Child-Resistant 
Packaging Statements 
in Drug Product 
Labeling 
 
Guidance for Industry 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
Center for Biologics Evaluation and Research (CBER) 
 
August 2019 
Labeling 
17266044 FNL  Contains Nonbinding Recommendations 
 
Child-Resistant 
Packaging Statements 
in Drug Product 
Labeling 
 
 
 
Guidance for Industry 
 
 
Additional copies are available from: 
Office of Communications, Division of Drug Information  
Center for Drug Evaluation and Research 
Food and Drug Administration 
10001 New Hampshire Ave., Hillandale Bldg., 4th Floor  
Silver Spring, MD 20993-0002  
Phone: 855-543-3784 or 301-796-3400; Fax: 301-431-6353 
Email: druginfo@fda.hhs.gov  
http://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm 
and/or 
Office of Communication, Outreach and Development  
Center for Biologics Evaluation and Research 
 Food and Drug Administration 
10903 New Hampshire Ave., Bldg. 71, Room 3128 
Silver Spring, MD 20993-0002 
Phone: 800-835-4709 or 240-402-8010 
Email: ocod@fda.hhs.gov 
http://www.fda.gov/BiologicsBloodVaccines/GuidanceComplianceRegulatoryInformation/Guidances/default.htm    
 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Drug Evaluation and Research (CDER) 
Center for Biologics Evaluation and Research (CBER) 
 
August 2019 
Labeling 
  Contains Nonbinding Recommendations 
 
 
TABLE OF CONTENTS 
 
 
 
I.  INTRODUCTION............................................................................................................. 1 
II.  DISCUSSION .................................................................................................................... 2 
III.  LABELING ....................................................................................................................... 3 
A.  Prescription Drug Products .......................................................................................................... 4 
1. Prescribing Information................................................................................................................... 4 
2. Patient Information .......................................................................................................................... 4 
3. Carton Labeling and Container Labels ........................................................................................... 5 
B.  Nonprescription Drug Products ................................................................................................... 5 
1. Drug Facts Labeling ........................................................................................................................ 5 
2. Carton Labeling and Container Labels ........................................................................................... 6 
IV.  PROCESS FOR INCLUDING STATEMENTS REGARDING CRP ON THE 
LABELING ........................................................................................................................... 6 
A.  Prescription Drug Products and Nonprescription Drug Products Approved Under an 
Application ...................................................................................................................................... 6 
1. Original NDA, BLA, or ANDA submission ...................................................................................... 6 
2. Postapproval Change....................................................................................................................... 6 
B.  Nonprescription Drug Products Marketed Under the OTC Drug Review............................... 7 
  Contains Nonbinding Recommendations 
 
Child-Resistant Packaging Statements in Drug Product Labeling 
Guidance for Industry1 
 
 
This guidance represents the current thinking of the Food and Drug Administration (FDA or Agency) on 
this topic.  It does not establish any rights for any person and is not binding on FDA or the public.  You 
can use an alternative approach if it satisfies the requirements of the applicable statutes and regulations.  
To discuss an alternative approach, contact the FDA office responsible for this guidance as listed on the 
title page.   
 
 
 
I.  INTRODUCTION  
 
This guidance is intended to assist applicants, manufacturers, packagers, and distributors 
(collectively referred to as firms) who choose to include child-resistant packaging (CRP) 
statements in their drug product2 labeling.  The guidance discusses what information should be 
included to support CRP statements in labeling for new drug applications (NDAs), abbreviated 
new drug applications (ANDAs), biologics license applications (BLAs), and supplements to 
these applications.  In addition to recommendations for labeling of prescription drug products, 
this guidance also includes recommendations for labeling both for nonprescription drug 
products3 approved under an NDA or ANDA and those that are marketed under the Over-the-
Counter (OTC) Drug Review.4  This guidance is intended to help ensure that such labeling is 
clear, useful, informative, and, to the extent possible, consistent in content and format.5 
 
In general, FDAs guidance documents do not establish legally enforceable responsibilities.  
Instead, guidances describe the Agencys 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 Agency guidances means that something is suggested or recommended, but 
not required.  
 
   
                                                 
1 This guidance has been prepared by the Center for Drug Evaluation and Research and the Center for Biologics 
Evaluation and Research at the Food and Drug Administration.  
2 References to drugs and biological products include drugs approved under section 505 of the Federal Food, Drug, 
and Cosmetic Act (FD&C) and biological products licensed under section 351 of the Public Health Service Act 
(PHSA) that are drugs.  For the purposes of this guidance, drug product or drug will be used to refer to human 
prescription drug and biological products that are regulated as drugs. 
3 For the purposes of this guidance, the term nonprescription drug products refers to over-the-counter (OTC) drug 
products. 
4 See 21 CFR 330-358. 
5 This guidance is intended to apply to FDA-regulated drug products that bear CRP statements, regardless of 
whether CRP is required for such products under 16 CFR 1700.  For example, bulk packages of prescription drugs 
that are shipped to pharmacies for repackaging by a pharmacist are not required to utilize CRP, but a firm may 
nevertheless choose to use CRP (and a CRP statement) for such drugs.  16 CFR 1701.1.  
  1 
  Contains Nonbinding Recommendations 
 
II.  DISCUSSION 
 
In 1970, the Poison Prevention Packaging Act (PPPA) was enacted to protect children (under 5 
years of age) from unintentional exposure to household substances including food, drugs, and 
cosmetics.6  Under the Federal Food, Drug, and Cosmetic Act (FD&C Act), a drug that has 
packaging or labeling that is in violation of a regulation issued pursuant to section 3 or 4 of the 
PPPA is deemed to be misbranded.7  FDA was responsible for enforcing the PPPA until 1973, 
when jurisdiction was transferred to the U.S. Consumer Product Safety Commission (CPSC).8    
Because of FDAs authority to regulate labeling for prescription and nonprescription drug 
products, if firms choose to make statements in their labeling for such products about child-
resistant packaging, such statements must comply with FDAs statutory and regulatory 
requirements.9 
 
CPSCs regulations list special packaging standards10,11 (also referred to herein as child-
resistant packaging, or CRP) for a wide range of household products, including most oral 
prescription drugs and many nonprescription drug products.12  There are different ways to make 
packaging child-resistant, with the most common forms being a child-resistant closure (e.g., a 
safety cap) and certain unit-dose blister packaging (e.g., puncture-resistant and peel-push 
blisters.  It should be noted that child-resistant should not be equated with child-proof, 
because CRP is not designed to completely eliminate the possibility of an accidental pediatric 
ingestion.  It can only impede access to harmful products and is recognized by public health 
experts as only one component of preventing these events.  Therefore, FDA advocates that all 
drugs, irrespective of the type of packaging, be stored safely out of reach and sight of children to 
further the overall public health efforts to address this safety issue.   
 
FDA regulates certain aspects of drug products container closure systems related to safety and 
efficacy as part of the drug application review and approval process.13,14  During FDAs review 
of an NDA, ANDA, or BLA (and nonprescription drugs marketed under an application), data 
related to container closure systems are evaluated, such as the type of closure employed, the 
stability of the product in the container closure system, and whether the closure design is suitable 
for the product.  FDAs review does not include evaluation of testing reports to determine 
whether a product meets the applicable standards for special packaging set forth in the PPPA and 
its implementing regulations. 
                                                 
6 Poison Prevention Packaging Act of 1970 (PPPA), (Pub. L. 91-601, 84 Stat. 1670-74), enacted December 30, 
1970. 
7 See FD&C Act,  502(p). 
8 Consumer Product Safety Act, Public Law 92-573; 86 Stat. 1207, October 27, 1972, Sec. 30. 
9 See, e.g., FD&C Act  502(a), (c).   
10 See definitions in section 2 (4) of the PPPA. 
11 Special packaging and child-resistant packaging (CRP) are used interchangeably in this guidance. 
12 See 16 CFR 1700 for substances requiring special packaging and the relevant packaging standards and testing 
procedures. 
13 FDA generally does not regulate retail pharmacy vials or other containers used by pharmacies to repackage drugs 
to dispense to patients. 
14 See FDA guidance for industry Container Closure Systems for Packaging Human Drugs and Biologics, May 
1999.  This guidance is available on the Internet at 
https://www.fda.gov/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/default.htm under Guidances 
(Drugs). 
  2 
  Contains Nonbinding Recommendations 
 
 
With respect to nonprescription drug products marketed under the OTC Drug Review, FDA does 
not review data related to container closure systems, as applications for individual drug products 
under the OTC Drug Review are not submitted to FDA for review or approval.  In addition, 
although manufacturers of nonprescription products marketed under the OTC Drug Review must 
comply with the labeling requirements under 21 CFR 201.66, they are not required to submit 
labeling to FDA prior to marketing.   
 
In this guidance, we recommend text that may be appropriate to consider when including CRP 
statements in the prescribing information, in the patient information, on carton labeling and 
container labels for prescription drug products, and in the drug facts labeling and on carton 
labeling and container labels for nonprescription drug products.   
 
III.  LABELING 
 
Because health care professionals and consumers may not be able to determine on visual 
inspection whether packaging is child-resistant, a labeling statement may help to identify this 
attribute.  As a general matter, if a drug product is packaged using CRP and the firm elects to 
include labeling statements that identify the product as packaged with CRP, the CRP should be 
described using words and not abbreviations (e.g., CRP, CRC, or CR) or symbols because 
these abbreviations and symbols may not be readily understood.  Because it is important to 
clarify that CRP statements in labeling describe how the product is supplied from the 
manufacturer, versus how the product is dispensed by a pharmacist, the term supplied as 
opposed to available is preferred. 
 
Section 502(a) of the FD&C Act provides that a drug is deemed to be misbranded if its labeling 
is false or misleading in any particular.  In general, to ensure that CRP statements on labeling are 
not false or misleading, such statements should only be used when the drug product packaging 
has been shown to comply with CPSC regulatory standards and test procedures for CRP, as 
applicable.15,16  In addition, placement of CRP statements on the labeling must not interfere with 
required information on the labeling.17 
 
We provide additional recommendations for the labeling of prescription drug products and 
nonprescription drug products below.  
                                                 
15 See 16 CFR 1700.15 for poison prevention packaging standards and 16 CFR 1700.20 for special packaging testing 
procedures.  In order to make household substances that are subject to the PPPAs special packaging requirements 
readily available to elderly or handicapped persons who are unable to use those substances in special packaging, 
section 4(a) of the PPPA authorizes manufacturers and packers to package such substances in non-complying 
packaging of a single size provided that:  1) complying packaging is also supplied, and 2) the non-complying 
packages are conspicuously labeled to indicate that they should not be used in households where young children are 
present.  In order to comply with CPSC regulations, any non-complying packages a firm elects to market pursuant to 
section 4(a) of the PPPA must bear the labeling described in 16 CFR 1700.5. 
16 We note that if a product is subject to the special packaging requirements of the PPPA, but its packaging or 
labeling is in violation of applicable regulations issued pursuant to section 3 or 4 of the PPPA, it may also be 
misbranded under section 502(p) of the FD&C Act.    
17 See FD&C Act  502(c).   
  3 
  Contains Nonbinding Recommendations 
 
 
A.  Prescription Drug Products 
 
1.  Prescribing Information 
 
If a firm chooses to include information about CRP in the prescribing information, such 
information should appear in the HOW SUPPLIED/STORAGE AND HANDLING section as 
this is generally where practitioners look to ascertain information about a products packaging.  
It is important that the CRP statements be linked clearly to a particular package, especially when 
multiple packages are supplied and not all have been demonstrated to be child-resistant.   
 
Examples include the following: 
 
HOW SUPPLIED/STORAGE AND HANDLING 
 
  Drug X is supplied in 30 g, 4 oz tubes with a child-resistant cap. 
 
  Drug X is supplied as child-resistant sachets. 
 
  The 50 mg tablet is film-coated, round, biconvex, pink, scored, and is 
debossed with XXX on one side and scored on the other side. 
        Bottles of 30 with child-resistant closure, NDC xxxx-xxx-xx 
        Bottles of 60 with child-resistant closure, NDC xxxx-xxx-xx 
        Bottles of 500, NDC xxxx-xxx-xx 
 
2.  Patient Information 
 
If a firm chooses to include information about CRP for a prescription drug product whose 
commercial container bearing the CRP is designed to be dispensed directly to patients, the CRP 
information should be included in the patient labeling (e.g., medication guides, patient package 
inserts).  Information about the CRP in patient labeling should appear under a heading titled 
How should I store Drug X?  The description should be consistent with the CRP statement(s) 
included in the HOW SUPPLIED/STORAGE AND HANDLING section of the full prescribing 
information.  
 
Examples include the following: 
 
  Drug X comes in a child-resistant package.  
 
  Drug X comes in a sealed child-resistant foil pouch.  
 
The following statement should also appear at the end of the How should I store 
Drug X? section: 
 
  Keep Drug X and all medicines out of the reach of children.  
 
  4 
  Contains Nonbinding Recommendations 
 
3.  Carton Labeling and Container Labels  
 
If a firm chooses to include information about the CRP on carton labeling and container labels, it 
may do so as long as there is sufficient space to include such information in addition to 
information required to be included.18  If space permits, a firm may also include, in conjunction 
with the CRP statement, a statement to recommend that the package be kept out of reach of 
children, particularly for those packages which may be dispensed directly to patients.  Statements 
about CRP are most appropriately displayed on the side panels of the carton labeling and 
container labels in close proximity to storage information. 
 
Examples include the following: 
 
  This package is child-resistant.  Store at 20C-25C (68F-77F); excursions 
permitted to 15C-30C (59F-86F). 
 
  This package is child-resistant.  Keep out of reach of children.  Store at 
20C-25C (68F-77F); excursions permitted to 15C-30C (59F-86F). 
 
B.  Nonprescription Drug Products 
 
1.  Drug Facts Labeling 
 
FDA regulations do not specify where to place CRP statements on labeling for nonprescription 
drug products.  If firms choose to include the statement in the drug facts labeling (DFL), it 
should appear under the subheading Other information with the storage statement.19   Other 
information is the subheading used for certain information that is not included under the other 
DFL subheadings, including optional information.  A CRP statement would be considered to be 
optional Additional information20 under the Other information subheading and should 
follow any required statements. 
 
The following examples illustrate types of information considered to be other information, 
including a CRP statement: 
 
  Read the directions and warnings before use.  
  Keep the carton.  It contains important information.  
  This package is child-resistant. 
  Store at 20-25C (68-77F) and protect from moisture. 
 
   
                                                 
18 If the container label is too small, see 21 CFR 201.10(i). 
19 See  201.66(c)(7). 
20 See  201.66(c)(7)(iii). 
  5 
  Contains Nonbinding Recommendations 
 
2.  Carton Labeling and Container Labels 
 
Even if the CRP statement(s) are included in the DFL, their placement on the carton labeling 
and/or container labeling outside the DFL is optional.  Conversely, if the CRP statement is not 
included in the DFL, it is still permissible to include a CRP statement(s) on the carton labeling 
and/or the container labeling outside the DFL, space permitting.21  Appropriate text could read 
this package is child-resistant.  For small containers and/or cartons, appropriate text could read 
child-resistant package.  Although any available panel or part of a panel, outside the DFL, is 
appropriate for this use, consumers may find this information to be more useful if displayed on 
the principal display panel(s). 
 
IV.  PROCESS FOR INCLUDING STATEMENTS REGARDING CRP ON THE 
LABELING  
 
If firms choose to include CRP statements on their product labeling, they should verify in writing 
for FDA that the CRP meets the standards set forth by the CPSC in 16 CFR 1700, as applicable, 
as discussed below.22,23  FDA also recommends that firms retain the data demonstrating that the 
packaging meets applicable CPSC standards. 
 
A.  Prescription Drug Products and Nonprescription Drug Products Approved 
Under an Application 
 
1.  Original NDA, BLA, or ANDA submission 
 
In an original NDA, BLA, or ANDA submission, written verification that the CRP meets the 
CPSCs standards under 16 CFR 1700 should appear in the container closure section of Module 
3.2.P.7 Container Closure System (name, dosage form) of the Electronic Common Technical 
Document (eCTD).  An example of the written verification may be We verify in this submission 
that the following package (or packages) meet CPSCs standards under 16 CFR 1700. 
 
2.  Postapproval Change 
 
If there is a postapproval change to the package or labeling of a product approved under an 
NDA, BLA, or ANDA, refer to appropriate regulations and guidances to determine the 
appropriate pathway to implement these changes.24  Submissions for changes to add CRP 
statements on labeling should verify in writing that the CRP meets the CPSCs standards under 
16 CFR 1700 and the verification should appear in the detailed container closure description 
                                                 
21 In such circumstances, we encourage applicants to discuss their plans with FDA.  When the submission is for an 
NDA or BLA, contact the specific drug products review division with questions.  When the submission is for an 
ANDA, submit questions as a General Correspondence to the application. 
22 The written verification discussed in this guidance is intended for FDA only, and is separate from the certification 
required to be provided to CPSC under 15 USC 2063 and 16 CFR 1110. 
23 Firms should provide such written verification to FDA to support CRP statements even in circumstances where 
they have elected to use CRP for products that are not subject to the special packaging requirements of 16 CFR 
1700. 
24 See 21 CFR 314.70 and 601.12 for reporting requirements for changes to approved applications for drug products 
and licensed biological products. 
  6 
  Contains Nonbinding Recommendations 
 
section of Module 3.2.P.7 Container Closure System (name, dosage form) in the eCTD.  An 
example of the written verification may be We verify in this submission that the following 
package (or packages) meet CPSCs standards under 16 CFR 1700. 
 
B.  Nonprescription Drug Products Marketed Under the OTC Drug Review 
 
There is no defined process for submission of a written verification to FDA that a 
nonprescription drug product marketed under an OTC monograph meets CPSCs standards under 
16 CFR 1700.  However, if firms elect to include a CRP statement on the labeling of a 
nonprescription drug product marketed under an OTC monograph, they should retain the data 
demonstrating that the packaging meets applicable CPSC standards and follow the labeling 
recommendations in this guidance.  
 
  7