challenges and considerations that businesses must be aware of when implementing them. Firstly, staying up-to-date with regulatory changes and ensuring compliance with evolving guidelines is crucial. The FDA regularly updates its regulations, and businesses must adapt their practices to maintain GRAS status.
Secondly, businesses must invest in research and development to ensure the safety and efficacy of their GRAS applications. Thorough testing and evaluation are necessary to provide scientific evidence supporting the protection of GRAS ingredients. This requires resources and expertise to conduct comprehensive studies and gather relevant data.
Lastly, businesses must effectively communicate the benefits and safety of their GRAS applications to consumers. Transparency and education are vital in building consumer trust and confidence in these products. Clear labeling and marketing efforts that emphasize the safety and quality of GRAS ingredients can help businesses overcome potential skepticism and gain consumer acceptance.
Best practices for maximizing the efficiency and success of GRAS applications
To maximize the efficiency and success of GRAS applications, businesses should follow certain best practices. Firstly, it is crucial to establish strong relationships with regulatory experts who can provide guidance and support in navigating the regulatory landscape. These experts can help businesses understand the requirements and ensure compliance with relevant regulations.
Secondly, investing in research and development is vital to developing innovative GRAS applications. By staying at the forefront of scientific advancements and conducting thorough testing, businesses can create products that meet consumer demands and provide a competitive edge.
Additionally, businesses should prioritize transparency and communication with consumers. Clearly labeling products and providing accurate information about the safety and benefits of GRAS ingredients can build trust and credibility with consumers. Engaging in educational initiatives and sharing scientific research can enhance consumer confidence in GRAS applications.
Resources and tools for navigating GRAS applications
Navigating the world of GRAS applications can be complex, but resources and tools are available to assist businesses. The FDA website provides detailed information on GRAS regulations, guidelines, and the submission process. It is a valuable resource for companies looking to understand the requirements and stay updated on regulatory changes.
Working with regulatory consultants and industry associations can also provide businesses with expert guidance and support. These professionals have in-depth knowledge of GRAS applications and can help enterprises to navigate the regulatory landscape effectively.
Conclusion:
In conclusion, GRAS applications allow businesses to unlock their full potential and achieve peak efficiency and success. By incorporating GRAS ingredients into products, companies can ensure consumer safety, gain a competitive edge, and meet the growing demand for safe and healthy options. Understanding the regulatory landscape, exploring typical applications in various industries, and implementing best practices are crucial for maximizing the benefits of GRAS applications. With the right approach and resources, businesses can harness the power of GRAS and propel themselves forward in their respective industries. Unlock the potential of GRAS applications and unlock a world of possibilities for your business.
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!
Health Canada publishes product monographs to describe a product’s health risks, benefits, and performance. Product monographs are for health products licensed by Health Canada and those approved by the Natural Health Products Directorate (NHPD). A product may appear on the market without a product monograph being written. A manufacturer is responsible for ensuring that the information provided on labels and in marketing submissions is accurate.
They contain comprehensive safety, efficacy, and quality information on human health products sold in Canada. They include information on how the products should be used and stored, a description of the ingredients, and how they were manufactured. This blog answers the what, why, when, who, and more questions about Health Canada product monographs.
What is a product monograph?
Health Canada product monographs are essential documents that provide comprehensive and detailed information about regulated health products, including prescription drugs, over-the-counter medications, natural health products, and medical devices.
What is commonly found in a product monograph?
Here are the key components typically found in a product monograph:
Product Identification: This section includes the brand, generic, and other product trade names. It may also include information about the dosage form, strength, and route of administration.
Indications and Clinical Use: This section outlines the approved therapeutic uses for the product, including specific medical conditions it is intended to treat or prevent.
Dosage and Administration: Information about the recommended dosing regimen, including instructions for how the product should be taken, administered, or applied. This section may include details about dosing adjustments for different patient populations (e.g., children, elderly patients).
Contraindications: A list of circumstances or medical conditions under which the product should not be used due to potential risks or adverse effects.
Warnings and Precautions: Important safety information, including potential risks, interactions with other substances, and specific precautions to take when using the product.
Adverse Reactions: A comprehensive list of known side effects and adverse reactions associated with the product, along with their frequencies and severity.
Clinical Pharmacology: Information about how the product works in the body, including its mechanism of action, pharmacokinetics (absorption, distribution, metabolism, and excretion), and pharmacodynamics (effects on the body).
Nonclinical Toxicology: Data from preclinical studies provide insights into the product’s potential toxicity and safety profile.
Clinical Studies: Summaries of vital clinical trials and studies conducted to demonstrate the product’s safety and efficacy. This may include information on patient populations, study designs, endpoints, and results.
Storage and Handling: Instructions for proper storage conditions to ensure the product’s stability and effectiveness.
Date of Revision: The date on which the monograph was last updated or revised.
How Supplied: Details about packaging, available sizes, and any additional materials or accessories that come with the product.
What is the role of these product monographs?
Product monographs are critical in ensuring healthcare professionals and consumers access accurate, evidence-based information about health products. They help guide these products to safe and effective use, facilitate informed decision-making, and contribute to patient safety.
These monographs serve as a valuable resource for healthcare professionals, regulators, and the general public to understand a specific health product’s characteristics, indications, contraindications, dosing, safety, and efficacy.
What you should know about Health Canada product monographs:
Purpose and Content: Product monographs are created by the health product manufacturer and reviewed and approved by Health Canada. They contain essential information about the product, including its active ingredients, therapeutic indications, recommended dosage, administration guidelines, contraindications, warnings, precautions, adverse reactions, and clinical trial data.
Regulatory Approval: Health Canada reviews and evaluates the information provided in the product monograph to ensure that the health product is safe, effective, and of high quality before it can be authorized for sale in Canada.
Accessibility: Product monographs are typically available to the public on Health Canada’s Drug Product Database (DPD) or Natural Health Products Database (NHPD) websites. Healthcare professionals and consumers can access these monographs to make informed decisions about using health products.
Updates and Revisions: Health Canada requires manufacturers to keep their product monographs updated with new information, including any changes to indications, dosing, safety information, or manufacturing processes. This helps ensure the most current and accurate information is available to healthcare professionals and patients.
Comparison to Other Countries: Health Canada product monographs may be similar in purpose and content to documents like the United States FDA-approved product labeling (package inserts) and the European Summary of Product Characteristics (SmPC). However, specific requirements and formats may vary among different regulatory agencies.
Patient Information: Some product monographs also include patient-friendly sections that provide essential information about the health product in language that is easy to understand. This helps patients make informed decisions about their treatment.
Off-Label Use: While product monographs provide information about authorized uses of a health product, healthcare professionals sometimes prescribe medications for off-label uses that are not explicitly listed in the monograph. This practice is based on their clinical judgment and the available evidence.
Importance for Healthcare Professionals: Healthcare professionals, including doctors, pharmacists, and nurses, rely on product monographs to make informed decisions about prescribing, dispensing, and administering health products. They use this information to ensure patient safety and optimal therapeutic outcomes.
When using Health Canada product monographs, it’s essential to refer to the most current version available on official government websites and to consider the specific context and patient needs. These monographs are crucial tools for promoting safe and effective healthcare practices.
How can I check for Health Canada monograph updates?
To check for updates to Health Canada product monographs, you can follow these steps:
Health Canada’s Drug Product Database (DPD):
The Drug Product Database (DPD) is a comprehensive source of information about approved drugs in Canada. It provides access to product monographs, including updates and revisions. Here’s how you can use the DPD to check for updates:
a. Visit the Health Canada Drug Product Database website:
b. Use the search function to find your desired drug or product. You can search by brand name, generic name, or active ingredient.
c. Once the product is located, click on its name to access the detailed product monograph.
d. Look for the “Date of Revision” or a similar section in the monograph. This information indicates when the monograph was last updated.
Health Canada’s Natural Health Products Database (NHPD):
For natural health products, you can use the Natural Health Products Database (NHPD) to check for updates to product monographs:
a. Visit the Health Canada Natural Health Products Database website:
b. Use the search function to find the specific natural health product you want.
c. Once the product is located, click on its name to access the detailed product monograph.
d. Look for the “Date of Revision” or a similar section in the monograph to determine the latest update.
Subscriptions and Notifications:
Health Canada may offer subscription or notification services that allow you to receive updates when product monographs are revised or new information is added. These services can help you stay informed about changes without actively checking the databases.
a. Check the Health Canada website or contact Health Canada’s regulatory information service for subscription or notification options.
It’s important to note that product monographs are regularly updated as new information becomes available, such as changes in dosing recommendations, safety warnings, or indications. Keeping track of these updates is crucial for healthcare professionals, patients, and consumers to ensure health products’ safe and effective use. Always refer to official Health Canada sources for the most accurate and up-to-date information.
How do I use the Health Canada product Monograph database?
To use the Health Canada Product Monograph Database, which includes both the Drug Product Database (DPD) and the Natural Health Products Database (NHPD), follow these steps:
Access the Database:
a. For drug products, visit the Drug Product Database (DPD) website:
b. For natural health products, visit the Natural Health Products Database (NHPD) website:
Search for a Product:
a. You’ll find a search bar on the DPD or NHPD homepage. Enter the name of the drug or natural health product you want to search for. You can search by brand name, generic name, active ingredient, or other relevant information.
b. Click on the “Search” button to initiate the search.
View Product Information:
a. Browse the search results to find the specific product you want.
b. Click on the product name to access its detailed product monograph.
Explore the Monograph:
a. The product monograph provides comprehensive information about the product, including its indications, dosing, contraindications, warnings, adverse reactions, and more.
b. Navigate through the monograph using the table of contents or scroll through the document to find the specific information you want.
c. Pay attention to important sections such as “Indications and Clinical Use,” “Dosage and Administration,” “Warnings and Precautions,” and “Adverse Reactions.”
Check for Updates:
a. Look for information about the “Date of Revision” or a similar section within the monograph. This will indicate when the monograph was last updated.
b. If you’re concerned about the currency of the information, you can contact Health Canada or refer to other reliable sources to verify any recent updates.
Print or Save the Monograph:
a. You can print or save the monograph for your reference. This can be useful for healthcare professionals and individuals who want to keep a record of the information.
Additional Features:
a. The databases may offer additional features, such as advanced search options, viewing product labels or packaging, and links to related resources.
Remember that the Health Canada Product Monograph Database is valuable for accessing accurate and up-to-date information about regulated health products. It’s crucial to rely on official sources like this database when making decisions about the use of health products. If you have questions or need further assistance, contact Health Canada’s regulatory information service for guidance.
Anyone looking to manufacture a Class II, III or IV medical device in Canada requires a Medical Device Licence (MDL) for each product they sell. In order to obtain an MDL you need an ISO 13485 certificate that has been issued through the Medical Device Single Audit Program (MDSAP). These certificates are evidence that your company has an appropriate quality management system in place to ensure that only safe and effective medical devices are made available for sale.
How do I obtain an MDSAP certificate?
First you must implement a quality management system within your company that meets the requirements of ISO 13485. The areas covered by these practices include design and development, production, storage and distribution, installation, and servicing of medical devices. Once all applicable procedures are in place you must contact an auditor that has been authorized to issue MDSAP certificates. Only certificates issued by approved auditors will be recognized by Health Canada.
Note that these certificates include a scope of the types of products that your company is authorized to manufacture. For example, if you obtain an MDSAP certificate for the manufacture of medical gloves you can get an MDL for medical gloves but not for home pregnancy tests. The scope of the certificate must match the type of product being sold. If you need to expand the scope of your certificate you must contact your auditor.
Why is it called a single audit program?
Historically every country would require their own audit of medical device manufacturer’s quality management system. This led to a situation where a company looking to sell in 5 different countries would often require 5 different audits of the quality management system. In order to reduce the burdens associated with multiple audits, several countries banded together to form the Medical Device Single Audit Program. Certificates issued through MDSAP will satisfy the audit requirements for all participating countries.
Countries that currently recognize MDSAP certificates include:
Australia
Brazil
Canada
Japan
USA
Are there any exemptions? What if I have an ISO 13485 certificate but it’s not MDSAP?
Health Canada won’t accept any other ISO 13485 certificate even if it’s from a major market such as the European Union. The only exception that has ever been granted is for devices related to the COVID-19 pandemic. Health Canada created a special approval pathway for these devices that would allow non-MDSAP certified companies to obtain authorization to sell their products.
I don’t have an MDSAP certificate and I’m not interested in obtaining one. What are my options?
The only option in this case is to enter into a private label agreement with a company that has one. The company you partner with must already have an MDSAP certificate and an MDL for the product they will be making. You will need to submit a Private Label Licence Application to Health Canada that states that your business partner will be conducting all manufacturing work and the product is identical to the already licenced product in every way except brand name and the company name listed on the label.
Health Canada has published a consultation paper on proposed changes to the regulation and oversight of clinical trials for drug, medical devices and natural health products (NHPs). The purpose of these changes is to improve the speed at which these trials are approved, to avoid stifling medical advances that could help improve the health of Canadians, and to improve transparency and regulatory oversight.
The proposed changes would integrate all health products into the same framework and feature:
Proportional risk-based oversight
New regulatory agilities over the lifecycle of the trial
Greater transparency through registration and public disclosure of results
A modernized compliance and enforcement regime (see figure 1)
Health Canada is accepting feedback on the proposed changes until 4 July 2021.
Agile Life Cycle
With the adoption of a more agile life cycle approach, Health Canada is looking to be able to give themselves the tools to oversee clinical trials in their entirety while better enabling sponsors to conduct innovative types of trials. As part of these changes, Health Canada will be able to authorize a trial rather than just the sale or importation of an investigational product, authorize a trial with multiple product types through a single authorization, and streamline the application requirements across all product lines for greater efficiency, while maintaining the protection of the health and safety of participants.
Under this scheme Health Canada will allow for the authorization of Master protocols that include multiple sub-studies for different therapies or indications for use. Types of proposed Master protocols include:
Basket trials, which investigate the safety/efficacy/effect of an investigational product across a variety of indications
Umbrella trials, which investigate the safety/efficacy/effects of several investigational products in a single indication
Platform trials, which investigate several investigational products in one or multiple indications in a highly dynamic design
By integrating all health products into a common framework, products from multiple categories can be approved under the same protocol. For medical devices this would result in an expansion of who can sponsor a clinical trial. It will now include independent investigators (such as a researcher, clinician or health care facility) in addition to the manufacturers and importers of medical devices. These changes will also result in any medical device trial being required to adhere to Good Clinical Practices (GCP).
Health Canada is also seeking to improve safety monitoring of clinical trials through improved clarity and increased authority to request information relating to adverse events including the ability to request an analysis of safety data while the trial is ongoing. This may include an assessment of safety signals to determine if the benefit/risk balance has changed during the conduct of the trial.
In this approach, Health Canada will have the ability to suspend or cancel either the whole trial or only a part of the trial if there’s a lack of efficacy or a safety concern.
Risk-Based Approach
All health products will follow a common risk-based approach to authorization. To do this they will create risk-based categories with differing levels of oversight and regulatory requirements for drugs and NHPs. The pre-existing risk-based device classification scheme for medical devices will be maintained and integrated into the new scheme. See figure below:
Source: www.canada.ca
Health Canada will be granted the authority to impose terms and conditions on a clinical trial authorization before and during the trial to address significant uncertainties or mitigate risks related to the product(s) being tested, or to the conduct of the trial. These terms and conditions may include:
More frequent safety reporting
Monitoring of specific populations because of potential increased risk (e.g. children, pregnancy)
Additional information to characterize and mitigate newly identified risks
To allow for greater trial participation from volunteers outside of major urban areas, changes will be made to allow for studies to take place remotely, without a physical visit to a trial site. Monitoring will be allowed using videoconferences with investigators, visits at home by study personnel, internet-based tools for data collection and reporting, and mobile technology such as biosensor devices.
Transparency
Health Canada is looking to expand on its current Clinical Trials Database and is exploring new ways to publish clinical trial information. This may include mandatory registration of any trial conducted in Canada on an existing international registry of Health Canada’s choosing. Sponsors may be required to make the results of their trials available to all members of the public by publishing the information in this database. Health Canada is also proposing making this information available on its website to ensure it’s easy to find and available in both official languages.
Modernization of Compliance and Enforcement
Although Health Canada already has the authority to conduct inspections on clinical trial activities under Section 23 of the Food and Drugs Act, its activities have been limited to drugs. As part of the modernization, Health Canada will extend its compliance and enforcement to NHPs and medical devices. Inspections will be conducted using a risk-based and pro-active approach based on trial design, the medical condition under study, target population, and the risk classification of the investigational product. Health Canada will also implement a cyclical risk-based inspection approach that considers the compliance history and the volume of activities. Highly compliant entities would be inspected less frequently while less compliant ones would be inspected more frequently.
At present Health Canada only has direct oversight over the sponsors of the trials. Health Canada is proposing regulatory changes that would ensure that all third parties conducting trials on behalf of a sponsor are legally responsible for any activities they conduct. This would result in an increased regulatory burden for these third parties but will increase the safety of clinical trial participants by allowing Health Canada to require them to take corrective action instead of directing the sponsor to take the action against the third party.
Anticipated Outcomes for Stakeholders
Health Canada believes these changes will help encourage clinical trials in Canada by providing greater agility in oversight of the development of healthcare products, ensuring that regulatory requirements are proportional to risks, improving access to clinical trial information, creating a more streamlined approach that is better aligned internationally and leverage partnerships and provide leadership in Canada’s health ecosystem to further facilitate clinical trials in Canada.
Cancellation of Medical Device Establishment Licence for A Non-compliance With Annual Licence Review Requirements
On May 27, 2021 Health Canada issued a bulletin about cancellation of Medical Device Establishment Licence (MDELs) for the sites that are not compliant with the annual licence review requirements. About 700 MDEL holders have not submitted an annual licence review application for the 2020/2021 fiscal year, and as a result Health Canada cancelled their MDELs. This means that these sites are not able to conduct their activities and must re-apply for a new establishment licence and pay the applicable fees.
Annual Licence Review
An annual licence review (ALR) ensures that medical device establishment licence (MDEL) holders are complying with regulatory requirements associated with the Medical Devices Regulations. An ALR also ensures that their licence information is up-to-date.
As a courtesy, Health Canada sends an ALR application package to all active MDEL holders at the end of each calendar year. Health Canada also sends out 2 reminder notices to the licence contact person on file.
MDEL Holder Responsibilities
To continue doing business, active MDEL holders must submit an ALR application before April 1 of each year as per section 46.1 of the Medical Devices Regulations. Licence holders with a suspended MDEL do not need to apply.
Health Canada will cancel the MDEL for those licence holders who do not submit their ALR application within the required timeline. This authority is set out in section 51.1(b).
Under section 48, active MDEL holders must also notify Health Canada within 15 calendar days if they change their contact information. This includes changing the name or address of their establishment or the information of the establishment representative associated with their MDEL.
Cancellation of MDELs
Since the ALR deadline of April 1, 2021, about 700 MDEL holders have not submitted an ALR application for the 2020/2021 fiscal year. As this violates section 46.1, Health Canada have cancelled their MDELs and removed them from the active MDEL live listing.
MDEL holders whose establishment licence is cancelled are no longer authorized to conduct licensable activities (such as manufacturing, distributing or importing medical devices). They must cease their activities immediately once they receive their cancellation notice.
Resuming Licensable Activities
To resume licensable activities, companies whose MDEL has been cancelled must re-apply for a new establishment licence and pay the applicable fees. In line with the compliance and enforcement policy for health products (POL-0001), Health Canada carries out compliance monitoring activities. Cancelled MDEL holders may be subject to compliance and enforcement actions if Health Canada finds they are conducting non-compliant activities.
For more information on how to re-apply for a MDEL or if you need assistance filling your ALR please visit our website. Our Experts at Quality Smart Solutions continue to support your needs for medical devices, natural health products, foods, cosmetics and OTC drugs for North America. Contact us today to learn more about how we can support your compliance for Medical Device Establishment licence.
References:
Cancellation of MDELs for non-compliance with annual licence review requirements – Health Canada.
As of March 1, 2021, Interim Order No. 2 replaces Interim Order No. 1 Respecting the importation and sale of medical devices for use in relation to COVID-19. Interm Order No. 2 will continue to issue expedited authorizations for the sale or import of medical devices to deal with the current significant risk of COVID-19 to the health and safety of Canadians.
The Interim Order provides an expedited authorization pathway for:
new COVID-19 medical devices that are not yet licensed in Canada,
COVID-19 related uses for existing devices licensed under the Medical Devices Regulations or Interim Order No. 2 and
COVID-19 medical devices that leverage an authorization of a device from a trusted foreign regulatory authority, whereby the Minister would maintain the ability to request additional information on a case-by-case basis.
Interim Order No. 2 introduces new requirements for importers and distributors of COVID-19 medical devices to hold an MDEL, and for manufacturers to comply with bilingual labelling requirements. Both of these changes align with requirements in the Medical Devices Regulations.
Authorization for importation or sale by the manufacturer
Interim Order No. 2 provides COVID-19 medical device manufacturers an exemption from certain requirements of the Medical Devices Regulations, provided they have received an authorization for the importation or sale of their device(s) from Health Canada.
A manufacturer may submit an application for authorization under Interim Order No. 2. If an authorization is granted, the manufacturer may import or sell the COVID-19 medical device for which they hold an IO authorization in Canada. The manufacturer’s information and device information on the device label can then be cross-referenced against the IO authorization during importation and distribution, which is required to accompany the product during import.
Fees related to the submission of an application for a COVID-19 medical device authorization
Health Canada will waive all application fees for COVID-19 medical device authorizations subject to Interim Order No. 2 Respecting the Importation and Sale of Medical Devices for Use in Relation to COVID-19.
Quality Management System requirements related to the submission of an application for a COVID-19 medical device
Health Canada does not require manufacturers to provide a Medical Device Single Audit Program (MDSAP) certificate with their application for a COVID-19 medical device subject to Interim Order No. 2. Manufacturers will be required to share information to demonstrate that their products are of consistent quality and effectiveness. This can be demonstrated by either providing a copy of the manufacturer’s Quality Management System certificate to ISO 13485:2016, or by submitting evidence of Good Manufacturing Practices and its proper implementation.
Documentation required for importation
Under Interim Order No. 2, each shipment of a COVID-19 medical device that is imported into Canada must be accompanied by a copy of the Interim Order authorization. This document will be issued to the applicant upon authorization and will facilitate transport of the COVID-19 medical device(s) across the border, as it will be used as a signal that the device has been authorized under the Interim Order. Importers should rely on this mechanism to demonstrate to Health Canada that a shipment containing COVID-19 medical devices should be allowed access into Canada. References to Interim Order No. 1 on the authorizations can be read to be references to Interim Order No. 2.
Incident reporting
Interim Order No. 2 requires that the holder of the COVID-19 medical device authorization for the importation or sale of the device report to Health Canada to comply with incident reporting requirements.
Importers and distributors also must comply with mandatory reporting as outlined in the Medical Devices Regulations. Importers and distributors should also note that new regulations on mandatory reporting under the Medical Devices Regulations will come into effect on June 23, 2021, at which point importers will be expected to comply with the new regulations.
Requirement for importers and distributors to hold a Medical Device Establishment Licence (MDEL)
Under Interim Order No. 1, importers and distributors were not required to hold an active Medical Device Establishment Licence (MDEL) to import or distribute COVID-19 medical devices authorized under the IO. To enable risk-based regulatory oversight on the medical device supply chain and facilitate complete and rapid recalls of problematic devices when necessary, Health Canada has added this requirement to Interim Order No. 2.
Requirement to hold an MDEL
Interim Order No. 2 requires importers and distributors of COVID-19 medical devices to hold an MDEL and comply with certain requirements set out in the Medical Devices Regulations.
COVID-19 medical device importers and distributors:
have six months from the date that Interim Order No. 2 takes effect to obtain an MDEL and comply with relevant parts of the Medical Devices Regulations as defined in section 2(2)(a) of the Order (by September 1, 2021)
must submit applications for an MDEL within sufficient time to accommodate the service standard of 120 calendar days
are required to pay application fees, as well as annual fees, for as long as they hold an MDEL
MDEL holders are subject to other regulatory requirements, including record-keeping, reporting and inspections. Health Canada inspectors verify that the MDEL holder has the ability to conduct rapid, effective recalls of problematic devices when necessary.
Consult the existing Guidance Document for Mandatory Problem Reporting for Medical Devices for information on how to comply with those sections. Importers and distributors should also note that new regulations on mandatory reporting under the Medical Devices Regulations will come into effect on June 23, 2021, at which point importers will be expected to comply with the new regulations.
MDEL fees
Importers and distributors of any medical devices (including COVID-19 medical devices) who are required to hold an MDEL, must pay the associated MDEL fee, and comply with requirements set out in the Medical Devices Regulations.
For more information pertaining to MDEL fees, please review the Fees for the Review of Medical Device Establishment Licence Applications at the official website of Health Canada.
Natural Health Products (NHPs) are regulated by Health Canada under the authority of the Food and Drugs Act and the Natural Health Products Regulations (NHPR) and must be licensed prior to marketing in Canada. Licensed NHPs are assigned an eight (8) digit Natural Product Number (NPN) or Homeopathic Medicine Number (DIN-HM). To be classified as an NHP, all of the medicinal ingredients in the product must be in Schedule 1 of the NHPR, not include any substances listed in Schedule 2 of the NHPR and be marketed for health reasons.
NHPs include traditional medicines; health supplements/vitamins; minerals; and bulk raw materials manufactured, sold or represented for use as NHPs. Cosmetics containing NHP ingredients and that meet both the function and substance components of the NHP definition are regulated as NHPs.
Health Canada has an easy-to-follow policy on the importation of health products for commercial use. The Guidance Document on the Import Requirements for Health Products under the Food and Drugs Act and its Regulations (GUI-0117) outlines the requirements related to the importation of health products as defined by the Food and Drugs Act.
Health products commercially imported into Canada must meet all applicable requirements of the Food and Drugs Act and its Regulations including proper labelling, market authorization and establishment licenses. Here’s a summary of the licensing requirements for natural health products that are intended to be shipped to Canada for commercial purposes.
License Requirements for Natural Health Products:
Product license (NPN or DIN-HM) for each product.
All products, whether manufactured domestically or in a foreign site, must first undergo a pre-market review where it will be assessed for safety, efficacy, and quality. Evidence demonstrating this must be submitted to Health Canada by means of a product licence application (one for each product). Products, which meet the required criteria, will be authorized for sale and each issued a Natural Product Number (NPN) or Homeopathic Medicine Number (DIN-HM). Further information on this process is available in the Product Licensing Guidance Document.
Site license for each importer located in Canada.
The Natural Health Products Regulations require any Canadian site where natural health products are manufactured, imported, labelled, packaged, distributed, and/or stored to have a site licence. Businesses can choose to have a single site licence for all their operations (i.e. multiple sites) or an individual licence for each site. Site licences are obtained by demonstrating that the above-mentioned activities are conducted in a manner that is congruent with the requirements of the Canadian Good Manufacturing Practices (GMPs) for NHPs.
Quality Import Solutions (QIS) has a valid Site License to import Natural Health Products and can act as an importer of record into the Canadian market. We have collaboration with fist-class third-party warehouses annexed to our site license that can provides storage services of NHPs in compliance with Canadians GMPs if needed.
The foreign manufacturer must be listed on the importer’s site license.
While site licences are only issued to Canadian sites (none are issued to foreign sites). Foreign manufacturers as well as packagers, labellers of NHPs must be annexed to a Canadian importer’s site licence. In order to annex a foreign site to importer’s site licence, each foreign site must provide GMP evidence to demonstrate compliance with Part 3, GMP, of the Natural Health Products Regulations in full.
Why Use Quality IMPORT Solutions (QIS) as a Third-Party NHPs Importer of Record
Using QIS as a third-party NHPs Importer of Record will give you the benefits outlined below:
Flexibility to use multiple distributors and/or brokers or sell direct in Canada
Acting as a neutral third party which helps eliminating packaging liability (Our Importer’s name is required on your NHP label) if you were to use a distributor as your NHP importer and if down the line the relationship doesn’t work or if you decide to switch to a new distributor, you would be required to either over-sticker or destroy packaging
Multiple geographical choices as we have warehouse and fulfillment partners (annexed to Quality IMPORT Solutions site licence) located across Canada improving speed to market based on your preferred destination point
Having the option to either sell to traditional retail outlet or to online venues like Amazon, Well.ca and others
Low resource cost as we have an experienced team of quality assurance who provide full product disposition to the Canadian market and manage your quality assurance obligations
More than 80% of Canadians consume natural health products (NHPs), so it’s a ripe market for brands that are willing to navigate the product registration and importation requirements outlined by Health Canada. Our team will help you navigate through the process of registration and importation of your NHPs.
Our Experts at Quality Smart Solutions continue to support your needs for natural health products, foods, cosmetics, OTC drugs and medical devices for North America. Contact us today to learn more about how we can support your compliance for NHPs registration and NHP importation.
In order for food that is regulated under the Safe Food for Canadians Regulations, to be imported into Canada, the importer must hold a valid Safe Food for Canadians (SFC) license.
This license is issued by the Canadian Food Inspection Agency (CFIA) and must be presented with the shipment at the border in order for importation to be approved. Please note that this licensing may not be obtained at the border and all documentation must be in order when the shipment arrives at the border for it to be eligible for import.
The CFIA has announced that as of March 15th, 2021 certain commodities may be rejected by the CFIA unless a valid SFC license is entered in the Integrated Import Declaration (IID). The following food commodities are included.
Meat
Fish
Dairy
Eggs
Processed Eggs
Processed Fruits or Vegetables
Honey
Maple
Fresh Fruits or Vegetables
The Safe Food for Canadians license number should be entered into the appropriate field exactly as it was issued. This field is entitled “Registration Number” and the format for the license number an 8-digit alpha-numeric code.
The provided SFC license number will be reviewed to ensure that the license is valid, covers the activity of importing food, and covers the specific commodity being imported.
If the license number is not valid, a reject message will be received in the importer or custom broker’s IID system. See the below chart for an explanation of reject messages that could be received. If you have multiple licenses, verify that you are entering the correct license number on the import declaration.
Reject Message
Reason for Reject
Corrective Actions
AIRS registration number is required. (893 – Safe Food License).
When the registration number field is left blank.
Enter your SFC license number in the registration number field.
License number must be 8-digit alpha numeric (A12B3CD4). Verify license in My CFIA.
When a Y or N is entered, or the number provided is not in the CFIA database. (Check for typos)
Ensure your license number is entered correctly.
License number is either suspended, cancelled, or expired. Verify status in My CFIA.
When the license number entered has been suspended, cancelled, or expired.
If your license is suspended or cancelled, you will have to contact your local CFIA office. If your license has expired, you will have to apply for a new one using the My CFIA Portal.
License number is not valid for importing. Verify activity in My CFIA.
When the license number entered is not issued for importing food.
You can amend your license in your My CFIA portal to include “importing food” to your license profile.
License number entered does not cover food being imported. Verify license in My CFIA.
When the license number entered is not issued for the food commodity that is being declared.
You can amend your license in your My CFIA portal to include the commodity in your profile.
Please note you can amend your SFC license at any time utilizing the My CFIA Portal without incurring an additional fee.
Obtaining a Safe Food for Canadians License:
The first step involved in obtaining a Safe Food for Canadians license is to create a My CFIA Account. It is through the use of the My CFIA account that you can request license and export certifications as well as set up electronic payment methods. While enrolling, you can create one or more profiles for your business. This way if your company involves multiple site locations, you can have a profile for each site.
Once your My CFIA Account is created, you will need to then determine your license structure. Since the Safe Food for Canadians Regulations do not limit the number of licenses a person can hold, you can operate under a single license or multiple licenses. It all depends on what works best for your business!
In order to decide how many licenses you will request, you should take the following points into consideration.
There is a fee for each license requested.
A Preventative Control Plan must be implemented and maintained for each license you hold.
Since many foreign trading partners require unique identifiers for each location or establishment, you may want to ensure that each license you hold is only associated with one establishment is you deal with exportation.
If there is more than one license for a particular physical location, there cannot be any overlap in the food categories and activities covered by the license.
After you know which license(s) you wish to apply for, you should collect all the necessary details of your business that are required during the application process. The following must be entered into the Safe Food for Canadians License Application,
The activities being conducted.
The location of the establishment(s) where the activities will be conducted.
The category of food.
Attestations regarding the requirements of holding an SFCR License such as having a preventative control plan implemented within the facility and that the information provided within the application is complete and not misleading.
Once the application for licensure has been submitted you will receive an electronic message indicating whether your license was approved or if the CFIA must first inspect the business before the license can be issued.
If your license is approved, it can be found within your My CFIA account.
If the CFIA has indicated that an inspection is required first, this could be for several reasons. The CFIA utilizes a risk-based approach for inspecting new business with a variety of risk factors being selected to prioritize and manage the inspection activities. If you are requesting an export certificate or other permissions, this inspection may be a requirement of the importing country.
With the need for hand sanitizers significantly increasing for healthcare personnel and individuals during the current COVID-19 pandemic do help prevent and reduce the spread of the coronavirus Health Canada is taking action with interim measures to increase the supply of these products. This post is to help answer questions related to these actions and help you make an informed decision as it relates to licensing and marketing your hand sanitizer.
1. What action is Health Canada taking to increase the supply of disinfectants and hand sanitizers?
On March 17, 2020 Health Canada announced actions they take as an interim measure to increase the supply of hand sanitizers and disinfectants. A summary of these actions can be found here:
On February 16, 2023 Health Canada announced the interim measure for hand sanitizers has expired.
2. I am a distiller of alcoholic beverages in Canada. Do I need any special license to make hand sanitizers?
There are 3 requirements to manufacture and sell hand sanitizers. You must obtain a Natural Product NPN license (if the hand sanitizer is ethanol or isopropyl alcohol based). Licensing timelines can take 60 to 90 days for this class of natural health products. Second, you will require a site license to manufacture, package and/or label hand sanitizers. Third, you will need to obtain a Specially Denatured Alcohol (SDA) registration. This is issued by the Canada Customs and Revenue Agency (CCRA). Quality Smart Solutions can help you with all 3 of these requirements.
3. Which countries does Health Canada recognize as being licensed and approved hand sanitizers?
As of February 216, 2023 the interim program has expired. As such, Health Canada will not accept authorization in other PIC/S countries as equivalent to sell hand sanitizers in Canada. Hand sanitizers from those countries must obtain a NPN license. However, GMP from manufacturers of those countries may help in equivalency to Canada’s GMP requirements. Countries that are part of the PIC/S scheme are as follows:
4. If I have a hand sanitizer license and/or authorization from one of these countries does this mean I can sell hand sanitizers in Canada?
No, as of February 16, 2023. A Natural Health Product Number (NPN) or Drug Identification Number (DIN) is required. You will also need to partner with a Health Canada licensed importer. Quality Smart Solutions can file your NPN or DIN application.
5. My hand sanitizer is registered in the United States but my label is based on FDA regulations. Can I sell this in Canada?
You must obtain a NPN or DIN to sell your hand sanitizer in Canada. We can register your hand sanitizer whether it requires a NPN or DIN. If your hand sanitizer is a NHP that requires a NPN we can act as your Health Canada importer through our sister company, Quality IMPORT Solutions.
6. How can Quality Smart Solutions help me?
We can assist you with licensing your hand sanitizer. We have extensive experience having registered over 8000 Natural Health Products successfully obtaining Natural Product Number (NPN) licenses for hundreds of companies worldwide including many hand sanitizer companies. Our sister company, Quality IMPORT Solutions, is a Health Canada licensed importer of Natural Health Products. We currently import several hand sanitizer brands. If you are planning to manufacture your hand sanitizer in Canada we will complete your SDA registration of your facility with CCRA.
Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Medical Devices, OTC drugs in Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.
Under the Food Safety Modernization Act (FSMA), the United States (U.S.) started graduated enforcement of the Foreign Supplier Verification Program (FSVP) in May 2017.
FSVP (Foreign Supplier Verification program) requires U.S. importers (regulated by US FDA) to verify that food imported into the United States has been produced in a manner that meets applicable U.S. safety standards. Similar to the Safe Food for Canadian Regulations, Canadian importers will soon have to verify and prove to CFIA the food they are importing meets the regulations and standards.
What does this mean for US Importers of Canadian foods?
Canada and the U.S. have a Food Safety Systems Recognition Arrangement (FSSRA). The FSVP provides modified requirements to U.S. importers when they import food that is covered under the FSSRA from Canadian manufacturers that are in good regulatory standing with the Canadian Food Inspection Agency (CFIA).
Does this mean we can finally see an alliance between the US FDA and CFIA?? That is the intention of the FSSRA and, fingers crossed, this will make it easier for US and Canadian imports and exports.
The FSSRA applies to foods regulated by the US FDA including:
fruit and vegetables
shelled eggs
dairy (except “Grade A” milk and milk products)
fish (except farmed catfish, catfish products and molluscan shellfish
maple
honey
processed products; and
manufactured foods
What does this mean for the Canadian food industry?
Canadian food manufacturers who process food for export will require a licence under the Safe Food for Canadians Regulations (SFCR). When the SFCR comes into force, the CFIA will publish a listing of SFCR licensed food manufacturers as the method to certify that they are operating in good regulatory standing if they comply with SFCR requirements. To be considered to be operating in good regulatory standing under the SFCR, the federally licensed establishments will need to operate with an acceptable Preventive Control Plan (PCP) and maintain acceptable traceability documents in order to be placed on the listing of SFCR licensed food manufacturers.
If you are currently federally registered and/or licensed with CFIA:
If you operate an establishment that is currently registered with the CFIA, you will need to have an acceptable Preventive Control Plan (PCP) and traceability documentation process in place in order to obtain a license when the SFCR comes into force. Your registration and the federally registered lists currently available may be used by U.S. importers to indicate your good standing until all food manufacturers are licensed and the new list of SFCR licence holders comes into effect.
If your business is already federally registered or licensed at the time that the SFCR comes into force, you can maintain your exporting activities while you make the necessary changes to transition to the SFCR licensing system.
If you are NOT currently federally registered and/or licensed with CFIA:
Businesses in certain food sectors (i.e. manufactured foods, non-federally registered sector, etc.), which have traditionally NOT required federal registration and/or licensing, will now need to be licensed to demonstrate that your company is in good regulatory standing. Like a registered facility, you will need to have an acceptable a PCP and a traceability documentation process in place in order to obtain a licence when the SFCR comes into force.
Food businesses seeking to begin or continue exports to the U.S. will need to be licensed when the SFCR comes into force if they want to be on the Canadian list of licence holders in ‘good standing’ in order for US importers to apply the modified FSVP requirements.
The CFIA encourages all Canadian food businesses exporting to the U.S. to prepare for the SFCR as it comes into force. Being federally licensed and listed with the CFIA will eliminate the burden of documentation for importers and exporters of US FDA regulated foods. Businesses do not need to apply for an SFCR licence at this time, but as the transition to the new regulations takes place, you will be able to apply for the new licence online or access information about the licence and regulations through your My CFIA account.
If you want to be sure your food safety practises are in line with the new SFCR and export requirements, Quality Smart Solutions has a team of specialists who can assist with preparing and implementing a PCP or reviewing your documents and conducting an audit of your facility. Get prepared now and contact us today to discuss how we can be your food safety solution!
Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Canna, Medical Devices, OTC drugs in Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.
Brand names are an important part of your marketing strategy, but as many of us know firsthand there is a difference between what the marketing team wants to say and what the regulatory authorities will let you get away with. Consideration needs to be taken to ensure your brand name is as compliant as your health claims since a brand name is essentially an extension of your health claims.
As part of the review process, the Natural and Non-precription Health Products Directorate reviews your brand name in addition to your health claims. They expect that the name you choose for your product reflects the approved product claims. For example, if you want to market a product containing vitamin B12 which is licensed for the claim “Helps to maintain the body’s ability to metabolize nutrients” you will not be permitted to use any reference to weight management as part of the brand name. Other brand name challenges we have come across is the use of the term ‘detox’. This term is reserved exclusively for products which support liver function or the elimination of waste from the body.
Another challenge is having a brand name which implies treatment of a condition but only being able to receive a licence for an antioxidant claim. For example, the marketing team wants to call the product “Low Dose Lutein for Eye Health” and market the product to support eye health in conditions such as cataracts and age-related macular degeneration. However, when we review Health Canada’s monograph for Marigold extracts and isolates (including lutein) we see this eye health claim is based on quantities of at least 6 mg lutein per day. If the ‘low dose lutein’ product provides less than 6 mg lutein per day, Health Canada will only permit the use of the product for antioxidant purposes. In which case, using a brand name which speaks to the products efficacy for eye health would be considered non-compliant.
If you are looking to appease your marketing department while keeping the product brand name fully compliant, Quality Smart Solutions has a team of specialists who can assist in achieving innovative brand name compliance for your products. Contact us today to discuss how we can be your solution!
Quality Smart Solutions is an end-to-end compliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Medical Devices, OTC drugs and Canna for Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.
In September Amazon.ca notified every Natural Health Product vendor (whether they had an NPN or not) that, effective in October 2018 they will be removing all products that don’t have a Natural Health Product Number. Here’s the email they sent to sellers:
AMAZON NOTICE TO SELLERS OF NATURAL HEALTH PRODUCTS
Dear Seller,
Pursuant to Canadian laws and regulations, all non-prescription drugs, supplements, and natural health products (“NHPs“) that are sold in Canada must be assigned a registration number by Health Canada.
We are updating our product registration templates to require either a Natural Product Number, Drug Identification Number or a Homeopathic Medicine Number to list these products on our site.
From October 2018, Amazon will remove drugs, supplements, and NHPs that do not have registration numbers associated with them in the catalog from the site. If your product is impacted, you can identify the ASINs and contact Seller Support.
To back-fill the required compliance information for your existing products, you can do so through the single item setup in Seller Central or through an Inventory Template file. More information about listing drugs, supplements and NHPs can be found here: https://sellercentral.amazon.ca/gp/help/external/200164490
Amazon.ca, in recent months, had been taking a proactive approach for new products listed on their site whereby if a brand didn’t have an NPN they couldn’t be listed. However, prior to this policy implementation many products were listed without an NPN. Clearly there was significant pressure on Amazon from border officials, Health Canada and likely shareholders to tighten up their policy.
For international (ie. outside Canada) companies shipping dietary supplements to Canada there are 3 requirements as summarized on NHPLicenseExperts.com which includes:
A Natural Product Number
A compliant Natural Health Product label
An importer of record if you are shipping a finished product into Canada.
Some of the biggest brands like Amazing Grass, Dr. Bronner’s Barlean’s, Goddess Garden, SmartyPants and many more rely on our end-to-end NHP License solution.
The good news is that we are your one-stop shop solution for all three of these requirements. Working with hundreds of clients and brands we offer competitive rates having prepared thousands of NPNs over the last 12 years. Ask about our new client NPN registration offer to help you continue your business on Amazon.ca and your business in the Canadian marketplace.
Quality Smart Solutions is an end-to-end ompliance solutions expert which has been assisting clients for 11 years in the areas of Dietary Supplements/NHPs, Foods, Cosmetics, Medical Devices, OTC drugs and Canna for Canada and the United States. Ask us for details or visit our website at www.qualitysmartsolutions.com.
Just a little background information first before I talk about the business aspect of capitalizing on your NPN. NPN stands for Natural Product Number. It is a license that is issued by Health Canada and required for a dietary supplement (the term used in Canada is Natural Health Product) to legally be sold in Canada. The NPN is required to have at least one health claim associated with the license. Obtaining a license can take 10 days to 210 days depending on the product ingredients and whether they are within the scope of Natural Health Product (NHP) Monographs (class 1 or 2 NHPs) or not (Class 3).
Timing is crucial to get the highest ROI and timely return for your NPN. This will depend on when your business generates the most revenue for the desired NPN. For example, sunscreen products would typically generate most of their revenue between the summer months, May to September. Retail stores (particularly food, drug, mass stores) set their planograms and orders much earlier to ensure on-shelf presence in advance of the season start so preplanning is important, starting with a timeline when to apply for an NPN. In this example of natural sunscreen products (those with titanium dioxide and zinc oxide) these are class 1 NPNs so license is issued in 10 days. Based on lead times of various other factors (label print run, manufacturing) a reasonable time should be considered to start the process to deliver on time and not miss those key selling months. Why is this so important? If an NPN were prepared late, packaging completed mid season and delivery of packaged goods late in the summer, in this example, there could be inventory sitting that becomes short dated (in this sunscreens example, shelf life is1 to 2 years) or worse, doesn’t sell, possibly delisting or repeat orders not placed for the next season thereby depreciating your ROI for your NPN!
In the case with a class 3 NPN, that could take up to 210 days (7 months) after submission acknowledgement, a more long term planning launch strategy is needed. Some retailers, for example, won’t begin dialogue with a branded company until they have an NPN. Most natural health products see most of their sales between September to February. Diet and Sports Nutrition companies see a significant portion of new business in the “new years resolution period” between December to February. Let’s look at a hypothetical example, of a class 3 NHP that would start in 2016. Here’s how a Canadian launch planning could be mapped out to gain the most revenue and the soonest to NPN issuance:
Mid August/early September 2016 – submit class 3 NHP application
mid September/Early October 2016 – acknowledgement letter of class 3 NHP submission indicating that it will take up to 180 days, 30 days after the date of the letter (total 210 days) to meet the performance target to obtain an NPN
April 2017 – if you are a foreign company and manufacturing, shipping finished product from outside of Canada your manufacturer, labeller and packager have to be annexed to a Canadian importer. This process can take 30 to 90 days for approval
May 2017 – latest when the class 3 NHP will be issued an NPN (based on an October acknowledgement letter receipt). Safe now to schedule the manufacturing of approved NPN product.
Mid May/early June 2017 – bilingual compliant NHP label ready to print
Late June/early July 2017 – printed packaging ready
June to August 2017 – manufacturing of approved NPN product (based on manufacturer lead time which is dependent on raw material availability, seasonality peaks, line time queue from other manufacturer clients). Typical lead time of manufacturers is 4 to 12 weeks.
Mid August – ship to retail or warehouse
September 2017 – Product launch
This scenario is a best case situation. There are many factors that come into play upstream such as ingredient safety and efficacy substantiation, formula feasibility, researching substitute ingredients if one or more ingredient in the original formula aren’t meeting safety parameters and other considerations (these are some areas we look at with our clients applying for NPNs).
Here are general rules of thumb when to begin the NPN license process prior to launch date:
Class 1 – at least 6 months
Class 2 – at least 7 months
Class 3 – at least 13 months
In each of these cases, if annexing your manufacturer to a Canadian importer site license is required, this should start at least 5 months before product launch.
If you have any questions we are happy to help. Feel free to contact us.
Our business development solution division, Quality IMPORT Solutions, can act as your Dietary Supplement Importer into the Canadian market and connect you with reputable brokers and distributors that cover the Canadian market from coast-to-coast. Ask us for details or visit our website at www.qualitysmartsolutions.com
Large Indoor Marijuana Commercial Growing Operation With Fans, Greenhouse, Equipment For Growing High Quality Herb. Cannabis Field Growing For Legal Recreational Use in Washington State
On November 21, 2017 the Canadian Minister of Health announced the Proposed Approach to the Regulation of Canna. The public consultation 60-day period has begun for feedback on the proposed rules which are primarily to layout the framework and regulations around recreational marijuana with medical marijuana rules, for the most part, being status quo. The consultation paper covers 8 areas including Licenses, permits and authorizations, security clearances, canna tracking system, canna products, packaging and labelling, canna for medical purposes, health products and cosmetics containing canna and miscellaneous issues. The government’s intent is to have the Canna Act be approved before July 2018. Here are the main takeaways from the proposed Canna Act :
Expansion of License categories
Currently the license categories include cultivation, processing and selling of medicinal marijuana. The new proposal will allow for an expansion of the cultivation license including micro cultivation, microprocessing and nursery licenses. Also, outdoor cultivation would be permitted (as opposed to the current regulations that allow for indoor cultivation that is only allowed) though a dwelling house would be prohibited from conducting any licensed activity. Import and Export of medical canna and industrial hemp would be allowed.
Security Clearances
The current system has a strict security clearance of individuals with any previous criminal record not being permitted to obtain clearance for producing or distributing canna. Under the proposed regulations, this will be determined on a case-by-case basis whereby individuals who are considered low risk may be granted clearance.
Canna Tracking System
A National tracking system (likely through a public online platform) would be created with the intent to prevent unauthorized activities and/or deter organized crime from conducting activities. This system would likely be similar to the Establishment License system for drugs and medical devices. There is currently a monthly tracking system in place for medical canna licensed producers. This new proposed system would expand on this platform.
Canna Products and Forms
Five classes of canna would be permitted for sale including dried canna, canna oil, fresh canna, canna plants and canna seeds. Edibles such as foods or beverages would be permitted. Currently capsules and creams are not allowed under the ACMPR framework. However, with the proposal various forms such as capsules, topical application creams and oils would be permitted and likely licensed similar to the NHP and DIN regulations. There would be limits set on the amount of THC allowed per dosage unit set at 10 mg.
Packaging and Labelling
Adopting the labelling standards of tobacco products, the proposed labelling requirements would limit graphics, colours and other packaging aesthetics to deter youths from purchasing recreational canna products. Tamper evident, child-resistant packaging. Limits of 30 grams of dried canna per single package and 2.1 Litres for canna oil would be set. Labelling requirements would include such items as product name, description, THC/CBD content and warnings to KEEP OUT OF REACH OF CHILDREN. Health warning statements would be mandatory similar to tobacco products. A Standardized canna symbol will be created to prevent accidental ingestion for products with more than 10 ppm of THC.
Medical Canna
The regulations for medical canna, as outlined in the ACMPR, would remain mostly the same with the access for patients being modified to allow for greater than a 30 day supply if a licensed seller cannot fill multiple orders within a 30-day period.
Health Products and Cosmetics with Canna
Health products such as prescription, non-prescription (OTC) drugs, natural health products (NHP), veterinary drugs, veterinary health products (VHP) and medical devices with canna may be permitted based on scientific evidence that demonstrate safety and efficacy of these combination products. Furthermore, cosmetics (which currently prohibit canna derived ingredients) may be allowed under the proposed Canna Act.
Miscellaneous Issues
Amendments to the current ACMPR and NCR based on this proposed Canna Act would be implemented. Qualifications for designated analysts of suspected seized controlled substances would be determined. Amendments to the practitioners to prescribe, administer and provide based on respective provincial regulations.
Quality Smart Solutions is ready to assist companies seeking expert Canada Canna regulatory and quality assurance assistance under the current ACMPR framework for license applications and we will be prepared to assist companies on the forthcoming Canna Act framework. Contact us today how we can be your solution!
On November 14, 2017 the Natural and Non-prescription Health Products Directorate (NNHPD) announced that there are several updates to the NHP Monograph for Green Tea Extract based on reports from Canada and worldwide that there may be a link, albeit the risk is rare, of the use between green tea extract and risk of a rare and unpredictable liver injury. The risk statement is already required with products falling within the scope of the current Green Tea Extract monograph. The updated monograph will elaborate on these warnings and risk statements. As well, the subpopulation of children and adolescents will be excluded from the monograph and will be restricted to adults 18 years and older.
The following changes to and additional risk statements will be required (with new verbiage in bold):
“If you have a liver disorder, consult a healthcare practitioner prior to use. Stop useif you develop symptoms of liver trouble such as yellowing of the skin/eyes (jaundice),stomach pain,dark urine, sweating, nausea, unusual tiredness and/or loss of appetite and consult a healthcare practitioner”
“Rare, unpredictable cases of liver injury associated with green tea extract-containing products have been reported (in Canada and internationally)”
Products that contain Green Tea Extract as a non-medicinal ingredient are required to report the amount of EGCG in the green tea and required to add the above stated risk statements.
As Health Canada must be notified stating companies containing GTE either as medicinal or non-medicinal ingredient the dates are as follows:
GTE as a non-medicinal ingredient and quantity of EGCG – December 14, 2017
GTE as a medicinal ingredient attestation – November 14, 2018
If you have a NPN licensed product containing Green Tea extract either as a medicinal ingredient or non-medicinal ingredient please contact Quality Smart Solutions today to assist you in notifying Health Canada about this important label update.
This past June 2017 the Food and Drug Administration (FDA) put a hold on the compliance dates for Nutrition Facts and Supplement facts compliance dates. The compliance dates were scheduled for July 26, 2018 for companies with annual sales over $10 million and July 26, 2019 for companies with sales over $10 million. Scott Gotlieb sent a tweet out in mid-September that FDA would propose a 18 month delay on the compliance dates so we knew this was coming soon.
The new dates are as follows:
January 1, 2020 – companies with annual sales over $10 million
January 1, 2021 – companies with annual sales under $10 million
The details of these changes to the Nutrition Facts tables can be found here.
Quality Smart Solutions has been implementing the new Nutrition Facts and Supplement Facts table regulations for our clients for the last 12 months so they are future-proofed. We are experts in US Food and Dietary Supplement label compliance. Contact us today if you are seeking affordable US label review assistance.
As discussed in an earlier post (PLL – Plain Language Labeling: What it means and how it affects you), the Food and Drugs Act (F&DA) underwent drastic revision after the thalidomide crisis of the 1960s. While some amendments have been introduced since then, the F&DA has remained mostly untouched. In 2014, the Regulations Amending the Food and Drug Regulations were passed in order to address several issues that were identified over the previous 50 years. One set of these amendment impacts the registration of veterinary health products, defined as low-risk products such as vitamins, minerals, traditional and homeopathic medicines for companion and food-producing animals. These products promote the health and wellbeing of animals but do not diagnose or treat disease.
On May 17, 2017, the final publication in the Canada Gazette, Part II of the Regulations Amending the Food and Drug Regulations (Veterinary Drugs – Antimicrobial Resistance) formalizes the existing voluntary Interim Notification Pilot Program (INPP). The regulations are scheduled to come into effect on November 13, 2017.
Background
Health Canada’s INPP for veterinary health products (VHPs) has been in place since 2012. Health Canada leveraged a third-party organization North American Compendiums (NAC – www.lrvhp.ca) and the Canadian Animal Health Institute, launched a voluntary pilot program to launch a pilot as a mechanism to assess how well a risk-based, streamlined process would work to register such products and all learnings were to inform a more permanent program. Nearly 1000 products have been successfully notified by Canadian manufacturers and importers for sale in Canada.
The Veterinary Drugs Directorate of Health Canada will administer the Notification Program that will build on the current pilot’s process structure. The notification of VHPs, the requirements for VHP substances or ingredients as included on List C: Veterinary Health Products, and the reporting of adverse events remains intact.
Rules For VHPs The risk-based notification program for VHPs will require:
companies to notify Health Canada 30 days before selling a VHP or making a change to a marketed VHP
All active, homeopathic and traditional medicine substances permitted in VHPs are listed in List C: Veterinary Health Products and must be labeled accordingly
labels to state “Veterinary Health Product”
mandatory reporting of serious adverse drug reactions to Health Canada
For companies with existing valid notifications, their labels will be transferred over to the new system and companies must update their labels within 18 months, or sooner at the next labeling cycle. New registrants can notify according to the old rules until October 13, 2017, and all VHPs will be required to comply with the new rules as of November 13, 2017.
How QSS Can Help
Our Quality Smart Solutions (QSS) team takes great pride in our client-focused, solutions-oriented approach to resolving your issues and challenges. Not only will we review your labels to assess your compliance with the new regulations, but we will also submit the registrations and work with the regulator on your behalf. Further to this, we will work with you to make sure you and your supply chain meet GMP. QSS is your solution to ensuring you are compliant with Health Canada’s VHP requirements. Contact Quality Smart Solutions today at 1-800-396-5144 ext. 4 or fill out our online page by clicking here. To see all we have to offer in regulatory compliance and quality assurance solutions, visit us at www.qualitysmartsolutions.com.
Our sister company, Quality IMPORT Solutions has a new website with all the information you need to make an informed decision when choosing an importer for your natural health products and what makes Quality IMPORT Solutions different than other providers. You visit the site at www.qualityIMPORTsolutions.com.
Originally implemented in 1920 after the inception of the Federal department of Health in 1919, the Food and Drugs Act (F&DA) underwent drastic revision after the thalidomide crisis of the 1960s. While some amendments have been introduced since then, the F&DA has remained mostly untouched. In 2014, the Regulations Amending the Food and Drug Regulations were passed in order to address several issues that were identified over the previous 50 years.
Many of the 2014 changes allocated to the Minister more power to demand action in the face of identified risk, i.e. the power to request recalls products affected by emergent safety issues, or request immediate package label revisions to include warnings in reaction to newly identified risks in a mandate called Vanessa’s Law. Along with this and other sets of changes, amendments were passed in order to promote consumers’ understanding of drug labels at the point of purchase.
The new Canada Plain Language Labeling (PLL) requirements apply these amendments to the regulations. The intention was seemingly simple: to provide important information to consumers in plain language in an easy to read format, so product names are not confusing and it is clear how to report harms caused by the purchased drug.
IMPACT TO INDUSTRY
These PLL requirements for prescription and non-prescription pharmaceutical drugs, biologic drugs, and radiopharmaceuticals were phased in per drug product type. The Health Canada Labeling Guidance Regulations took effect for prescription products as of June 13, 2015, and for non-prescription products, more recently as of June 13, 2017.
Overall, much more work must be done upfront before submitting application packages to the regulator for pre-market approval. As such, graphic design work must be done in parallel to submission preparation. Health Canada will no longer accept unformatted label text; however, it will accept annotated written text, in lieu of mock-ups, to reflect proposed changes to the inner/outer labels as part of Notifiable Change (NC) submissions or Post-Authorization Division 1 Change submissions (PDCs).
If you plan to submit a new or amend a DIN, NDS, SNDS, or to amend your existing drug product license, you are affected by this.
CANADA LABELING REQUIREMENTS
Information on the label must be expressed in plain language in a way that does not impede the user’s understanding. Health Canada’s expectation is for all existing labels to be updated with PLL labels over time and for all new drug applications to consider the following aspects of their labeling:
Brand name: Your product’s brand name cannot resemble any other DIN product, a kit, or a radiopharmaceutical. HC may request evidence. Look-alike sound-alike (LASA) drug product names refer to names of different drug products that are similar when written or spoken. Such similarities may cause confusion and result in errors when self-selecting, prescribing, transcribing, dispensing, or administering a drug product, introducing a risk of harming the user/patient/consumer if the wrong medication is prescribed or improperly dosed/administered.
Contact information: Inner and outer labels must display information that allows the consumer to contact the party responsible for the product in Canada for guidance if any problems occur. At least one method of contact should be listed, such as a toll-free number, email address, or website. The licensee can decide who can be the initial contact. Note that biologic drugs and radiopharmaceuticals are exempt from this requirement.
Mock-up requirement: Mock-up labels of every label to be used for the drug must be provided to Health Canada upfront with the product license application submissions instead of at the DIN activation stage (i.e. as part of market notification). These labels are market-ready and fully bilingual, in full color and actual size. This includes package inserts. Health Canada Labeling reviewers will review font size and type, color; and placement (including proximity, overlap, and panel location) of key elements of an inner/outer label. Only editable labels (i.e. not locked PDF files) are accepted, meaning those which enable reviewers to verify the font type and sizes. A locked file impedes reviewers from making annotations to the labels. Provide the font size and typestyle upfront in the Certification doc, required to accompany the submission. When Health Canada label reviewers know the font size and typestyle of labels at the beginning of a review, they are able to review labels more efficiently. Specific labeling requirements exist for product monographs and various package insert/pamphlet/leaflet formats. Mock-ups must also be submitted with administrative for changes to manufacturer or product name.
Canadian Drug Facts Table (CDFT): A formatted table of the required information is mandatory only for non-prescription drugs only so that consumers are fully informed at the point of sale. Good Label and Package Practices must be applied, and all formatting rules must be followed.
PLL applies to prescription and non-prescription pharmaceutical drugs, biologic drugs, and radiopharmaceuticals.
TIPS
To facilitate your adherence to PLL and Health Canada’s review and approval of your drug submissions, consider the following points:
Research Brand names to ensure they do not resemble other brand names, common names, or proper names of products/chemical entities that are currently available for sale in Canada.
Wording for contact information most often seen is “For questions or to report problems, please contact…” or “Questions or concerns?”, followed by the contact information.
Provide only editable labels (i.e. not locked PDF files) to the QSS reviewer and as part of the submission.
Provide the font size and typestyle used in the label upfront in the accompanying Certification document
Review the specific formatting requirements for product monographs and package insert/pamphlet/leaflet. Leverage QSS’s expertise for strategic advice in your unique circumstance. We believe in a no-nonsense approach to help you navigate regulatory hurdles without sacrificing your business goals.
HOW WE CAN HELP
Our Quality Smart Solutions (QSS) team takes great pride in our client-focused, solutions-oriented approach to resolving issues and challenges. With expertise in OTC, ANDS drug submissions, label review, and French translation, we provide Health Canada Labeling Guidance to ensuring you are compliant with Health Canada’s Drug Regulations. Contact Quality Smart Solutions today at 1-800-396-5144 ext. 4 or fill out our online page by clicking here. To see all we have to offer in regulatory compliance and quality assurance solutions, visit us at www.qualitysmartsolutions.com.
Some companies make the assumption that selling a dietary supplement product in Canada is no different than selling in the United States. There are, in fact, several distinct differences. As you plan to enter the Canadian market there are several points to consider.
You need to obtain a Natural Product Number (NPN). This is a license issued by Health Canada for Dietary Supplements. The process to obtain a license can take 10 to 210 days depending on the ingredients in the formula. There is currently a pilot program which is trying to ensure that 95% of applications receive a license in 30 days. This program concludes at the end of February and initiatives, technology and processes will be improved to hit this target.
You must have a compliant label, both in terms of content and layout as well as a bilingual label that is in both English and French.
Your manufacturing facility has to be annexed to a Natural Health Product site licensed importer (these licenses are only issued to Canadian businesses). Often distributors hold an import site license but it is not necessary or a requirement that the distributor also be your importer on record. Depending on your needs and strategy for Canada, it may be preferable to work with a third party importer that is separate from the distributor.
Quality Smart Solutions can assist you in these three areas. In addition, we have a national network of distributors and brokers in Canada to fit your distribution and channel needs. We are more than just a consulting firm. We are YOUR end-to-end solution for a compliant and successful Canadian launch. Contact us today or call us at 1-800-396-5144.
Health Canada recently announced their initiative to modernize the regulatory framework for health products and foods. This is required due to a variety of factors, such as new and emerging science breakthroughs and public health threats worldwide. The modernization is also based on public input regarding the need for greater transparency. The Canadian federal government published a Red Tape Reduction program in January 2012, and some of the reasons for change also stem from this report.
The NHPD recently released a Standards of Evidence document that is currently under consultation review by stakeholders. This consultation review is set to end August 21, 2012. The document takes a risk based approach to health claims and may allow lower risk claims to be made based on non-human studies (e.g. In vitro animal studies) as long as safety data in humans is available. Essentially this review and licensing will be based on three class levels, each having a level of risk. In addition to this license evaluation approach there are new timelines proposed. The chart below illustrated the current and future timelines:
Class
Current Timeframe
Future timeframe
1 – High level of certainty – (eg. Monographs, AbLs, Category IV/TPD labeling
60 days
10 days
2 – Medium level of certainty – a combination of pre-cleared information and high quality data from peer reviewed published journals
180 days
30 days
3 – Low level of certainty – clinical trial evidence and full pre-market assessment
180 days
180 days
Based on the amount of information that the NHPD has gathered over the last 8 years and pre-cleared information through NHPD monographs, the anticipation is that 99% of all product license applications would be reviewed in 30 days or less. With the Exemption number program set to expire in February, the NHPD is under the gun to clear the backlog and introduce a new process. After UPLAR expires in February, the mandate will be in place so that products will not be allowed for sale unless an NPN is issued.
These new target review timelines are a major requirement forcing companies to set dates for products on shelf with their retail partners. The new framework will hopefully prevent any future backlogs. Based on the rapid response that Quality Smart Solutions has seen in the past year, from license submission to license issuance for our clients, it is encouraging that the NHPD will meet their target of clearing the backlog and repeal UPLAR without further extension of the regulations past the due date. We also anticipate many more monographs to be published between now and next February. Quality Smart Solutions will keep you updated as this new approach develops and becomes reality.
Significant changes are occurring in the global regulatory landscape as of late, and this is just another example of how the world is evolving into a single global marketplace. Products marketed in the United States may be in Brazil after having cleared the regulatory hurdles of that country. Products made in Korea may be in Canada after receiving an acknowledgment letter or NPN. With globalization, various regulatory hurdles must be overcome for each country or region where entry is desired. Quality Smart Solutions is involved in this global market, and our clients span the globe. We will keep you informed through news feeds which we regularly update on our website.
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