Contains Nonbinding Recommendations 
 
 
Unique Device Identification System: 
Small Entity Compliance Guide 
 
Guidance for Industryand  
 
Food and Drug Administration Staff 
 
Document issued on August 13, 2014  
 
On November 5, 2014 this document was edited to correct the Compliance Dates table on 
page 23. 
 
For questions for the Center for Devices and Radiological Health regarding this document 
contact UDI Regulatory Policy Support, 301-796-5995, email: udi@fda.hhs.gov.  
 
For questions for the Center for Biologics Evaluation and Research regarding this document, 
contact the Office of Communication, Outreach and Development at 1-800-335-4709 or 240-
402-7800, email: ocod@fda.hhs.gov . 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
           U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Devices and Radiological Health 
    Center for Biologics Evaluation and Research 
 
 
  1  Contains Nonbinding Recommendations 
 
 
Preface 
 
 
Public Comment 
 
You may submit electronic comments and suggestions at any time for Agency consideration to 
http://www.regulations.gov. Submit written comments to the Division of Dockets 
Management, Food and Drug Administration, 5630 Fishers Lane, Room 1061, (HFA-305), 
Rockville, MD 20852.  Identify all comments with the docket number listed in the notice of 
availability that publishes in the Federal Register. 
 
 
 
Additional Copies 
 
CDRH 
 
Additional copies are available from the Internet. You may also send an e-mail request to 
CDRH-Guidance@fda.hhs.gov to receive a copy of the guidance.  Please use the document 
number 1400046 to identify the guidance you are requesting. 
 
CBER 
 
Additional copies of this guidance document are also available from the: 
 
Center for Biologics Evaluation and Research (CBER),  
Office of Communication, Outreach and Development,  
10903 New Hampshire Ave, Bldg. 71, Room 3128 
Silver Spring, MD 20993, or by calling 1-800-835-4709 or 240-402-7800, by email 
ocod@fda.hhs.gov, or from the Internet at 
http://www.fda.gov/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInform
ation/default.htm.  
  2  Contains Nonbinding Recommendations 
 
 
 
 
Table of Contents 
 
I.     Introduction ..................................................................................................................................................... 4 
II.  Background ............................................................................................................................................... 5 
III.  Overview ................................................................................................................................................... 6 
IV.  Definitions ................................................................................................................................................. 6 
V.   UDI Final Rule ........................................................................................................................................ 11 
A.  Requirement to bear a UDI label ............................................................................................................. 11 
1.  Device Identifier and Production Identifier ......................................................................................... 11 
2.  Voluntary Labeling of Device with UDI (21 CFR 801.35) ................................................................. 12 
3.  In Vitro Diagnostic Products (21 CFR 801.119) ................................................................................. 12 
4.  Discontinuation of legacy FDA identification numbers assigned to medical devices (NHRIC and 
NDC numbers) .............................................................................................................................................. 12 
(21 CFR 801.57) ........................................................................................................................................... 12 
B.  UDI Label Requirements ......................................................................................................................... 13 
1.  Form of a UDI (21 CFR 801.40) ......................................................................................................... 13 
2.  Technical Requirements for a UDI (21 CFR 830.20) ......................................................................... 13 
3.  Format for Dates Provided on a Label (21 CFR 801.18) .................................................................... 14 
4.  Permanent UDI (21 CFR 801.45) ....................................................................................................... 14 
5.  Stand Alone Software (21 CFR 801.50) ............................................................................................. 14 
C.  Issuing Agency ........................................................................................................................................ 15 
D.  GUDID data submission requirements .................................................................................................... 16 
1.  Information required (21 CFR 830.310) ............................................................................................. 16 
2.  Rejection, removal or correction ......................................................................................................... 17 
E.  Exceptions and Alternatives to the UDI Requirement ............................................................................. 17 
1.  General Exceptions (21 CFR 801.30) ................................................................................................. 17 
2.  Requesting a Specific Exception or Alternative (21 CFR 801.55) ...................................................... 19 
F.  Modifications to other 21 CFR Provisions .............................................................................................. 20 
VI.  Compliance Dates .................................................................................................................................... 23 
 
 
  3  Contains Nonbinding Recommendations 
 
 
Unique Device Identification System 
Small Entity Compliance Guide
 
 
Guidance for Industry and  
Food and Drug Administration Staff  
 
This guidance represents the Food and Drug Administration's (FDA's) current thinking 
on this topic.  It does not create or confer any rights for or on any person and does not 
operate to bind FDA or the public.  You can use an alternative approach if the approach 
satisfies the requirements of the applicable statutes and regulations.  If you want to discuss 
an alternative approach, contact the FDA staff responsible for implementing this 
guidance.  If you cannot identify the appropriate FDA staff, call the appropriate number 
listed on the title page of this guidance.  
 
I.     Introduction 
 
The Food and Drug Administration (FDA) is responsible for protecting the public health by 
assuring the safety, effectiveness, and security of human and veterinary drugs, vaccines and 
other biological products, medical devices, the nations food supply, cosmetics, dietary 
supplements, and products that give off radiation; and for regulating tobacco products. 
 
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).  Some parts of the rule became effective on 
October 24, 2013; the remaining parts became effective on December 23, 2013.  Certain 
requirements within the rule have later compliance dates, as will be explained in Section VI 
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.   
 
This guidance is intended primarily to provide information to the medical device industry,   
including small businesses, concerning FDAs September 24, 2013, final rule establishing a 
unique device identification system; see 78 FR 58786 et seq.  It provides an overview of the 
UDI Rules regulatory requirements and discusses the actions a small entity should take to 
meet those requirements. Other guidance documents, such as the guidance document titled 
  4  Contains Nonbinding Recommendations 
 
 
Global Unique Device Identification Database (GUDID) and issued on June 25, 2014, 
discuss in greater detail the technical implementation of the UDI Rule. 
 
Throughout this guidance document, the terms we, us and our refer to FDA staff from 
CDRH and the Center for Biologics Evaluation and Research (CBER). You and your 
refers to the labeler. 
 
FDA's guidance documents, including this guidance, do not establish legally-enforceable 
responsibilities. Instead, guidances describe FDAs current thinking on a topic and should be 
viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited. The use of the word should in FDA guidance means that something is suggested or 
recommended, but not required.  
 
II.  Background 
 
Under Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996 (PL 
104-121) we are required to publish one or more guides that assist small entities in complying 
with each rule or group of related rules for which we are required to prepare a final regulatory 
flexibility analysis under 5 USC 605(b).    
 
The UDI Rule establishes a UDI system.  It requires the labels and device packages of 
medical devices distributed in the United States include a unique device identifier (UDI), 
unless we grant an exception or alternative to UDI label requirements.  As will be explained 
later, this UDI will be in both easily readable plain-text and Automatic Identification and 
Data Capture (AIDC) technology  usually a bar code. The UDI Rule also requires specified 
product information be submitted to FDAs Global Unique Device Identification Database 
(GUDID). Most of this information in GUDID will be made available to the public. When 
fully implemented, the UDI system will serve several important public health objectives: 
 
  It will facilitate the healthcare community, industry, and the publics rapid and 
accurate identification of a device using the UDI that appears on the devices label 
and device package. 
  Medical providers, patients and others will be able to more easily access important 
information concerning the device, thereby reducing medical errors.  
  It will allow more accurate reporting, reviewing, and analyzing of adverse event 
reports so that problems can be identified and corrected more quickly. 
  It will provide a standard and clear way to document device use in electronic health 
records, clinical information systems, claims data sources and registries, leading to a 
more robust postmarket surveillance system which can be leveraged to support 
premarket approval or clearance of new devices and new uses of currently marketed 
devices.  
  It will enable manufacturers, distributors and healthcare facilities to more effectively 
manage medical device recalls.  
  5  Contains Nonbinding Recommendations 
 
 
  It will provide a foundation for a global, secure distribution chain that will help 
address counterfeiting and diversion, and prepare for medical emergencies.  
 
III.  Overview 
 
The UDI Rule establishes label and data submission requirements for all medical devices in 
commercial distribution in the United States.  There are two main parts to the UDI system; 
there is a label requirement and a data submission requirement.  Every medical device label 
and every device package must include a UDI, unless we have granted an exception or 
alternative.  The rule lists general exceptions and outlines the procedure for requesting a 
specific exception or alternative.  The UDI Rule specifies the requirements for how the UDI 
will appear on the device label and package.  The UDI Rule also specifies data submission 
and record keeping requirements.  It requires all UDIs to be issued under a system operated 
by an FDA-accredited issuing agency.  It also outlines the procedure to apply for FDA-
accreditation as an issuing agency, specifies the information that the applicant must provide 
to FDA, and lists the criteria we will apply in evaluating applications.  The UDI Rule 
provides for the suspension and revocation of the accreditation of an issuing agency, and 
explains the circumstances under which we may act as an issuing agency.  The UDI system 
will be phased in over a seven year period, through an established set of compliance dates, to 
ensure a smooth implementation, and to spread the costs and burdens over time.  Greater 
details of the UDI Rule are set out in the following sections of this document. 
 
IV.  Definitions 
 
The following terms are defined in the UDI Rule: 
 
Automatic identification and data capture (AIDC) 
 
Any technology that conveys the unique device identifier or the device identifier of a device 
in a form that can be entered into an electronic patient record or other computer system via an 
automated process. 21 CFR 801.3. 
 
Center Director 
 
The Director of the Center for Devices and Radiological Health or the Director of the Center 
for Biologics Evaluation and Research, depending on which Center has been assigned lead 
responsibility for the device. 21 CFR 801.3. 
 
Combination product 
 
Includes: 
(1) A product comprised of two or more regulated components, i.e., drug/device, 
biologic/device, drug/biologic, or drug/device/biologic, that are physically, chemically, or 
otherwise combined or mixed and produced as a single entity; 
  6  Contains Nonbinding Recommendations 
 
 
(2) Two or more separate products packaged together in a single package or as a unit and 
comprised of drug and device products, device and biological products, or biological and 
drug products; 
(3) A drug, device, or biological product packaged separately that according to its 
investigational plan or proposed labeling is intended for use only with an approved 
individually specified drug, device, or biological product where both are required to achieve 
the intended use, indication, or effect and where upon approval of the proposed product the 
labeling of the approved product would need to be changed, e.g., to reflect a change in 
intended use, dosage form, strength, route of administration, or significant change in dose; or 
(4) Any investigational drug, device, or biological product packaged separately that according 
to its proposed labeling is for use only with another individually specified investigational 
drug, device, or biological product where both are required to achieve the intended use, 
indication, or effect. 21 CFR 801.3 citing 21 CFR  3.2(e). 
 
Convenience kit 
 
Two or more different medical devices packaged together for the convenience of the user.  
21 CFR  801.3. 
 
Device Identifier (DI) 
 
A mandatory, fixed portion of a UDI that identifies the specific version or model of a device 
and the labeler of that device. 21 CFR  801.3. 
 
Unique Device Identifier (UDI) = Device Identifier (DI) + Production Identifier (PI) 
 
Device package 
 
A package that contains a fixed quantity of a particular version or model of a device. 21 CFR  
801.3. 
 
Expiration date 
 
The date by which the label of a device states the device must or should be used. 21 CFR  
801.3. 
 
FDA, we, or us 
 
The Food and Drug Administration 21 CFR  801.3. 
 
Finished device 
 
Any device or accessory to any device that is suitable for use or capable of functioning.  
21 CFR  801.3. 
 
  7  Contains Nonbinding Recommendations 
 
 
Federal Food, Drug, and Cosmetic Act 
 
21 USC 321 et seq., as amended. 
 
Global Unique Device Identification Database (GUDID) 
The database that serves as a repository of information to facilitate the identification of 
medical devices through their distribution and use. 21 CFR  801.3. 
 
Human cells, tissues, or cellular or tissue-based product (HCT/P) regulated as a device 
 
An HCT/P,1 as defined in 21 CFR 1271.3(d), that does not meet the criteria set forth in  
1271.10(a) and that is also regulated as a device. 21 CFR  801.3. 
 
 
                                                           
1  1271.3(d) - Human cells, tissues, or cellular or tissue-based products (HCT/Ps) means articles containing or 
consisting of human cells or tissues that are intended for implantation, transplantation, infusion, or transfer into a 
human recipient. Examples of HCT/Ps include, but are not limited to, bone, ligament, skin, dura mater, heart 
valve, cornea, hematopoietic stem/progenitor cells derived from peripheral and cord blood, manipulated 
autologous chondrocytes, epithelial cells on a synthetic matrix, and semen or other reproductive tissue. The 
following articles are not considered HCT/Ps: 
(1) Vascularized human organs for transplantation; 
(2) Whole blood or blood components or blood derivative products subject to listing under 21 CFR Parts 607 
and 207 of this chapter, respectively; 
(3) Secreted or extracted human products, such as milk, collagen, and cell factors; except that semen is 
considered an HCT/P; 
(4) Minimally manipulated bone marrow for homologous use and not combined with another article (except for 
water, crystalloids, or a sterilizing, preserving, or storage agent, if the addition of the agent does not raise new 
clinical safety concerns with respect to the bone marrow); 
(5) Ancillary products used in the manufacture of HCT/P; 
(6) Cells, tissues, and organs derived from animals other than humans; and 
(7) In vitro diagnostic products as defined in  809.3(a) of this chapter. 
(8) Blood vessels recovered with an organ, as defined in 42 CFR 121.2, that are intended for use in organ 
transplantation and labeled "For use in organ transplantation only. 
 
The criteria listed in  1271.10(a): 
(1) The HCT/P is minimally manipulated; 
(2) The HCT/P is intended for homologous use only, as reflected by the labeling, advertising, or other 
indications of the manufacturer's objective intent; 
(3) The manufacture of the HCT/P does not involve the combination of the cells or tissues with another article, 
except for water, crystalloids, or a sterilizing, preserving, or storage agent, provided that the addition of water, 
crystalloids, or the sterilizing, preserving, or storage agent does not raise new clinical safety concerns with 
respect to the HCT/P; and 
(4) Either: 
(i) The HCT/P does not have a systemic effect and is not dependent upon the metabolic activity of living cells 
for its primary function; or 
(ii) The HCT/P has a systemic effect or is dependent upon the metabolic activity of living cells for its primary 
function, and: 
(a ) Is for autologous use; 
(b ) Is for allogeneic use in a first-degree or second-degree blood relative; or 
(c) Is for reproductive use. 
  8  Contains Nonbinding Recommendations 
 
 
Implantable device 
 
A device that is intended to be placed in a surgically or naturally formed cavity of the human 
body. A device is regarded as an implantable device for the purpose of this part only if it is 
intended to remain implanted continuously for a period of 30 days or more, unless the 
Commissioner of Food and Drugs determines otherwise in order to protect human health. 21 
CFR 801.3. 
 
Issuing agency 
 
An organization accredited by FDA to operate a system for the issuance of unique device 
identifiers. 21 CFR 830.3. 
 
Label 
 
A display of written, printed, or graphic matter upon the immediate container of any article; 
and a requirement made by or under authority of this Act that any word, statement, or other 
information appear on the label shall not be considered to be complied with unless such 
word, statement, or other information also appears on the outside container or wrapper, if any 
there be, of the retail package of such article, or is easily legible through the outside container 
or wrapper. 21 CFR 801.3 citing 21 USC 321(k). 
 
Labeler 
 
(1) Any person who causes a label to be applied to a device with the intent that the device 
will be commercially distributed without any intended subsequent replacement or 
modification of the label; and 
(2) Any person who causes the label of a device to be replaced or modified with the in-tent 
that the device will be commercially distributed without any subsequent replacement or 
modification of the label, except that the addition of the name of, and contact information for, 
a person who distributes the device, without making any other changes to the label, is not a 
modification for the purposes of determining whether a person is a labeler. 21 CFR  801.3. 
 
Lot or batch 
 
One or more finished devices that consist of a single type, model, class, size, composition, or 
software version manufactured under essentially the same conditions and that are intended to 
have uniform characteristics and quality within specified limits. 21 CFR  801.3. 
 
Production Identifier (PI) 
 
A conditional, variable portion of a UDI that identifies one or more of the following when 
included on the label of the device: 
(i) The lot or batch within which a device was manufactured; 
(ii) The serial number of a specific device; 
  9  Contains Nonbinding Recommendations 
 
 
(iii) The expiration date of a specific device; 
(iv) The date a specific device was manufactured; 
(v) For an HCT/P regulated as a device, the distinct identification code required by 21 CFR 
1271.290(c) of this chapter. 21 CFR  801.3. 
 
Unique Device Identifier (UDI) = Device Identifier (DI) + Production Identifier (PI) 
 
Shipping container 
 
A container used during the shipment or transportation of devices, and whose contents may 
vary from one shipment to another. 21 CFR  801.3. 
 
Small business 
 
A medical device manufacturer with 500 or fewer employees, or a medical device relabeler or 
repackager with 100 or fewer employees. 21 CFR  830.3. 
 
Specification 
 
Any requirement with which a device must conform. 21 CFR  801.3. 
 
Unique Device Identifier (UDI) 
 
An identifier that adequately identifies a device through its distribution and use by meeting 
the requirements of 21 CFR 830.20 of this chapter. A unique device identifier is composed of 
a (1) device identifier and (2) production identifier.2 21 CFR  801.3 
 
Universal Product Code (UPC) 
 
The product identifier used to identify an item sold at retail in the United States. 21 CFR  
801.3. 
 
Version or model 
 
All devices that have specifications, performance, size, and composition, within limits set by 
the labeler. 21 CFR  801.3. 
 
                                                           
2  830.20 - A unique device identifier (UDI) must: 
(a) Be issued under a system operated by FDA or an FDA-accredited issuing agency; 
(b) Conform to each of the following international standards: 
(1) ISO/IEC 15459-2, which is incorporated by reference at  830.10; 
(2) ISO/IEC 15459-4, which is incorporated by reference at  830.10; and  [*58826]  
(3) ISO/IEC 15459-6, which is incorporated by reference at  830.10. 
(c) Use only characters and numbers from the invariant character set of ISO/IEC 646, which is incorporated by 
reference at  830.10. 
  10  Contains Nonbinding Recommendations 
 
 
V.   UDI Final Rule 
 
A.   Requirement to bear a UDI label  
 
The UDI Rule requires a UDI on every device label and package.  There are general 
exceptions to this requirement which are explained in Section V.E.1.3 Each UDI must be in 
both easily readable plain-text and in a form that uses automatic identification and data 
capture (AIDC) technology.   We explain this more in Section V.B.1. 
 
The labeler has the responsibility for complying with the UDI label, data submission, and 
records requirements.  Therefore, it is important to determine whether you fit the definition of 
labeler.  The definition of labeler is included in Section IV.  In most instances, the device 
manufacturer is the labeler.  But this is not always the case.  For example, if you 
remanufacture and place a new label on a device, you are a labeler for purposes of the UDI 
Rule.  
 
1.  Device Identifier and Production Identifier 
 
(UDI = DI + PI) 
 
A UDI typically comprises both a device identifier (DI) and a production identifier (PI).  
These terms are defined in Section IV.  However the UDI of a class I device is not required to 
include a PI.  
  
a.  Device Identifier 
 
The device identifier (DI) is a mandatory, fixed portion of the UDI that identifies (1) you as 
the labeler, and (2) the specific model or version of your device.  The DI is used to look up 
information about the device in the database administered by FDA called the GUDID.  The 
GUDID is discussed further in Section V.D.  
 
Each DI is used to identify only one version or model.  You must assign a new DI if you 
change a device so that it becomes a new version or model.  Also, if you create a new device 
package such as a new package configuration or another packaging level, you must assign a 
new DI to that new package.  Keep in mind, you as the labeler, and not FDA, decides what is 
a separate version or model of your device for purposes of requiring a DI. 
 
If you discontinue a version or model of a device, you may not reassign the DI to another 
device.  If you reintroduce a discontinued version or model of a device, you may use the DI 
assigned to that particular version or model of the device at the time that you discontinued it. 
                                                           
3 If you do not fit within one of the general exceptions, Section V.E.2  explains how to request a specific 
exception or alternative. 
  11  Contains Nonbinding Recommendations 
 
 
 
b.  Production Identifier (PI) 
 
A production identifier (PI) is a conditional, variable portion of the UDI.  If you have 
included any of following information in your device label, that information must also be 
included in the PI portion of the UDI:  
 
(a) The lot or batch within which a device was manufactured; 
(b) The serial number of a specific device; 
(c) The expiration date of a specific device; 
(d) The date a specific device was manufactured. 
(e) For an HCT/P regulated as a device, the distinct identification code required by 21 
CFR  1271.290(c). 
 
For ease of use, this type of information is referred to as PI.  Please note: any identifiers 
beyond those five listed above are outside the scope of the FDA-regulated UDI.  
 
2.  Voluntary Labeling of Device with UDI (21 CFR 801.35) 
 
If your device is not required to have a UDI, you may still voluntarily comply with UDI 
requirements, including label and data submission requirements.  If you voluntarily comply 
with the UDI label requirements, you are not required to submit data to the GUDID, but you 
may volunteer to do so. 
 
3.  In Vitro Diagnostic Products (21 CFR 801.119) 
 
In vitro diagnostic products must comply with both UDI label requirements and the label 
requirements in 21 CFR 809.10. 
 
4.  Discontinuation of legacy FDA identification numbers 
assigned to medical devices (NHRIC and NDC numbers) 
  (21 CFR 801.57) 
 
If your device has a National Health-Related Item Code (NHRIC) or National Drug Code 
(NDC) assigned to it, and a UDI is also required, the NHRIC or NDC will be rescinded on 
the devices UDI compliance date (see Section VI for compliance dates). As of the UDI 
compliance date, you may no longer put a NHRIC or NDC number on your device label or 
package.   
 
If your device is not required to bear a UDI, any NHRIC or NDC assigned to it will be 
rescinded on September 24, 2018, and you will not be permitted to put the NHRIC or NDC 
on the device label or package. 
 
  12  Contains Nonbinding Recommendations 
 
 
 
 
Figure 1 UDI Label.  This is for illustration purposes only 
 
 
B.  UDI Label Requirements 
 
1.  Form of a UDI (21 CFR 801.40) 
 
Every UDI must be presented in two forms:  
 
(1) Easily readable plain-text, and 
(2) Automatic identification and data capture (AIDC) technology.  If the AIDC 
technology is not evident upon visual examination of the label or package, the label or 
package must disclose the presence of the AIDC technology.   
 
If your device is class I, you may use a Universal Product Code (UPC) to serve as the UDI on 
the device label and package. In addition, the UDI on your class I devices are not required to 
include a PI. 
 
2.  Technical Requirements for a UDI (21 CFR 830.20) 
 
There are very specific technical requirements for UDIs. FDA-accredited issuing agencies 
(IAs) are required to issue UDIs that conform to the following ISO standards (FDA-
accredited issuing agency is explained in detail in Section V.C.):  
 
(a) ISO/IEC 15459-2:2006(E), Information technology--Unique identifiers--Part 2: 
Registration procedures (second edition; March 1, 2006); 
(b) ISO/IEC 15459-4:2008(E), Information technology--Unique identifiers--Part 4: 
Individual items (second edition; July 15, 2008); and  
  13  Contains Nonbinding Recommendations 
 
 
(c) ISO/IEC 15459-6:2007(E), Information technology--Unique identifiers--Part 6: 
Unique identifier for product groupings (first edition; June 15, 2007). 
 
The UDI may use only characters and numbers from the invariant character set of ISO/IEC 
646:1991(E), Information technology--ISO 7-bit coded character set for information 
interchange (third edition; December 15, 1991). 
 
3.  Format for Dates Provided on a Label (21 CFR 801.18) 
 
If your device label includes a printed expiration date, date of manufacture, or any other date 
that you intend to be brought to the attention of the user, the dates must be presented in a 
specified format that is consistent with international standards and international practice.  
This format is: the year, using four digits: followed by the month, using two digits; followed 
by the day, using two digits; each separated by hyphens.  For example, January 2, 2014, must 
be presented as 2014-01-02.   
 
There are some limited exceptions pertaining to combination products and radiation emitting 
products that are listed in 21 CFR 801.18(b). 
 
4.  Permanent UDI (21 CFR 801.45) 
 
If your device is intended to be used more than once and intended to be reprocessed before 
each use, your device must have the UDI permanently marked on the device itself.  This 
permanent UDI may be identical to the UDI that appears on the device label, or it may be a 
different UDI to distinguish the device itself from its packaging.  The permanent UDI must 
be in either or both (1) easily readable plain-text and (2) AIDC form or alternative technology 
that will provide the UDI of the device on demand. 
The permanent UDI requirement does not apply if your device that is intended to be used 
more than once and intended to be reprocessed before each use meets any of the following 
criteria: 
(1) Any type of direct marking would interfere with the safety and effectiveness of the 
device; 
(2) It is not technologically feasible to directly mark the device; 
(3) The device is cleared/approved as a single use device; or 
(4) The device already has a permanent UDI directly marked on the device. 
 
If you decide to make use of one of these exceptions, the basis of your decision must be 
documented in the design history file required by 21 CFR 820.30(j). 
 
5.  Stand Alone Software (21 CFR 801.50) 
 
There are no UDI special requirements for a device that contains software as a component of 
the device, but stand-alone software must be labeled with a UDI.  If your stand-alone 
software is distributed in packaged form, it is subject to the same UDI labeling requirements 
  14  Contains Nonbinding Recommendations 
 
 
as any other medical device -- the device label and device package must bear a UDI in plain-
text and AIDC formats.  All stand-alone software, regardless of whether it is or is not 
distributed in packaged form, that is regulated as a medical device must provide its unique 
device identifier through either or both of the following: 
(1) An easily readable plain-text statement displayed whenever the software is started, 
and/or 
(2) An easily readable plain-text statement displayed through a menu command (e.g., an 
About * * * command). 
 
Stand-alone software that is not distributed in packaged form (e.g., when downloaded from a 
Web site) must also convey the version number in its production identifier. 
 
Stand-alone software that is distributed in both packaged form and in a form that is not 
packaged may be identified with the same DI.   
 
C.  Issuing Agency 
 
You are required to use a UDI system operated by a FDA-accredited issuing agency (IA).  
An IA may charge a labeler a fee for use of the IA for the issuance of UDIs.  Each IA 
operates a system for assignment of UDIs that meets the requirements listed in Section 
V.B.2.  An IA makes available information concerning its system for assigning UDIs, 
maintains a list of labelers that use its system for the assignment of UDIs, provides an 
annual list of labelers to FDA, and upon request provides us with information on a labeler 
that employs the IAs system for assigning UDIs. 
 
We accredit IAs.  The eligibility and accreditation criteria are set out in 21 CFR 830.100.  
A private organization may apply for accreditation.  We may accredit an organization if 
the system employed by the organization will (1) conform with the ISO standards listed in 
Section V.B.2.of this document, (2) be available to all users according to a single set of 
consistent, fair, and reasonable terms and conditions and (3) protect against conflicts of 
interests between the organization and labelers.  
 
The procedure for FDA initial accreditation and renewal is outlined in 21 CFR 830.110.  
The initial term of accreditation is three years with renewal terms of seven years.  We 
may suspend or revoke an IAs accreditation if we find that the IA was guilty of fraud in 
obtaining its accreditation, failed to fulfill the responsibilities required by the UDI Rule, 
failed to protect against conflicts of interest or has engaged in anticompetitive activity, or 
has violated the UDI Rule or related regulation.  
 
Under 830.200, under certain conditions, FDA may act as an IA. These conditions 
include (1) any period where these is no accredited IA, (2) when we determine that a 
significant number of small businesses would be substantially and adversely affected by 
the fees required by all accredited IAs, (3) when we determine that it is necessary for the 
continuation of the UDI system, or (4) when we determine it is appropriate to facilitate or 
  15  Contains Nonbinding Recommendations 
 
 
implement an alternative granted under 21 CFR 801.55.  When we act as an IA, any 
labeler may use our IA services, not only small businesses. 
 
If your IA relinquishes or does not renew its accreditation, you may continue to use the 
previously assigned DI until the UDI Rule otherwise requires a new DI to be assigned (e.g. a 
change in version or model).  
 
D.  GUDID data submission requirements 
 
In general, if a UDI is required for your device or device package, you are also required to 
submit the information described below to the GUDID electronically.  You may obtain a 
waiver from electronic submission by submitting a letter requesting a waiver addressed to the 
CDRH or CBER Center Director at the address listed on the front page of this document.  If 
you have already been granted a waiver from electronic submission of 21 USC 510(p) 
registration and listing information, you are automatically waived from UDI electronic 
submission.  If granted a waiver from electronic submission, you must submit the required 
information by letter as described in 21 CFR 830.320(c)(3). 
 
1.  Information required (21 CFR 830.310) 
 
a.  Concerning the labeler 
 
You must designate one individual to serve as the point of contact with FDA on matters 
relating to the identification of medical devices marketed by you.  This individual may 
authorize an IA or other person to submit information to us.  The contact individual (or other 
authorized person) shall submit your name and contact information, and the IA(s) you use for 
issuance of UDIs to the GUDID. 
 
b.  Concerning each version or model of a device 
 
For each version or model of a device required to have a UDI on its label, you must submit 
the following information to the GUDID: 
 
1.  The device identifier portion of the UDI assigned to the version or model; 
2.  When reporting a substitution of a new device identifier, the device identifier that was 
previously assigned to the version or model; 
3.  If the device is required to bear a permanent UDI on the device itself, either: 
i.  A statement that the device identifier that appears as a permanent marking on 
the device is identical to that reported under paragraph (b)(1) of this section, 
or 
ii.  The device identifier portion of the UDI that appears as a permanent marking 
on the device; 
4.  The proprietary, trade, or brand name of the device as it appears on the label of the 
device; 
  16  Contains Nonbinding Recommendations 
 
 
5.  Any version or model number or similar reference that appears on the label of the 
device; 
6.  If the device is labeled as sterile, a statement to that effect; 
7.  If the device is labeled as containing natural rubber latex that contacts humans, or is 
labeled as having packaging containing natural rubber latex that contacts humans, a 
statement to that effect; 
8.  Whether a patient may be safely exposed to magnetic resonance imaging, nuclear 
magnetic resonance imaging, or magnetic resonance tomography while using the 
device, or while the device is implanted in the patient. 
9.  If the device is available in more than one size, the size of the particular version or 
model, together with the unit of measure, as it appears on the label of the device; 
10. The type of PI that appears on the label of the device; 
11. The FDA premarket submission number of a cleared or approved device, or a 
statement that FDA has by regulation exempted the device from premarket 
notification; 
12. The FDA listing number assigned to the device; 
13. The Global Medical Device Nomenclature (GMDN) term or code for the device; and 
14. The total number of individual devices contained in the device package. 
 
2.  Rejection, removal or correction 
 
a.  FDA rejection or removal of submitted information 
 
If you submit device identification data that: does not conform with UDI requirements; 
concerns a device or combination product that requires, but does not have premarket 
approval, licensure or clearance; concerns a device that is neither manufactured nor in 
interstate commerce in the United States; the product is not a device or does not contain a 
device; or concerns a device that we have banned, we may reject or delete that information 
from GUDID.  We may also reject or remove any device identification data if we have 
suspended the accreditation of the IA that you use. This does not apply if the IA relinquishes 
or does not renew its accreditation.  This is explained further in Section V.C..  
 
b.  Correction (21 CFR 830.350) 
 
We may notify you and delete or correct any information submitted to the GUDID that 
appears to be incorrect or potentially misleading.  You must provide corrected information, or 
explain why the information is correct, within 30 days from receipt of our notice.  
 
E.  Exceptions and Alternatives to the UDI Requirement 
 
1.  General Exceptions (21 CFR 801.30) 
 
The following types of devices are excepted from the UDI labeling requirement in 21 CFR 
801.20. 
  17  Contains Nonbinding Recommendations 
 
 
 
Description of  Exception  Additional Information 
Device 
Category 
Finished  Manufactured and labeled prior to the  This exception expires 
Device  compliance date established by FDA for  with regard to a particular 
Section 801.20 regarding the device.  device 3 years after the 
compliance date 
established by FDA for 
the device. 
Class I GMP  Class I devices, exempted by FDA from the   
Exempt  good manufacturing practice requirements of 
Device  part 820 of this chapter, exclusive of any 
continuing requirement for recordkeeping 
under Sections 820.180 and 820.198. 
Individual  Distributed together all of a single version or  The device package 
Single-Use  model in a single device package, intended to  containing these 
Devices  be stored in that device package until removed  individual devices is not 
for use, and which are not intended for  excepted from UDI 
individual commercial distribution.  labeling requirements. 
Device used  Not intended for clinical use.   
solely for 
research, 
teaching, or 
chemical 
analysis 
Custom   As defined in  Section 812.3.4   
Device 
Investigational  As defined in  Section 812.3.5   
Device 
Veterinary  Not intended for use in the diagnosis of disease   
Medical  or other conditions in man, in the cure, 
                                                           
4 As per  812.3(b), custom device means a device that: 
(1) Necessarily deviates from devices generally available or from an applicable performance standard or 
premarket approval requirement in order to comply with the order of an individual physician or dentist; 
(2) Is not generally available to, or generally used by, other physicians or dentists; 
(3) Is not generally available in finished form for purchase or for dispensing upon prescription; 
(4) Is not offered for commercial distribution through labeling or advertising; and 
(5) Is intended for use by an individual patient named in the order of a physician or dentist, and is to be made in 
a specific form for that patient, or is intended to meet the special needs of the physician or dentist in the course 
of professional practice. 
 
5 As per  812.3(g), investigational device means a device, including a transitional device, which is the object of 
an investigation. 
  18  Contains Nonbinding Recommendations 
 
 
Device  mitigation, treatment, or prevention of disease 
in man, or intended to affect the structure or 
any function of the body of man. 
Exported  Intended for export from the United States.   
Device   
Strategic  Held by the Strategic National Stockpile and   
National  granted an exception or alternative under 
Stockpile  Section 801.128(f)(2). 
Performance  This exception applies if the performance   
standard  standard established by FDA provides an   
established by  exception from the requirement of Section 
FDA under  801.20 or includes an exception from the 
section 514(b)  requirement of section 801.20 within the scope 
of the Federal  of that recognition. 
Food, Drug, 
and Cosmetic 
Act 
Packaged  Label of the combination product or   
device within  convenience kit bears a UDI. 
the immediate 
container of a 
combination 
product or 
convenience 
kit 
Combination  Bears a National Drug Code (NDC) number on  Each device constituent of 
Product  its label.  a combination product, 
other than one described 
by Section 3.2(e)(1), must 
bear a UDI.6 
Shipping  UDI not required to be placed on shipping   
Container  containers. 
 
 
2.  Requesting a Specific Exception or Alternative (21 CFR 
801.55) 
 
                                                           
6 21 CFR 3.2(e)(1) provides that a combination product includes: 
(1) A product comprised of two or more regulated components, i.e., drug/device, biologic/device, drug/biologic, 
or drug/device/biologic, that are physically, chemically, or otherwise combined or mixed and produced as a 
single entity; 
 
  19  Contains Nonbinding Recommendations 
 
 
You may submit a request for a specific exception from or alternative to the UDI labeling 
requirement or any other requirement of the UDI Rule.   
 
The written request must: 
 
1.  Identify the device or devices that would be subject to the exception or 
alternative; 
2.  Identify the provisions of 21 CFR Part 801 Subpart B that are the subject of 
the request for an exception or alternative; 
3.  If requesting an: 
 
Exception  Explain why you believe the requirements of 21 CFR Part 801 Subpart B are 
not technologically feasible 
Alternative  Describe the alternative and explain why it would provide for more accurate, 
precise, or rapid device identification than the requirements of 21 CFR Part 
801 Subpart B or how the alternative would better ensure the safety or 
effectiveness of the device subject to the alternative; 
 
 
4.  Provide, if you know, the number of labelers and the number of the devices 
that would be affected were we to grant the requested exception or alternative; and 
5.  Provide other information that we request to clarify the scope and effects of 
the requested exception or alternative. 
 
Send the written request for an exception or alternative to: 
 
Device regulated  Email  Mailing Address 
by: 
Center for Biologics  cberudirequests@fda.hhs.gov   Center for Biologics Evaluation and 
Evaluation and  Research, FDA,  Document Control 
Research (CBER)  Center, 10903 New Hampshire 
Avenue, Bldg. 71, Rm. G112,  Silver 
Spring, MD 20993-0002 
 
All other devices  udi@fda.hhs.gov  UDI Regulatory Policy Support, 
CDRH, FDA, Bldg. 66, Rm. 3303, 
10903 New Hampshire Avenue, Silver 
Spring, MD 20993-002 
 
F.  Modifications to other 21 CFR Provisions 
 
The UDI Rule modifies additional sections of 21 CFR so that other 21 CFR provisions 
remain consistent with the provisions, definitions, and language of the UDI Rule.  The below 
  20  Contains Nonbinding Recommendations 
 
 
chart describes modifications made by the UDI Rule to other CFR sections that have not 
otherwise been mentioned in this Guidance. 
 
The UDI requirements that affect other sections of 21 CFR went into effect on December 23, 
2013. But there is no practical effect until the other provisions must be complied with. (See 
Section VI - Compliance Dates). For example, the amendments to Parts 820 and 822 will 
have no practical effect until September 24, 2014, when class III devices become subject to 
UDI labeling requirements. 
  21  Contains Nonbinding Recommendations 
 
 
Section  Modification 
Modified 
803.32  User facilities must include the UDI on the device label or on the device 
package in individual adverse event report submissions. 
803.33  User facility must submit in annual reports the UDI that appears on the device 
label or device package.   
803.42  Importers must include the UDI on the device label or on the device package in 
individual adverse event report submissions. 
803.52  Manufacturers must include the UDI on the device label or on the device 
package in individual adverse event report submissions. 
806.10  The manufacturer or importer must include on reports of corrections and 
removals: the UDI that appears on the device label or on the device package, or 
the device identifier, universal product code (UPC), model, catalog, or code 
number of the device and the manufacturing lot or serial number of the device 
or other identification number. 
806.20  Records of corrections and removals not required to be reported to FDA shall 
contain the UDI, or the device identifier, UPC, model, catalog, or code number 
of the device and the manufacturing lot or serial number of the device or other 
identification number. 
810.10  FDA will include the UDI that appears on the device label or on the device 
package in its cease distribution and notification order. 
814.84  The holder of an approved pre-market approval shall identify in its periodic 
report each device identifier currently in use for the device, and each device 
identifier for the device that has been discontinued since the previous periodic 
report.    
820.120  Labeling shall not be released for storage or use until a designated individual(s) 
has examined the labeling for accuracy including, where applicable, the correct 
UDI or UPC, expiration date, control number, storage instructions, handling 
instructions, and any additional processing instructions. 
820.184  Device history records must include any UDI or UPC, and any other device 
identification(s) and control number(s) used. 
820.198  Manufacturers must include in their complaint files any UDI or UPC, and any 
other device identification(s) and control number(s) used. 
820.200  Service reports that represent an event that must be reported to FDA must 
include any UDI or UPC and any other device identification(s) and control 
number(s) used. 
821.25  A manufacturer of a tracked device must include the UDI, lot number, batch 
number, model number, or serial number of the device or other identifier 
necessary to provide for effective tracking of these devices. 
821.30  Persons other than device manufacturers and distributors must include the UDI, 
lot number, batch number, model number, or serial number of the device or 
other identifier used by the manufacturer to track the device. 
822.9  Class II and III device manufacturers required to conduct postmarket 
surveillance must include both premarket application/submission number and 
  22 
device identifiers in the postmarket surveillance plan submission.  Contains Nonbinding Recommendations 
 
 
 
 
 
VI.  Compliance Dates 
 
 
Device  Label/GUDID/Date Format  Direct Mark 
(When Required)3 
Class III  September 24, 2014  Class III LS/LS devices must bear a 
(including class III  permanent UDI by September 24, 
LS/LS)1  2015 
Devices licensed  All other class III devices must bear a 
under the PHS  permanent UDI  by September 24, 
Act  2016 
Implantable  September 24, 2015  N/A 
(class II, class I & 
unclassified) 
LS/LS1 (class II,  September 24, 2015   September 24, 2015 
class I & 
unclassified) 
Class II (other  September 24, 2016  September 24, 2018 
than I/LS/LS2) 
Class I or  September 24, 2018  September 24, 2020 
unclassified 
(other than 
I/LS/LS2) 
1LS/LS = life-supporting or life-sustaining 
2I/LS/LS = implantable, life-supporting, or life-sustaining   
3Direct Mark requirements apply to products that are intended to be used more than once 
and intended to be reprocessed before each use.  Direct mark compliance dates are in 
addition to label/GUDID/date format compliance dates. 
 
  23