Guidance for Industry 

Providing Regulatory 

Submissions in Electronic 

Format – Drug Establishment 

Registration and Drug Listing 

U.S. Department of Health and Human Services 

Food and Drug Administration 

Office of the Commissioner 

 

May 2009 

Electronic Submission 

OMB Control No. 0910-0045 

Expiration Date: 3/31/2012 

See additional PRA statement in Section VII of this guidance
Contains Nonbinding Recommendations 

Guidance for Industry 

Providing Regulatory 

Submissions in Electronic 

Format – Drug Establishment 

Registration and Drug Listing 

Additional copies are available from: 

Office of Training and Communication 

Division of Drug Information, HFD-240 

Center for Drug Evaluation and Research 

Food and Drug Administration 

5600 Fishers Lane 

Rockville, MD 20857 

(Tel) 301-827-4573 

 http://www.fda.gov/cder/guidance/index.htm 

and/or 

 Office of Communication, Outreach and 

Development, HFM-40 

Center for Biologics Evaluation and Research 

 Food and Drug Administration 

1401 Rockville Pike, Rockville, MD 20852-1448 

 http://www.fda.gov/cber/guidelines.htm 

(Tel) 800-835-4709 or 301-827-1800

and/or 

Communications Staff, HFV-12 

Center for Veterinary Medicine 

Food and Drug Administration 

7500 Standish Place, 

Rockville, MD 20855 

(Tel) 240-276-9300 

http://www.fda.gov/cvm/guidance/guidance.htm 

U.S. Department of Health and Human Services 

Food and Drug Administration 

Office of the Commissioner 

May 2009 

Electronic Submission 
Contains Nonbinding Recommendations 

TABLE OF CONTENTS 

I. INTRODUCTION............................................................................................................. 1

II. BACKGROUND ............................................................................................................... 1

III. DRUG ESTABLISHMENT REGISTRATION AND DRUG LISTING 

INFORMATION FOR ELECTRONIC SUBMISSION ........................................................... 4

A. Drug Establishment Registration .................................................................................................4

1. Who must register, when, and how? ................................................................................................4

2. What information is submitted for drug establishment registration? ..............................................5

B. Drug Listing....................................................................................................................................6

1. Who must list, when, and how?........................................................................................................6

2. What information is submitted for drug listing?..............................................................................7

IV. CREATING THE DRUG ESTABLISHMENT REGISTRATION AND DRUG 

LISTING FILE FOR ELECTRONIC SUBMISSION .............................................................. 9

A. Structured Product Labeling ........................................................................................................9

B. Code Sets and Codes....................................................................................................................10

1. Unique Ingredient Identifiers (UNII).............................................................................................10

2. Data Universal Numbering System (D-U-N-S®) Number.............................................................10

3. Other code sets...............................................................................................................................11

C. Submission and FDA Validation of Electronic Drug Establishment Registration and Drug 

Listing Information ..............................................................................................................................11

D. Technical Assistance ....................................................................................................................12

V. IMPLEMENTATION .................................................................................................... 12

VI. WAIVER REQUEST...................................................................................................... 12

VII. PAPERWORK REDUCTION ACT OF 1995.............................................................. 13
Contains Nonbinding Recommendations 

Guidance for Industry1

Providing Regulatory Submissions in Electronic Format – 

Drug Establishment Registration and Drug Listing 

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 

This is one in a series of guidance documents intended to assist persons making regulatory 

submissions to FDA in electronic format. This guidance is designed to assist manufacturers with 

electronic submissions of drug establishment registration and drug listing information. The 

guidance and accompanying technical documents explain (among other things): 

• The statutory requirement to submit electronically drug establishment registration and 

drug listing information; 

• How to create a Structured Product Labeling (SPL)2

 file for submitting drug 

establishment registration and drug listing information to FDA through the Electronic 

Submissions Gateway (ESG) using defined code sets and codes, i.e., a language 

recognized by the computer system; and 

• Beginning June 1, 2009, FDA intends to no longer accept drug establishment registration 

and drug listing information in paper format unless a waiver is granted. 

FDA intends to update these documents regularly to reflect the evolving technology and user 

experience. 

FDA's guidance documents, including this guidance, do not establish legally enforceable 

responsibilities. Instead, guidances describe the Agency's 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. 

II. BACKGROUND 

 

1

 The Office of Critical Path Programs, Office of the Commissioner, Food and Drug Administration prepared this 

guidance document in cooperation with the Center for Drug Evaluation and Research, the Center for Biologics 

Evaluation and Research, and the Center for Veterinary Medicine. 

 

2

 SPL standard is a Health Level Seven, Inc. standard for the exchange of product information using extensible 

markup language (XML). 

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Contains Nonbinding Recommendations 

Requirements for drug establishment registration and drug listing are set forth in section 510 of 

the Federal Food, Drug, and Cosmetic Act (the Act) and section 351 of the Public Health Service 

Act (the PHS Act), and 21 CFR Part 207.3 Fundamental to FDA’s mission to protect the public 

health is the collection of this information, which is used for important activities such as 

postmarket surveillance for serious adverse drug reactions, inspection of drug manufacturing and 

processing facilities, and monitoring of drug products imported into the United States. 

Comprehensive, accurate, and up-to-date information is critical to conducting these activities 

with efficiency and effectiveness. 

Section 510 of the Act and 21 CFR part 207, subject to certain limited exceptions, require 

establishment owners and operators (registrants) upon first engaging in the manufacture, 

preparation, propagation, compounding, or processing of drugs, (including human drugs, 

veterinary drugs, and biological drug products4) to register their establishments and submit 

listing information for all drugs in commercial distribution. Registrants are also required to 

submit registration information for their establishments on or before December 31 of each year.5 

At the time of registration, registrants must also submit required listing information.6

Additionally, registrants are required to update listing information in June and December of each 

year to include information for drugs that have not been previously listed.7 Certain changes to 

information for previously listed drugs must also be submitted every June and December.8

 

Changes in the Act, resulting from the Food and Drug Administration Amendments Act of 2007 

(Public Law 110-85) (FDAAA),9 require that drug establishment registration and drug listing 

information be submitted electronically unless a waiver is granted. Before FDAAA was enacted, 

section 510(p) of the Act expressly provided that drug establishment registration information 

must be submitted electronically, based on a finding that electronic receipt was feasible, and 

section 510(j) of the Act stipulated that drug listing information must be submitted in the form 

and manner prescribed by FDA. Section 224 of FDAAA, which amends section 510(p) of the 

Act, now expressly requires drug listing information to be submitted by electronic means in 

addition to requiring electronic drug establishment registration. 

 

3

 This guidance document does not apply to establishment registration and product listing information required 

solely under 21 CFR part 607 (Blood and Blood Products), 21 CFR part 807 (Devices), and 21 CFR part 1271 

(Human Cells, Tissues, and Cellular and Tissue-Based Products). 

4 Under section 351(j) of the PHS Act, the Federal Food, Drug, and Cosmetic Act (and regulations promulgated 

thereunder) applies to biological drug products, except that New Drug Applications (NDAs) are not required for 

products licensed under section 351(a) of the PHS Act. 

5

 Section 510(b)(1) of the Act. 

6

 Section 510(j)(1) of the Act. 

7

 Section 510(j)(2)(A) of the Act. 

8

 Section 510(j)(2) of the Act. 

9

 Signed into law on September 27, 2007. 

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Contains Nonbinding Recommendations 

Drug establishment registration and drug listing information have, until now, been submitted 

using a paper-based format, i.e., Form FDA 2656 (Registration of Drug Establishment/Labeler 

Code Assignment), Form FDA 2657 (Drug Product Listing), and Form FDA 2658 (Registered 

Establishments’ Report of Private Label Distributors).10 Moving from a paper-based format to 

an electronic system will improve the timeliness and accuracy of the submissions. 

Prior to the amendment of the statute to require electronic submission of both drug listing and 

establishment registration information, FDA issued a proposed rule that would amend 21 CFR 

part 207 to require electronic submission of drug establishment registration and drug listing 

information, and that included proposals such as certain changes to the National Drug Code 

(NDC) system and requirements regarding placement of the appropriate NDC on the drug label 

(71 FR 51276, August 29, 2006). FDA is considering comments submitted on the proposed rule 

and intends to issue a final rule based on that proposal which will also serve to conform the 

regulations to the changes in section 510(p) mandating electronic submission. FDA intends to 

revise, reissue, or revoke this guidance document as appropriate to make it consistent with the 

final rule, when the rule is issued. 

To facilitate the submission of drug establishment registration and drug listing information 

(including labeling as specified under 21 CFR 207.25), FDA is adopting the use of extensible 

markup language (XML) files in a standard SPL format. The automated submission process 

functions most efficiently and effectively when this information is provided in a standardized 

format with defined code sets and codes. This guidance and accompanying technical documents 

describe how to make these submissions using the SPL format, which FDA can process, review, 

and archive.11 Information in a properly created and complete SPL file can facilitate processing 

and allows for greater precision and accuracy through the use of coded data fields rather than just 

electronic text. Receipt of timely and accurate information will enhance FDA’s efforts to help 

ensure the integrity of the drug supply and protect public health. 

Technical specifications for creation of the electronic files are provided in the following 

technical documents, which can be found on the FDA Data Standards Council website, 

http://www.fda.gov/oc/datacouncil/spl.html: 

• Structured Product Labeling Implementation Guide for FDA Drug Establishment 

Registration and Drug Listing 

• Step-by-Step Instructions for Creating Structured Product Labeling (SPL) Files for Drug 

Establishment Registration and Drug Listing 

• Structured Product Labeling Validation Procedures for Drug Establishment Registration 

and Drug Listing 

 

10 These forms can be referenced at http://www.fda.gov/opacom/morechoices/fdaforms/default.html. 

11 When we are ready to receive a particular submission type in electronic format only, we generally identify the 

specific type of document that FDA can process, review, and archive. This information can be found in the public 

docket 92S-0251 at regulations.gov. See 21 CFR 11.2(b)(2); see also Guidance for Industry: Part 11, Electronic 

Records; Electronic Signatures -- Scope and Application (August 2003). 

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Contains Nonbinding Recommendations 

See also Section IV of this document for discussion of these specifications and other information 

on creating the drug establishment registration and drug listing file for electronic submission. 

SPL format is already used for submission of content of labeling in electronic format as required 

in New Drug Applications (NDAs), Abbreviated New Drug Applications (ANDAs), Biological 

License Applications (BLAs), and annual reports on approved drugs.12 See Providing 

Regulatory Submissions in Electronic Format – Content of Labeling (April 2005).13 Because the 

content of labeling required under those provisions can be duplicative in content and format 

(SPL) of the labeling required to be submitted electronically as part of listing information, FDA 

encourages applicants to submit this labeling material, and updates, primarily through the drug 

establishment registration and drug listing system. Rather than make duplicate submissions, 

applicants are then encouraged to reference the SPL labeling file submitted through the 

electronic drug registration and listing system in making labeling updates to applications under 

the content of labeling requirements. FDA intends to issue guidance that will address this issue 

in further detail. 

Beginning June 1, 2009, FDA intends to use the electronic drug establishment registration and 

listing system as the source of SPL to provide postapproval content of labeling for public access 

on the Web, making that system the key repository of this information. 

III. DRUG ESTABLISHMENT REGISTRATION AND DRUG LISTING 

INFORMATION FOR ELECTRONIC SUBMISSION 

The following information should be submitted to FDA in the SPL file format described in the 

technical documents and the defined code sets and codes as described in section IV of this 

document. 

A. Drug Establishment Registration 

1. Who must register, when, and how? 

The owner or operator of an establishment entering into the manufacture, preparation, 

propagation, compounding, or processing (which includes, among other things, repackaging and 

relabeling) of a drug or drugs14 and not exempt under section 510(g) of the Act or subpart B of 

21 CFR part 207, must register the establishment with FDA within 5 days after beginning the 

operation (21 CFR 207.21(a) and 21 CFR 207.3(a)(8)). Alternatively, if the establishment has 

not previously entered into such an operation, the owner or operator must register within 5 days 

after submitting (among other things) a drug application, biological license application, or 

 

12 For regulations requiring submission of content of labeling in electronic format that FDA can process, review, and 

archive, see 21 CFR 314.50(l) (NDAs), 21 CFR 314.94(d) (ANDAs), 21 CFR 601.14(b) (BLAs), and 21 CFR 

314.81(b) (annual reports to marketing applications). 

13 http://www.fda.gov/cder/guidance/6719fnl.htm 

14 Means both human, including biological drug products, and animal drugs. 

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Contains Nonbinding Recommendations 

medicated feed mill license application. (21 CFR 207.21(a)). Owners or operators must renew 

their registration information annually (Section 510(b)(1) of the Act; 21 CFR 207.21(a)). 

Establishments within any foreign country that engage in the manufacture, preparation, 

propagation, compounding, or processing (which includes, among other things, repackaging and 

relabeling) of a drug that is imported or offered for import into the United States (and that are not 

exempt) must upon first engaging in such activity immediately register and register annually 

thereafter (Section 510(i) of the Act; 21 CFR 207.40). 

Amendments to drug establishment registration must be submitted in accordance with 21 CFR 

207.26. 

Section 510(p) of the Act, as amended by FDAAA, now requires drug establishment 

registrations to be submitted electronically unless a waiver is granted. Therefore, registration 

information should now be submitted electronically using SPL files with coded data fields.15

Failure to register in accordance with section 510 of the Act is a prohibited act under section 

301(p) of the Act. Also, under section 502(o) of the Act, a drug is misbranded if it is 

manufactured in an establishment in any State not duly registered under section 510 of the Act. 

2. What information is submitted for drug establishment registration? 

Section 510 of the Act and 21 CFR Part 207 set forth registration information required to be 

submitted by domestic and foreign drug establishments. (See sections 510(b), (c), (d), and (i) of 

the Act and 21 CFR 207.25(a), 21 CFR 207.26, and 21 CFR 207.40). Under these provisions, all 

registrants must provide the name and full address of each establishment, all trade names used by 

the establishment, the kind of ownership or operation (e.g., individually owned, partnership, or 

corporation), and the name of the owner or operator (including in the case of a partnership the 

name of each partner, and in the case of a corporation, the name and title of each corporate 

officer and director and the State of incorporation). 

In addition to the information required for all registered establishments, certain additional 

information must be provided to register a foreign establishment. For example, a foreign 

registrant must submit: 

• the name, address, and phone number of the foreign registrant’s United States agent 

(Section 510(i)(1)(A) of the Act and 21 CFR 207.40)c)); 

• the name of each importer that is known to the establishment (Section 510(i)(1)(A) of the 

Act). (This means each U.S. company or individual in the United States that is an owner, 

consignee, or recipient of the foreign establishment’s drug that is imported into the 

United States. An importer does not include the consumer or patient who ultimately 

 

15 As explained in section IV.C., of this document, once the SPL file is created it can be submitted (uploaded) by 

following the instructions for the FDA Electronic Submissions Gateway (ESG). There may be some delay in 

obtaining an ESG account; review section IV.C. for further information. 

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Contains Nonbinding Recommendations 

purchases, receives, or is administered the drug, unless the foreign establishment ships 

the drug directly to the consumer or patient.); and 

• the name of each person who imports or offers for import such drug (Section 510(i)(1)(A) 

of the Act). (This means the name of each agent, broker, or other entity, other than a 

carrier, that the foreign drug establishment uses to facilitate the import of their drug into 

the United States). 

To facilitate correspondence between registrants and FDA, foreign registrants should submit the 

email address for the U.S. agent, and the telephone number(s) and email address for the importer 

and person who imports or offers for import described in section III.A.2 of this document. 

Historically, registrants have also included additional drug establishment registration information 

when making submissions, using Form FDA 2656.16 Likewise, for electronic submission, 

registrants should submit the following additional information in their SPL file: 

• Official contact’s name, mailing address, telephone number(s), and email address; and 

• The type of operation(s) performed at each establishment. 

Under section 510(e) of the Act, FDA may assign a registration number to any person or 

registered establishment. FDA intends to use the Data Universal Numbering System (D-U-NS®) as the registration number for the electronic system. Therefore, to facilitate and expedite 

processing of the SPL file, the registrant should submit their D-U-N-S® Number with the 

registration information. If the business entity does not submit a D-U-N-S® Number with its 

submission, FDA intends to make arrangements for obtaining a D-U-N-S® Number for that 

entity. An explanation of the D-U-N-S® Number and how to obtain one is described in section 

IV.B of this document. 

B. Drug Listing 

1. Who must list, when, and how? 

Registrants not exempt under 21 CFR 207.10 must submit the initial listing information for all 

drugs17 in commercial distribution at the time of their initial registration of their establishment(s) 

(21 CFR 207.21(a)). 

Failure to provide any listing information required by section 510(j) of the Act is a prohibited act 

under section 301(p). Also, under section 502(o) of the Act, a drug is misbranded if it was not 

included in a list required by section 510(j) of the Act. 

 

16 See 21 CFR 207.22(a) and 21 CFR 207.25(a). As noted, with the amendment of section 510(p) of the Act in 

2007, registration information is required to be submitted electronically. Therefore, submission of such information 

on a particular paper form is no longer acceptable (absent grant of a waiver), and information should instead be 

submitted in accordance with this guidance document. FDA intends to amend the regulations to conform to the 

changes in the underlying statutory provision. 

17 Registration and listing requirements for drugs should also be met for combination products that include a drug as 

a constituent part, and for drugs intended as a constituent part of a combination product, regardless of which FDA 

center has the lead for review of the combination product (See 21 U.S.C. 503(g); 21 CFR part 3). 

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Contains Nonbinding Recommendations 

Although FDA does not accept drug establishment registration information from private label 

distributors (PLDs),18 PLDs may request their own NDC Labeler Code and elect to submit drug 

listing information to FDA. (21 CFR 207.20(b)). By submitting drug listing information, the 

PLD assumes full responsibility for compliance with the listing requirements. (21 CFR 

207.20(b)) In such instances, at the time of submitting or updating drug listing information, 

private label distributors must certify to the registered establishment(s) that manufactured, 

prepared, propagated, compounded or processed (which includes, among other things, 

repackaging and relabeling) the listed drug(s) that the drug listing submission was made (21 CFR 

207.20(b)). The certification to the registered establishment by the private label distributor may 

be satisfied using paper format. If a drug product is listed by the PLD, it should not also be listed 

by the owner(s) of the registered establishment(s) that manufactured, prepared, propagated, 

compounded or processed (which includes, among other things, repackaging and relabeling) the 

listed drug(s). 

Registrants (and, if applicable, private label distributors) must update their drug listing 

information, and include drugs that have been introduced for commercial distribution and have 

not previously been listed (Section 510(j)(2) of the Act; 21 CFR 207.21(b); 21 CFR 20720(b)). 

Any updates must be submitted every June and December (Section 510(j)(2) of the Act; 21 CFR 

207.21(b)). However, registrants (and, if applicable, private label distributors) are encouraged to 

submit updates through the registration and listing system more frequently as changes occur, 

including labeling updates required to be submitted under listing requirements (21 CFR 

207.21(b); 21 CFR 207.22(b); 21 CFR 207.25; 21 CFR 207.30), or labeling submission needed 

to fulfill obligations for electronic submission of content of labeling in connection with approval 

applications. (See section II of this document and footnote 12.) As previously discussed in 

section II of this document, because the drug listing system is a key repository for labeling, it is 

particularly important to keep this information up to date. 

Section 510(p) of the Act, as amended by FDAAA, now requires drug listing, including updates, 

to be submitted electronically unless a waiver is granted. Therefore, listing information should 

now be submitted electronically using SPL files with coded data fields. 

The electronic drug establishment registration and drug listing system will permit FDA to 

electronically populate the Agency’s listing databases and the NDC Directory and will, therefore, 

improve the inclusiveness and accuracy of these databases. 

2. What information is submitted for drug listing? 

Section 510 of the Act and 21 CFR Part 207 set forth the drug listing information required to be 

submitted by domestic and foreign drug establishments. (Section 510(j) of the Act; 21 CFR 

207.25(b) and (c); 21 CFR 207.30; 21 CFR 207.31; 21 CFR 207.40). For representative 

 

18 “Private label distributor” or “PLD” means an owner or operator of an establishment not otherwise required to 

register under section 510 of the Act, but who distributes under its own label or trade name a drug manufactured or 

processed by a registered establishment. (See 21 CFR 207.20(b)) 

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Contains Nonbinding Recommendations 

samples of advertising and labeling required under 21 CFR 207.25(b)(4) and (b)(5), only one 

need be submitted of each sample type, as described in 21 CFR 207.3(a)(9) and (a)(10). 

Historically, registrants have also submitted additional drug listing information on Form FDA 

2657 and Form FDA 2658.19 Likewise, for electronic submission, registrants should submit the 

following additional information in their SPL file: 

• Name of establishment(s) manufacturing or processing the listed drug and the type of 

operation(s) performed; 

• DEA schedule; 

• Route(s) of administration; 

• Inactive ingredients; 

• Marketing information (e.g., category, start/stop date)20; 

• Information related to the application (e.g., type and year of approval) or OTC 

monograph citation number; and 

• Package size and type. 

In addition to information that was previously submitted on Forms FDA 2657 and FDA 2658, 

the registrant should also submit: 

• NDC Product Code for a Source Drug Repacked or Relabeled 

Repackers and relabelers should submit the NDC Product Code for the source drug that is 

repacked or relabeled, in order to reference manufacturing establishment information submitted 

in the listing entry for the source drug. 

• Unique Ingredient Identifiers (UNII) and other code sets 

An explanation of UNII codes and other code sets and where they may be found is described in 

section IV.B of this document. 

• Confidentiality Flag 

Registrants (and, if applicable, private label distributor) may identify an inactive ingredient or 

the registrant’s business relationship with an establishment that they view as confidential when 

submitting registration and listing information. Pursuant to a Freedom of Information Act 

request or on our own initiative, FDA will ultimately make determinations as to whether drug 

establishment registration and drug listing information can be disclosed to the public pursuant to 

 

19 See 21 CFR 207.22 and 21 CFR 207.25(b). As noted, with the amendment of section 510(p) of the Act in 2007, 

listing information is required to be submitted electronically. Therefore, submission of such information on 

particular paper forms is no longer acceptable (absent grant of a waiver), and information should instead be 

submitted in accordance with this guidance document. FDA intends to amend the regulations to conform to the 

changes in the underlying statutory provision. 

20 The expiration date of the last lot released to the marketplace is considered a stop-date. 

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Contains Nonbinding Recommendations 

the Trade Secrets Act, the Freedom of Information Act, and other applicable law (e.g., section 

510(f) of the Act and 21 CFR 207.37).21

• Distinctive Characteristics of Certain Listed Drugs 

Registrants (and, if applicable, private label distributors) should provide the following 

characteristics for the listed drug, when applicable. Registrants (or private label distributors) 

have previously provided these characteristics voluntarily as helpful information for the safe and 

effective use of their products. 

o Flavor 

When applicable, the registrant (and, if applicable, private label distributor) should provide the 

flavor as a unique distinguishing characteristic of the listed drug. (Registrants have previously 

provided this information on Form FDA 2657 as an ingredient.) 

o Color 

For liquid dosage forms, the registrant (and, if applicable, private label distributor) should 

provide the color as a unique distinguishing characteristic. This may be useful to assist in 

judging whether a change in color may indicate contamination or to avoid confusion of the 

intended color of a solution with contamination. 

o Image 

For solid oral dosage forms, the registrant (and, if applicable, private label distributor) may 

submit an image of the actual dosage form. This information is helpful in identifying the drug, 

for example in order to help determine that the correct drug has been dispensed. The registrant 

can obtain instructions on obtaining the image and the proper format in the SPL file by following 

the instructions for technical assistance in section IV.D of this document. 

IV. CREATING THE DRUG ESTABLISHMENT REGISTRATION AND DRUG 

LISTING FILE FOR ELECTRONIC SUBMISSION 

A. Structured Product Labeling 

SPL is the standard that FDA intends to use for the exchange of drug establishment registration 

and drug listing information and is based on the Health Level Seven (HL7) version 3 Reference 

Information Model (RIM) and the Clinical Document Architecture (CDA). 

FDA uses SPL for electronic submissions of drug establishment registration and drug listing 

information. The technical details on using SPL for registration and listing are available in the 

 

21 Other elements of listing information, including the marketing date and application ,information described above, 

will help FDA to determine the confidentiality of listing information, including labeling, submitted for drugs still 

under premarket review. 

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Contains Nonbinding Recommendations 

document Structured Product Labeling Implementation Guide for FDA Drug Establishment 

Registration and Drug Listing (SPL Implementation Guide). 

FDA has been accepting SPL files for certain product information since 2004, and vendors have 

provided solutions for creating SPL files ranging from basic software tools to comprehensive 

information management systems. Additionally, FDA has collaborated with GlobalSubmit on 

software to create SPL files based on XForms technology. Information on using the XForms is 

available in the document Step-by-Step Instructions for Creating Structured Product Labeling 

(SPL) Files for Drug Establishment Registration and Drug Listing. 

These documents are on the FDA Data Standards Council website, 

http://www.fda.gov/oc/datacouncil/spl.html. 

B. Code Sets and Codes 

To facilitate FDA’s ability to process, review, and archive electronic submissions, code sets and 

codes are used as a language that is recognized by a computer system. FDA has been working 

with a number of organizations to develop and maintain such code sets and codes used for 

submitting drug establishment registration and drug listing information electronically. Many 

code sets and codes are already available at the Data Standards Council website 

(http://www.fda.gov/oc/datacouncil/spl.html), and FDA is continuously updating these codes sets 

and adding codes. Information on the organizations that maintain the code sets for submitting 

drug establishment registration and drug listing information electronically and how to obtain the 

code sets and codes used for electronic drug registration and listing follows. 

1. Unique Ingredient Identifiers (UNII) 

UNII is the defined code FDA uses for ingredients/substances. FDA along with United States 

Pharmacopeia (USP) maintains the UNII using the FDA Substance Registration System. These 

names and identifiers are accessible through USP website at http://www.usp.org and 

publications, the Data Standards Council website (http://www.fda.gov/oc/datacouncil/spl.html) 

and the NCI Thesaurus website at http://evs.nci.nih.gov. Additional ingredient identifiers may be 

requested through FDA by sending a request to spl@fda.hhs.gov. 

2. Data Universal Numbering System (D-U-N-S®) Number22

Dun & Bradstreet assigns and maintains a database of the D-U-N-S® Numbers, which serve as 

unique identifiers (codes) of business entities. Upon application, each business entity (e.g., 

registrant, establishment, importer, US agent) is assigned a distinct site-specific 9-digit D-U-NS® Number. The site-specific D-U-N-S® Number for an entity is a useful resource for FDA in 

identifying and verifying certain business information for that entity, e.g., trade names used by 

the entity, addresses, additional ownership information, such as the name of each partner or the 

 

22 D-U-N-S® Numbers are proprietary to and controlled by Dun & Bradstreet (D&B). Where practicable, the 

customer will refer to the number as a “D-U-N-S® Number” and state that D-U-N-S is a registered trademark of 

D&B. 

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Contains Nonbinding Recommendations 

name of each corporate officer and director, and the State of incorporation. If the D-U-N-S® 

Number for a location has not been assigned, a business may obtain one for no cost directly from 

Dun & Bradstreet (http://www.dnb.com). If the business entity does not submit a D-U-N-S® 

Number with its submission, FDA intends to make arrangements for obtaining a D-U-N-S® 

Number for that entity. 

3. Other code sets 

FDA collaborates with the National Cancer Institute Enterprise Vocabulary Services (NCI EVS) 

to maintain code sets for dosage form, routes of administration, package types, DEA schedule, 

product color, product shape, flavors, business operations, marketing categories and equivalence 

codes. These code sets are located in the NCI Thesaurus and may be accessed through the NCI 

EVS website at http://evs.nci.nih.gov and the Data Standards Council website (see section II of 

this document). Additional code sets and codes for use in registration and listing may be 

requested though FDA by sending a request to spl@fda.hhs.gov. 

The Regenstrief Institute23 maintains a number of different code sets used in electronic drug 

establishment registration and drug listing including: document types, section headings, and units 

of measure. These code sets are located in the Logical Observation Identifiers Names and Codes 

(LOINC) and Unified Codes for Units of Measure (UCUM) systems. Both of these 

terminologies are available at http://www.regenstrief.org and at other locations. Additional code 

sets and codes may be requested through FDA by sending a request to spl@fda.hhs.gov 

following the instructions in section IV.D of this document. 

C. Submission and FDA Validation of Electronic Drug Establishment 

Registration and Drug Listing Information 

The SPL file should be created following the technical specifications in the SPL Implementation 

Guide and other information found in this document. Other resources for creating the SPL file, 

including a link to a user-friendly software tool (XForms), are also available.24 Once the SPL 

file is created, it can then be submitted (uploaded) by following the instructions for the FDA 

Electronic Submissions Gateway (ESG), including digital certification.25 

The process for establishing an ESG account may involve a delay before drug registration and 

listing information can be received electronically by FDA. FDA encourages owners and 

operators subject to registration and listing to establish their ESG accounts as soon as possible; 

establishing an ESG account 4-6 weeks in advance of the time when the owner or operator must 

register, list, or update a registration or listing will best ensure that electronic submissions are not 

delayed. 

 

23 The Regenstrief Institute is an internationally recognized informatics and healthcare research organization. 

24 See http://www.fda.gov/oc/datacouncil/spl.html for additional resources, terminology, and data standards 

regarding the SPL files. See http://www.fda.gov/oc/datacouncil/xforms.html for information on the user-friendly 

software tool. 

25 See http://www.fda.gov/esg/default.htm for information on other resources and using the FDA ESG. 

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Contains Nonbinding Recommendations 

FDA recognizes that there may be a delay between the time an owner or operator requests an 

ESG account and the time the account is established and can upload submissions. Provided the 

owner or operator requests an ESG account before the due date of their first electronic 

submission, FDA intends to exercise enforcement discretion and does not intend to initiate action 

based on a first electronic submission that is late if the owner or operator also makes the required 

submission (e.g., registration, listing, or update) within 30 days following establishment of an 

ESG account. 

FDA uses a computer system for processing the SPL files using controlled code sets and codes. 

The computer system automatically checks the SPL files for certain errors, mistakes and 

omissions prior to entering the information into FDA systems. FDA will work with companies 

to help correct identified problems in order to complete the registration and listing process. 

Information on the details used in checking SPL files for electronic drug establishment 

registration and drug listing are in the document FDA’s Structured Product Labeling Validation 

Procedures for Electronic Drug Establishment Registration and Drug Listing.

26 This document 

is on the Data Standards Council website (see section II of this document). 

D. Technical Assistance 

For technical problems or assistance with creating SPL files, send an email to spl@fda.hhs.gov. 

V. IMPLEMENTATION 

Beginning June 1, 2009, FDA intends to no longer accept drug establishment registration and 

drug listing information in paper format unless a waiver is granted. 

VI. WAIVER REQUEST 

Under section 510(p) of the Act, registrations and listings (including the submission of updated 

information) must be submitted electronically unless FDA grants a waiver of such requirement 

because use of electronic means is not reasonable for the person requesting such waiver. FDA 

does not anticipate many instances in which electronic submission of registration and listing 

information will not be reasonable for the person requesting the waiver. However, if you are 

granted a waiver, you will be instructed as to how to submit the registration and listing 

information. 

To apply for a waiver from the requirement to electronically submit drug establishment 

registration and drug listing information, provide a written request with a complete explanation 

of why use of electronic means is not reasonable for you. Submit the request to: 

 

26 This document is used by FDA and describes FDA’s computer instructions for automating the validation of 

submitted SPL files containing registration and listing information. 

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Contains Nonbinding Recommendations 

 13

SPL Coordinator 

U.S. Food and Drug Administration (HF-18) 

5600 Fishers Lane 

Rockville, MD 20857-0001 

Phone: 1-888-463-6332 

VII. PAPERWORK REDUCTION ACT OF 1995 

This guidance contains information collection provisions that are subject to review by the Office 

of Management and Budget (OMB) under the paperwork Reduction Act of 1995 (44 U.S.C. 

3501-3520), 

The time required to complete this information collection is estimated to average 4.5 hours per 

response, including the time to review instructions, search existing data sources, gather the data 

needed, and complete and review the information collection. Send comments regarding this 

burden estimate or suggestions for reducing this burden to spl@fda.hhs.gov.

This guidance also refers to previously approved collections of information found in FDA 

regulations. The collections of information in Part 207 have been approved under OMB Control 

No. 0910-0045. 

 

An agency may not conduct or sponsor, and a person is not required to respond to, a collection of 

information unless it displays a currently valid OMB control number. The OMB control number 

for this information collection is 0910-0045 (expires 3/31/2012).