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Unique Device Identifier System: Frequently Asked Questions, Vol. 1 : Guidance for Industry and Food and Drug Administration Staff

FinalCenter for Devices and Radiological Health Center for Biologics Evaluation and Research08/20/2014

Description

Section 226 of the Food and Drug Administration Amendments Act of 2007 (FDAAA) and section 614 of the Food and Drug Administration Safety and Innovation Act of 2012 (FDASIA) amended the Federal Food, Drug, and Cosmetic Act to add section 519(f), which directs FDA to publish regulations establishing a unique device identification system for medical devices. On September 24, 2013, FDA published a final rule establishing a unique device identification system (the UDI Rule). While some parts of the rule became effective on October 24, 2013 and some became effective on December 23, 2013, most requirements within the rule have later compliance dates, as will be explained in Section A.2. of this document. In developing the UDI Rule, FDA solicited input from a variety of stakeholders (e.g., manufacturers, global regulatory bodies, the clinical community, patient advocates) to ensure that as many perspectives were incorporated as possible.

Scope & Applicability

Product Classes

9
medical devices

Products subject to the unique device identification system

Humanitarian Use Devices

Medical devices intended to benefit patients in the treatment or diagnosis of diseases affecting not more than 8,000 individuals in the U.S. per year.; Devices intended for diseases occurring in fewer than 8,000 individuals; devices approved under an HDE

Class I devices

Subject to General Controls

implantable devices

Not required to be directly marked with a UDI.

Class III Device

Generally recommended for Enhanced Documentation; Regulatory classification mentioned for implantable sensors and HPV tests; Mentioned in the context of an in vitro nucleic acid test for CMV DNA.

Class II Device

Devices subject to section 522 postmarket surveillance orders; devices subject to postmarket surveillance orders

Class I Device

Low risk medical devices

Implantable Device

Specific UDI compliance dates and exception restrictions

Life-Supporting Device

Reusable life-supporting or life-sustaining devices issued an EUA; Devices like ventilators requiring specific transition steps

Stakeholders

9
labeler

Person who causes a label to be applied to a device for commercial distribution; Entity required to enter DI and attribute information into GUDID; Entity responsible for GUDID account and device information; Responsible for ensuring DI record information is accurate and up-to-date.; Entity identified by a GUDID account; Entity responsible for GUDID data and recordkeeping.

manufacturer

Entity required to conduct postmarket surveillance; entity responsible for submitting postmarket surveillance plans; Entity holding the approved PMA, HDE, or cleared 510(k); The entity responsible for conducting postmarket surveillance and submitting reports.; Entity that can use the checklist as a reference for submissions.

FDA-accredited issuing agency

Organization accredited by FDA to operate a UDI issuance system; Entity that operates a system for UDI assignment; Organizations that provide guidelines for including non-UDI elements.

device manufacturer

Entity responsible for specifying acceptance criteria and risk management; Responsible for specifying essential performance and submitting premarket submissions.; supplied by the device manufacturer to the testing laboratory

specification developer

A type of entity that may be considered a labeler.

single-use device reprocessor

A type of entity that may be considered a labeler.

convenience kit assembler

A type of entity that may be considered a labeler.

repackager

Trading partner defined in section 581(16) of the FD&C Act

relabeler

Entity that receives drug products for relabeling.

Regulatory Context

Attributes

1
Standard Date Format

YYYY-MM-DD format required on labels

Related CFR Sections (11)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Envoy Medical Inc.

    2025-12-09
  • CGMP/QSR/Medical Devices/Adulterated

    Hong Qiangxing Shenzhen Electronics Limited

    2025-11-25
  • CGMP/QSR/Medical Devices/Adulterated

    Contec Medical Systems Co., Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Royal Philips

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Qianjiang Kingphar Medical Material Co Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated

    LEVO AG

    2025-10-21
  • CGMP/QSR/Medical Devices/Adulterated

    Technological Medical Advancements LLC

    2025-10-07
  • Medical Device Reporting/Misbranded

    Insung Medical Co. Ltd.

    2025-09-30
  • Medical Device/Adulterated/Misbranded/Lacks PMA and/or 510(k)

    The Richline Group, Inc.

    2025-09-23
  • Investigational Device Exemptions (IDE)/Premarket Approval Application (PMA) Adulterated Device

    SeniorLife Technologies, Inc.

    2025-09-16

See Also (8)